ML20203C124

Transcript of 980219 Meeting in Rockville,Md W/Northeast Nuclear on Millstone - Public Meeting.Pages 1-175.W/ Supporting Documentation

ML20203C124
Person / Time
Site:	Millstone
Issue date:	02/19/1998
From:	NRC COMMISSION (OCM)
To:
References
REF-10CFR9.7 NUDOCS 9802250076
Download: ML20203C124 (332)

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OR 3 AAL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3

Title:

MEETING WITH NORTHEAST NUCLEAR ON MILLSTONE -- PUBLIC MEETING Location: Rockville, Maryland Date: Thursday, February 19,1998 Pages: 1 - 175

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DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on I February 19, 1998, in the Commission's office at One White Flint North, Rockville, Maryland, The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected or edited. and it may contain

! inaccuracies.

The transcript is intended solely for general informational purposes. As provided by 10 CFR 9,103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs, No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize, U

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UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3 ***

4 MEETING WITH NORTHEAST NUCLEAR ON MILLSTONE 5 ***

6 PUBLIC MEETING 7 ***

8 3

9 Nuclear Regulatory Commission 10 Commission Hearing Room 11 11555 Rockville Pike

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12 Rockville, Maryland l 13 14 Thursday, February 19, 1998 15 16 The Commission mec in open session, pursuant to 17 notice, at 9:30 a.m., the Honorable SHIRLEY A. JACKSON, 18 Chairman of the Commission, presiding.

19 20 COMMISSIONERS PRESENT:

21 SHIRLEY A. JACKSON, Chairman of the Commission 22 GRETA J. DICUS, Member of the Commission 5

23 NILS J. DIAZ, Member of the Commission 24 EDWARD McGAFFIGAN, JR.,

Member of the Commission 25 ANN RILEY & ASSOCIATES, LTD.

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2 1 1 STAFP AND PRESENTERS SEATED AT COMMISSION TABLE:

2 MIKE MORRIS, Chairman, President and CEO, 3 Northeast Utilities 4 BRUCE KENYON, President and CEO, Northeast Nuclear i

5 Energy Company  ;

I 6 DAVE GOEBEL, Vice President, Nuclear Oversight 7 MIKE BROTHERS, Vice President, Nuclear Operations 8 MARTIN BOWLING, Vice President, Unit 2 9 DAVID AMERINE, Vice President, Human Services 10 BRIAN ERLER, Senior Vice President, ICTVP Project 11 Director, Sargent & Lundy 12 DON SCHOFFER, Vice President and Verification 13 Manager, Sargent & Lundy 14 DAN CURRY, Vice President, Nuclear Services, 15 Parsons Power 16 ERIC BLOCHER, Deputy Project Director, Parsons 17 Power 18 JOHN GRIFFIN, Deputy Team Leader, Little Harbor 19 Consultants 20 JOHN BECK, President, Little Harbor Consultants 21 BILLIE GARDE, Consultant 22 L, JOSEPH CALLAN, EDO 23 DR. WILLIAM TRAVERS, Director, Special Projects 24 Office, NRR 25 ANN RILEY & ASSOCIATES, LTD.

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STAFC AND PRESENTERS SEATED AT COMMISSION TABLE:

2 (continued) 3 WAYNE LANNING, Deputy Director for Inspections, 4 SPO, NRR 5

PHILLIP McKEE, Deputy Directcr for Licensing and 6 Overcight, SPO, NRR 7 EUGENE IMBRO, Deputy Director for ICAVP, SPO, NRR 8

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4 1 PROCEEDINGS 1 l

2 [9:30 a.m.)

3 CHAIRMAN JACKSON: Good morning, ladies and l

4 gentlemen, 5 The purpose of this meeting is for the Commission 6 to be briefed on the status of activities related to the 7 three Millstone nuclear power reactors, 8 The Commission will hear presentations today from ,

9 Northeast Utiaities, Northeast Nuclear; contractors 10 associated with both the independent corrective verification 11 program; and employees concerns program; and the NRC staff, 12 Millstone Unit 1 has been shut down for over 27 13 months; Units 2 and 3 for approximately two years now. All 14 three of the Millstone units were placed on the NRC's watch 15 list in January 1996. The units were recategorized as 16 category 3 plants in June 1996. This action necessitates 17 Commission approval for restart of each of the units.

18 This Commission meeting is the fifth quarterly 19 meeting to assess the status of activities at the sites, 20 This meeting was scheduled two months after the last meeting e

21 in order for the Commission to better assess the results of 22 some of the significant inspections that recently have ,

23 occurred or are in process now.

24 In the interest of maintaining our schedule, I 25 will keep my opening comments short. I have recently ANN RILEY & ASSOCIATES, LTD.

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5 1 visited the Millstone site and conducted a public meeting 2 while I was there in the evening to listen first-hand to 3

comments and statements and concerns of the various members 4 of the local community and other stakeholders. I have made 5 available at the entrances to the meeting my comments from 6 this public meeting on February 2nd, 1998.

7 The Commission is interested in status updates a from all participants today to gauge how the licensee is v

9 measuring and tracking its progress, and as I stated at the 10 last Coimmiss4cn meeting, to understand how well the site is 11 functioning as a whole.

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12 Once again, all parties should feel not only 13 invited to but compelled to comment on questions asked of 14 any group. But if your turn at the table has passed, I ask 15 that you use the podium as necessary.

10 Copies of the presentation material are available 17 at the entrances to the meeting, ana unless my colleagues 18 have any opening comments, Mr. Morris, please proceed.

19 MR. MORRIS: Thank you, Chairman Jackson and 20 colleagues. Thanks for being here, It's nice for us to

• 21 come back and give you this update. We are here to 22 represent the company. We have w3th us members of our board 23 of trustees as well as the chair ut our nuclear committee, 24 oversight group, and we are happy that they are here to be 25 with us today. What we intend to do today with Mr. Kenyon ANN RILEY & ASSOCIATES, LTD.

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6 1 and his team is to update you on the results that continue 2 to be evaluated at the Millstone station. In fact, some 3 indicators aren't as good as we had hoped that they would 4 bo, and we will talk about that. Fortunately, some 5 indicators are much better than we thought they would be, 6 and we will surely talk about that as well.

7 But as we go through this -- and I know from ycur 8 trip at the site, I hope that you will sense the feeling of ,

9 the people of this stntn and the positive attitude that is 10 beginning to grow at the station as we get nearer and nearer 11 what we hope to be the opportunity to bring the stations 12 back on line, Unit 3 in particular.

13 We -- I felt very strongly about one of the 14 comments you made at that meeting when you looked at the 15 people in the audience that night and said that your 16 decision, along with your colleagues', would be based on

( 17 results, and that the results were up to the people in that 18 audience which, as you will remember, was surely dominated 19 by Millstone people. That was an excellent comment bectuse

-20 it's those people who are going to get this job done for us.

21 And we will give you that data as quickly and succinctly as 22 we can and as straightforwardly as we can. So we appreciate ,

23 this opportunity to come back and give you that update.

24 With that, I will turn it over to Bruce.

25 MR. KENYON: Good morning. The purpose of our ANN RILEY & ASSOCIATES, LTD.

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1 presentation is to highlight the progress that has been made 2 in preparing for the restart of Unit 3, to review the 3 criteria we intend to utilize as the basis of our restart 4 affirmation, and this is new to the briefing book, to 5 discuss our most important remaining issues -- these include l

6 our efforts to progress toward establishing a 4

7 safety-conscious work environment, and Dave Amerine, who is 8 the officer who integrates safety-conscious work 9 environment, human resources and training matters, reporting 10 to Mike Brothers, will brief you on

• chat. And other matters 11 are approaching completion of demonstrating compliance with 12 the' Unit 3 design and licensing basis, Marty Bowling will 13 brief you on this topic as wel] as the topic of corrective 14 action. And Mike Brothers will discuss progress toward 15 achieving Unit i restart readiness.

16 Certainly I want to have oversight briefly update 17 you regarding its assessment of our restart readiness, and 18 that will be done by Dave Goebel.

19 We plan to focus cn Unit 3 and site issues 20 relating to Unit 3, but we are prepared to address questions 21 on other units, should you desire.

5 22 We have provided considerable information to you 23 in advance of the meeting, in the form of both the briefing 24 book and copies of the slides for presentation. For the 25 most part, the format and content are similar to what you ANN RILEY & ASSOCIATES, LTD.

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8 1 have received previously. We added the description in 2 considerable substance regarding the long-term improvement 3 plan. We revised a few of the indicators to more clearly 4 display our status, and in so doing, to eliminate some 5 previous apparent discrepancies between what we were 6 describing as our progress and the data as displayed by your 7 indicacor. We substantially expanded the executive summary 8 with the objective of that being a much more comprehensive ,

9 presentation of our current state of readiness prognosis and 10 issues.

11 We did not make any changes to the slides after 12 thei~r transmittal to you. Your admonishment from the last 13 meeting was very clear and understood, and we trust that 14 this information and these adjustments have been helpful to 15 you.

16 The balance of my portion of the presentation will 17 be devoted to highlighting certain items from the executive 18 summary, 19 This slide shows four of the eight criteria to be 20 used by NU as a basis for affirming restart readiness. Now 21 these eriteria were discussed in some detail in the 22 executive summary of the briefing book, two of the four, and ,

23 these deal with root causes as well as self-assessment 24 corrective action. We view these as currently satisfactory.

25 The other two, compliance with the licensing and design  ;

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bases and safety-conscious work environment, are tracking to 2 satisfactory. These topics will be covered later in more 3 detailed presentations.

4 This next slide shows the remaining four criteria.

5 Unit and station readiness are tracking to satisfactory, and l l

6 will be discussed in subsequent presentations. Management  !

7 controls and oversight are satisfactory and, of course, 8 restart affirmation is pending.

t 9 Now this slide and the next summarize the progress 10 we have made in addressing the seven success objectives and

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11 the associated 16 key sitewide issues. These have been 12 discussed in previous briefings and are an essential part of 13 our recovery strategy.

14 I am pleased to report that of the 16 issues, nine 15 now meet our success criteria for start-up readiness. This 16 is a net improvement of three since our last meeting to have 17 reached satisfactory for restart. And on this particular 8 slide, emergency planning, self-assessment and corrective 39 action for Uni: 3 all move to a satisfactory status.

20 However, based on having identified an adverse 21 trend on procedure adherence, particularly pertaining to 22 administrative procedures, the status of procedure quality 23 adherence was reduced from satisfactory to tracking to 24 satisfactory, and we expect to have this resolved by the end 25 of the month.

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10 1 This next slide shows the remaining issues. The 2 one significant change on this slide from last time is that 1 3 environmental compliance moved to satisfactory. The other l 4 five issues are tracking to satisf actory for February.

5 Now I particularly want to comment on training, 6 which I had expected to reach satisfactory by the end of 7 January. Progress has not met expectations, 8 Further, as a result of a management assessment ,

9 followed by an investigation, it was determined that with 10 regard to in-process trtining for the shift technical 11 advisors, the requirements of a systems approach to training 12 were not rigorously followed, and there were instances of 13 improper documentation.

14 Now these are significant issues, we are 15 addressing these issues, management changes have been made, 16 and we are committed to achieving the proper standards, but 17 we do not expect this matter to affect the Unit 3 recovery 18 schedule.

19 Now this slide indicates what I believe are the 20 most important remaining challenges to bring Unit 3 to 21 restart readiness. Now the first is to complete the process 22 of establishing a safety-conscious work environment. There ,

23 is one remaining criterion, that is the timely recognition 24 and effective response to problems. This was identified as 25 a key challenge at our last briefing, and while we have IJRJ RILEY & ASSOCIATES, LTD.

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taken a number of important steps to strengthen performance, l

2 the entire situation is overshadowed by a recent 3 high-profile event, the use of an inappropriate phrase in 4 working papers, and that situation is still in progress.

5 CHAIRMAN JACKSON: Let me stop you for a second i 6 with respect to that, and ask you the following question.

7 And I realize that, as you say, it's still in-progress, and 8

I assume by that you mean that you are still investigating 9 or looking into it. But given the level from which it came, 10 or the level at which it was signed off, did you ever give 11 any thought to having a work standdown to just directly i

12 addresa the issue and to solicit your employees' thcughts 13 about that? Given that, you know, you have had the intense 14 focus on physical readiness of the plant for restart, in 15 terms of what message this might have sent to your employees 16 about your level of concern in terms of what chilling effect 17 it may have had even if it had been inadvertent?

18 MR. KENYON: What we have done, Chairman Jackson, 19 is add a nur.ber of site meetings. I don't know ; hat they'd 20 necessarily be classified as everybody at one point in time, 21 but we responded right aw:y with meetings, both in oversight 22 and elsewhere on the site. We got together all of 23 supervision. We communicated, not just verbally but in

-24 writing, not just to our employees and the entire site work 25 force but also to the public, that that particular phrase ANN RILEY & ASSOCIATES, LTD.

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12 1 --which was not really signed out -- what this was was a 2 working paper developed to describe strengths and weaknesses 3 in the uversight organization. It was a work in progress.

4 The next step in the process was for that to be discussed 5 with first-line supervisors and above in oversight, and they 6 correctly said that phrase is inappropriate. And so that 7 was good, and we have done a review for chilling effect, and 8 we have determined that there is none, which I think speaks ,

9 well not just to the fact that there is r.ot a chilling 10 effect, but it also speaks to the growing resilience of the 11 work force, and that something that can happen, and we now 12 have an environment where there's a lot greater trust than 13 what there used to be.

14 Now I am not in any way saying this wasn't a l

15 seriour event. We are conducting an investigation; it has 16 resulted in a verbal debrief to me yesterday. I expect a 17 written report in about two weaks. This is taking somewhat 18 longer than I would like, and that may be the basis of some 19 criticism, but I want to underscore the following --

20 CHAIRMAN JACKSON: In terms of your verbal 21 debrief, are there any preliminary conclusions that you are 22 willing to share with the Commission?

23 MR. KENYON: Chairman Jackson, with all due 24 respect, I think this is not the time and the place to 25 indicate the conclusions. This is an extremely important ANN RILEY & ASSOCIATES, LTD.

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13 1 matter. The integrity of the organization and certain 3

2 people's careers are at stake. It is very important that I 3 get the facts, and while I have a verbal debrief, the issues 4 in this are complicated; it's taken longer than I thought, 5 because as the investigation was accomplished, there were 6 certain conflicts in what was said by people giving their 7 views that required a second round of interviews in some 8 cases, and even in some cases it went to a third round.

N 9 While I have certain thoughts in my mind as to 10 what the ultimate outcome is going to be, I feel that given 11 the importance of this, there are certain things I want to 12 see' written down. In other words, the investigator who has 13 done this has -- yes, he's given a verbal debrief, but he 14 also needs to write up the inve nigation results with each 15 principal witness. He needs to take all that information 16 --

CHAIRMAN JACKSON: " hat's fine.

17 On February the 10th, the NRC sent you a letter 18 requesting within 30 days your response to several questions 19 related to chilling effect, enforcement under 50.7. You 20 intend then to fold the results of this investigation into 21 answering that under-oath-and-affirmation letter?

22 MR. KENYON: Absolutely.

23 Another challenge is to complete the process of r

24 demonstrating compliance with the design and licensing 25 bases.

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14 1 CHAIRMAN JACKSON: Let me stop you again, because 2 I feel that I want to get all the issues onto the table here 3 right from the beginning. You know, I have just read and 4 had a short briefing on -- and all of the Commissioners have 5 copies -- of an event notification on Millstone 3 that the 6 NRC has just received, and I believe, you know, we have to 7 try to be as open and straightforward about this as we can, 8 not to blind-side you, but presumably you know about it  !

9 since it was a notification that came from your station.

10 But the notification, at least on the surface, 11 appears troubling for numerous reasons. It states that a 12 condition could occur that could result in the failure of 13 the heat removal -- residual heat removal pump due to 14 inadequate cooling, and that since both pumps have a similar 15 design, this could lead to a common mcde failure.

16 Now from my briefing, I understand that a 17 motor-operated valve on the rer',rc line of the RER pump 18 senses a pressure spike on pump start which closes the 19 valve, and that an emergency work request was initiated, and 20 that a subsequent test confirmed the problem, but the issue 21 in the emergency work request was placed on the deferrt.1

• 22 list, that is for work to be done post-restart, but that, 23 you know, NRC review of the deferrable items list questioned 24 this condition, resulting in further review by you, and this 25 event notification.

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15 1 I guess I have a couple of questions I just want 2 to walk through with you, if you would.

3 When was the original testing completed?

4 MR, KENYON: I am going to have to refer to Mike 5 Brothers.

6 MR. BROTHERS: The original condition was actually 7 dircovered in the 1986 '87 time frame for the cycling on the 8 alpha train.

9 CHAIRMAN JACKSON: And when were subsequent tests 10 performed?

11 MR. BROTHERS: The subsequent tests were performed

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12 about six weeks ago.

13 CHAIRMAN JACKSON: And can you tell me a little 14 bit more about your reasons for placing it on the deferred 15 items list and was it reexamined after these subsequent 16 testing failures?

17 MR. BROTHERS: Yes. The condition occurs -- was 18 conservatively reported as potentially affecting both trains 19 because the logic of the arrangement is the same between the 20 two trains. It's only observed on one train primarily 21 because of the location of the orifice that devalops the 22 differential pressure that inputs to this signal to the 23 recirculation valve that you correctly described.

24 The event that actually has to occur is a break of 25 particular size -- in other words, a break that stabilizes ANN RILEY & ASSOCIATES, LTD.

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16 1 at a reactor coolant system pressure, at a fairly low level 2 below the injection point of residual heat removal at about 3 400 pounds, but high enough such that you can get into a 4 cycling mode.

5 Effectively what's postulated here is that the 6 valve closes based upon a pulse across this orifice, and 7 then when it times out, and by the time it reopens, it once 8 again sees the same type of condition if the break si:c has 9 caused the reactor coolant system to stabilize at a l 10 particular pressure.

11 We had contacted the nuclear steam system 12 supp' lying vendor and asked for the probability of a break of 13 this size. It is considered a very low probability that a 14 particular break of this size would in fact occur, but if 15 you postulate this particular break size, you can get into a 16 cycling mode which causes a potential of a thermal overload 17 failure, and then the valve could fail either open or 18 closed. And depending upon reactor coolant system pressure, 19 if it's a high pressure, the valve failing closed is the 20 worst case because tn the pump doesn't have enouch flow to j 21 keep it cool. If it's a very low pressure, the valve 22 failing open is a problem because you could be robbing flow ,

23 that should be going into the core in this condition.

24 So depending upon reactor coolant system pressure, i

25 the valve fai: mode is worse, depending whether it's open 1

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17 1 or closed was really indeterminate. We did go back and look 2 at it based upon questions from the Nuclear Regulatory 3 Commission and sent out the prompt report yesterday.

4 CHAIRMAN JACKSON: How would you assess this in 5 terms of significance level?

6 MR. BROTHERS: I don't yet have all the details.

7 I think it's very significant. We are in fact going to look 8 at it very hard from a process standpoint. We think it's a l'

9 low probability event. I believe that that would be 10 concurred upon. However, it appears that it may have been 11 narrowly assessed from the standpoint of the recirculation 12 valv'e cycling which we have normally seen as once. We have 13 never -- of course, we have never had a break in this 14 condition, but what you normally see is the valve cycle, it 3 was considered a nuisance, and evaluated as such. It was 16 probably too narrow of an evaluation.

17 CHAIRMAN JACKSON: Do you feel this indicates some 18 potential vulnerability in your corrective action program, 19 at least with respect to effective root cause and timeliness 20 of resolution? You indicated that the original testing was 21 back in the 1986 time frame.

22 MR. BROTHERS: The condition that I described has 23 been known for some time. It was just simply treated as a 24 nuisance. This arrangement is generic for Westinghouse 25 plants. It may be a Part 21 issue associated with MDJ RILEY & ASSOCI ATES, LTD.

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18 1 Westinghouse. So we knew about it, we have dealt with it 2 for some length of time on a fairly narrow basis. I think 3 from the standpoint of the deferrable items list, that we 4 need to take a look from lessons learned on this one as 5 well.

6 MR. KENYON: But just to emphasi e, Chairman 7 Jackson, we are talking about a situation where a very low 8 probnbility event, some -- and I'm not trying to argue this, ,

9 but some believe it's not even a credible event, and 10 certainly once the possibility of the broader interaction 11 was identified, we have gone forward from there. So we are 12 talkIing about something that is low probability, but 13 certainly we want to be conservative about it, and certainly 14 once it's identified, we want to thoroughly pursue it. It's is not, as Mike Brothers indicated, it's not an issue that's 16 unique to us, we think. So it's something that we'll be 17 responsible about, and chase. We --

18 CRAIRMAN JACKSON: Well, I guess the issue for me.

15 and I'll just leave it on the table, is this: There is the 20 specific issue related to the specific system, with all the 21 issues of whether it's a Part 21 issue, whether it's been 22 quote, unquote, known about. But it is an issue that .

23 relates to the potential inoperability of your ultimate heat 24 sink, the ECCS system. It is one that had been uncovered 25 during previous testing, and to the extent that you in fact IJRJ RILEY & ASSOCIATES, LTD.

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19 1 continuously say it was something that was known about, then 2 again, particularly known about for over a decade, then it 3

raises questions about the narrowness of focus in getting to 4 the root cause when there was an anomaly in the testing in 5 your ultimate heat sink. And that, I think, is the issue 6 because it's not a question of whether some people think 7 that is credible or not credible. It has to do with t i 8 something that could render your ultimate heat sink 9 potentially inoperable, and it has to do with narrowness of 10 point of view as well as getting to the fundamental root 11 cause in something that's been around for over a decade.

12 And'so that's the message in this from my perspective. And 13 there's not a whole lot of explaining away there can be with 14 respect to those things.

15 Would you go on?

16 MR. KENYON: Another challenge is to achieve Unit 17 3 readiness.

18 CHAIRMAN JACKSON: And because it does raise 19 issues about your deferred items list, because you, you 20 know, that's been a concern, period. And now this issue 21 comes up at the zeroth hour, before this meeting, that is.

22 MR. KENYON:

. Another issue is to achieve Unit 3 23 readiness. We expect to achieve readiness for Mode 4 next 24 week. This will provide an important opportunity to heat 25 the unit up to normal operating temperature-and pressure in Mm RILEY & ASSOCIATES, LTD.

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1 order to further check out systems.

2 CRAIRMAN JACKSON: Is this a systetn that is needed 3 for Mode 4?

4 MR. KENYON: Yes.

5 It also will allow us to close out a substantial 6 number of remaining items required for restart as part of 7 the process. We recognize the need to address this issue, 8 to address the recirculation spray system to the NRC's ,

9 satisfaction before entry into Mode 4, and there's -- that's 10 seen a recognized issue and we have a meeting with the NRC l 11 staff this afternoon to further discuss that.

12 We also recognize a challenge to manage 13 nonrestart-related work items to an acceptable level, This 14 obviously goes right into just what we've been talking 15 a.' ' ou t .

16 We have put together a process to determine 17 whether or not an item's deferrable, and certainly that 18 process is dependent on how you look at it, and we do have 19 this question of the cycling of a valve, was that looked at 20 too narrowly. For what we understood it to be, it was 21 legitimate to defer it, for understanding it to be something 22 more than that, then it's not likely to be an appropriate ,

23 item to defer. And we will as a result of this look back 24 through our screening and come to some further conclusion as 25 to whether the screening has been right, but up to now we ANN RILEY & ASSOCIATES, LTD.

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have felt that we have applied appropriate screening.

l 2 CHAIRMAN JACKSON: Do you feel your ECCS system is 3 important?

4 MR. KENYON: Absolutely.

5 CHAIRMAN JACKSON: Okay.

6 MR. KENYON: And in response to the NRC's very 7 broad question on backlog, and of course that goes into how

) 8 do you define backlog, in response to how we were asked to ls j 9 define it. we have provided a listing of items to the staff

! 10 which is very encompassing. It's not just those that are il risk and safety significant. It's not just those that 12 represent physical work. But everything that we're tracking 1

13 in the way of plant betterment, enhancements,

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1 14 clarifications, drawing upgrades -- I mean, there's a lot 15 here.

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. 16 The paperwork in process, condition reports, this i

17 is all what we're tracking, and thus when you cast the net 18 that widely, you come up with what appears to be a fairly 19 sizable number. But we have assessed not just individual 20 items but we've assessed the aggregate using PRA techniques, 21 so we're comfortable that the totality of the backlog is 22 acceptable for startup.

23 CHAIRMAN JACKSON: Now my staff tells me in fact 24 that if you look at this particular situation and you look 1

25 at what may dominate a cora damage event, that this is e

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1 22 1 nonnegligible in that regard. And, you know, the . ssue is 2 not to get into, you know, a debate specifically about this, 3 but the two points I really want to make is, this issue 4 about nonrestart backlog, the question is whether you may 5 need to reevaluate what you call nonrestart versus restart.

6 That's No. 1.

7 A second point has to do with an embedded issue 8 with respect to corrective actions has been timeliness of ,

9 the fix, as well as comprehensiveness of the analysis that 10 leads to it, and again, and I know the message you're trying 11 to project to us today, and we have a responsibility to

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12 listen to you, but, you know, I can't reemphasize more 13 strongly the need to take this and to propagate it as a 14 lessons learned into what you do.

15 MR. KENYON: And, Chairman Jackson, we will do 16 that, so I'm struggling a little bit to deal with an issue 17 that just surfaced which we need to put through our process 18 and ask us just the same questions that you're asking, and 19 thus we need to respond to that, so I'm trying in a sense to 20 take that one issue and assure you that we're going to deal 21 with that.

22 CHAIRMAN JACKSON: Well, it's not one issue. ,

23 That's my point.

24 MR. KENYON: Well --

25 CHAIRMAN JACKSON: And that's what I want --

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1 23

1 MR. F.ZNYON

Ramifications --

2 CHAIRMAN JACKSON: You to understand from at least 3 my point of view.

4 MR. KENYON: Yes.

4 5 CHAIRMAN JACKSON: It's not one issue. It is an 6 issue, and the question is to what extent does it have any j*

7 generic implications.

8 MR. KENYON: And if I conveyed anything other than i 9 that, I didn't mean to.

10 CHAIRMAN JACKSON: Okay. So why don't we move on.

11 MR. KENYON: Okay. To -- I guess finish my

12 comments on backlog with all acknowledgement of what you 13 just said, we do have a very broad definition of what 14 constitutes backlog. We do have a very low threshold for 15 identifying items. We have had a careful process to 16 evaluate things. We'll have to go back and check that. And

! 17 we think the magnitude that we have compares reasonably with 4

18 other plants providing they use a similar threshold and a 3 19 similar scope. We'll talk more about the backlog in greater 20 detail later in the presentation.

,' 21 Another challenge is to achieve station readiness 22 to support Unit 3 restart. And the remaining issue here is

-23 training, and we are going to get that resolved.

24 Now this next slide addresses important other 25 challenges in transitioning the Millstone organization from ANN RILEY & ASSOCIATES, LTD.

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24 1 a recovery organization into long-term operation. Chairman 2 Jackson, you correctly pointed out certain of these issues 3 and challenges in your recent site visit, and I also want to 4 say in addition to what Mike Morris said that your visit was 5 very much appreciated by -- and this is based on 6 considerable feedback by the community, it was appreciated 7 by the community, it was certainly appreciated by 8 management, and particularly by employees who valued and 9 appreciated the considerable time that you spent devoted to 10 talking with them. That communication was important.

11 Moving on to the challenges, there's a challenge 12 in t'he sense of needing to ensure sufficient separation of 13 Unit 3 operations from the continuing recovery efforts on 14 Unit 2 and the shutdown maintenance mode on Unit 1. This is 15 accomplished by having a management structure and dedicated 16 resources for Unit 3 startup and operations separate for 17 that --

separate for Unit 2 recovery, and thus this is our 18 means to ensure that there's a high degree of focus on unit 19 operations.

i 20 CHAIRhDdJ JACKSON: Where do you stand in 21 developing an integrated schedule?

• 22 MR. KENYON: We have an integrated schedule.

23 CHAIRMAN JACKSON: Has it been submitted?

24 MR, BOWLING: It will be on the docket this week.

25 MR. KENYON: We have shifted into-the normal i

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1 25 j

1 organization for startup and operations for Unit 3, and 2 that's headed by Mike Brothers.

3 Another challenge is the need to provide

! 4 additional monitoring and coaching as the plant resumes 5 operation. The unit has been out for a long period of time.

6 We have to be very careful, cautious and conservative as we 7 resume operation. An important action here will be to add

. 8 mentoring SRos in the control room from other units in order ,

i*

9 to watch and coach as necessary, and we're going to do l 10 something similar with plant equipment operators.

i 11 There's also the need to ensure that performance j 12 moni'toring and reporting and oversight shifts effectively 1 13 into an operating mode such that we're well positioned to 14 detect any potential backsliding performance. The programs

, 15- are in place. We have an acceptable but not generous number J

-16 of personnel in oversight with operating experience, so I 17 think we're prepared to do that.

18 We need'to establish a long-term improvement plan.

l 19 As I stated previously, achieving restart is just a 20 milestone on the road to excellence. The plan has been 21 drafted. A significant portion of that was included in the 22 briefing book and we will include the complete plan as part 23 of our next briefing.

24 Another important need is to do organizational and 25 succession planning. As we transition out of recovery mode,

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26 1 we're going to go to a simpler organization. The needs for 2 that need to be defined. An important characteristic will 3 be to maintain good checks and balances. We will do 4 succersion planning for obvious normal reasons, but also to 5 improve bench strength. We're not as deep as I would like, 6 and certainly we need to prepare for the eventual phase-out 7 of the recovery organizations. So even as we prepared for 8 restart, consideration is being given to these important a

9 other challenges.

10 Unless there are further questions for me, I would 11 like to call on Dave Amerine to brief on safety-conscious 12 work' environment.

13 CHAIRMAN JACKSON: Please.

14 COMMISSIONER McGAFFIGAN: I would like to ask one 15 question since it's not going to fit in anywhere easily in 16 the briefing about Unit 2. The staff is going to present 17 slides later that show their current schedule looking toward 18 completing staff actions around the loth of July. The last 19 time you were here, you were hoping to be one month behind.

20 Is that where you now are, three months behind in your own i

21 schedule?

• i 22 MR. KENYON: We've I think previously 1 23 characterized Unit 2 as being two to three months behind 24 Unit 3. The July time frame is obviously -- appears to 25 support the three-month interval. There has been some IdHI RILEY & ASSOCIATES, LTD.

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27 1 impact on Unit 2 because we have been devoting so much 2 attention and resources to Unit 3, so I think three months 3 and the July time frame is right for where we are now.

4 COMMISSIONER McGAFFIGAN: And then one other 5 questions. Parsons, in one of its backup slides, is --

6 preliminarily in their discrepancy report found five Level 7 l's and one Level 2 at Unit 2. You all will have a 8 conversation, but if-that holds, that will have implications 9 about your startup schedule as well.

10 MR. KENYON: We understand that.

11 Marty, how many have we responded to at this 12 poin't?

13 MR. BOWLING: We have responded to those Level l's 14 and provided additional technical information that should 15 justify a reclassification of those levels. That's 16 certainly up to Parsons to confirm.

17 COMMISSIONER McGAFFIGAN: So in your judgment, the 18 Level l's and Level 2's are 3's or 4's?

19 MR. BOWLING: That's correct, and some of those 20 have been responded to for over several months.

21 COMMISSIONER McGAFFIGAN: Several months, 22 MR. BOWLING: Yes.

23 COMMISSIONER McGAFFIGAN: Very well. I'm going to 24 ask questions later.

25 CHAIRMAN JACKSON: Okay, l ANN RILEY & ASSOCIATES, LTD.

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1 28 1 COMMISSIONER McGAFFIGAN: Thank you.

2 MR. KENYON: Dave?

3 MR. AMERINE: Good morning. My name is Dave 4 Amerine and I'm the Vice President of Human Services at 5 Millstone.

6 I have recently assumed the responsibilities for 7 the safety-conscious work environment there. In this 8 capacity, I report to Mike Brothers, who retains tne 9 responsibilities as executive sponsor for establishing and 10 maintaining the safety-conscious work environment, but I 11 will be going through that presentation.

12 May I have the first slide, please.

13 This slide gives our six high-level success 14 criteria which we will use to ensure that we have 15 successfully established and are in a position to maintain a 16 safety-conscious work environment at Millstone Station. I 17 will discuss the first four of these success criteria. The

. 18 last two, the employee concern oversight panel and Little 19 Harbor Consultant validation of our efforts, are independent 20 verifications of our evaluation.

1 21 At the December 12th NRC Commissioners' meeting, 22 we reported that we felt we were currently meeting our ,

23 acceptance criteria in the first two success criteria; that 24 is, employee willingness to raise concerns and line 25 management's ability to handle issues effectively. Today, I ANN RILEY & ASSOCIATES, LTD.

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29 1 am pleased to report that we continue to meet our success 2 requirements in the first two criteria, and we now feel that 3 we are meeting our success criteria in the third area, an 4 effective employee concerns program. l 5 Although in general, we feel we are tracking to 1 5 success in the fourth area, the ability to recognize and 7 address problem areas, as Bruce Kenyon mentioned, we have 8 had a potentially significant event which is under a .

9 investigation at this time. This is the recent situation j 10 which occurred relative to a brainstorming session in l 11 nuclear oversight during which inappropriate terminology was 12 used.

13 However, overall, we believe we have made progress 14 in all areas in establishing a safety-conscious work 15 environment and are on track to support the restart of 1

16 Millstone Unit 3 in this important area.

17 The first criterion I will discuss is the 18 willingness of employees to raise concerns. This criterion 19 is currently being met.

i 20 This graph shows our current leadership results to 21 support 'ccess criterion on employees' willingness to raise 22 concern-, As shown on the slide, our criterion is that 23 greater than 90 percent of the people are willing to raise 24 issues to their immediate supervisor. The current value is 25 approximately 97.5 percent, so this criterion is currently ANN RILEY & ASSOCIATES, LTD.

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30 1 being met.

2 This graph shows the culture survey results which 3 assess the percentage of respondents who agree that there is 4 a safety-conscious work environment in their work area.

5 Although this measurement is not yet at our long-range goal, 6 we believe the current results in the overall cultural 7 survey coupled with the percentage of people who are willing 8 to raise concerns to their supervisor meet our acceptance ,

9 criterion.

10 This next graph shows our confidentiality plus 11 anonymous trend. The top line is the total number of

.12 concerns received per month and the bottom line is the total 13 number of concerns which are requesting either 14 confidentiality or are received anonymously. Our criterion 15 is that no adverse trend exists in this area. As you can 16 see, in both December and to a lesser extent in January, we 17 had an increase in the total number of concerns and, 18 correspondingly, an increase in number of concerns which 19 requested confidentiality or were received anonymously.

20 Although the percentage of confidential or 21 anonymous concerns actually decreased, we will be watching 22 this indicator closely to ensure that an adverse trend is 23 not occurring.

24 By February 17th, four of the twelve concerns 25 received so'far this month requested either confidentiality ANN RILEY & ASSOCIATES, LTD.

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d

, 31 1 or were received anonymously. Now, if extrapolated 2 linearly, the total for February should be approximately 20 3 total concerns, which is less than both December and  !

4 January. There is no particular pattern in the increase of ,

5 concerns that has been detected, and in the same period, the 6 trend of allegations to the NRC has decreased.

I 7 I might add that I was responsible for instituting i 8 an employee concern program at-Davis Besse during their 9 restart, the recovery and restart of that unit, and also at 10 the defense waste processing facility of the Savannah River r 11 site. And when you go through that initial training and 12 advertising advertising to increase employee sensitivity and 13 awareness of an Employee Concern Program, in both those

14 cases, I experienced a similar kind of increased activity in 15 the beginning of the program, which eventually tapered off, 16 so this is not unexpected, in my opinion.

17 CHAIMOW JACKSON: You mentioned there that 18 although there is an adverse trend, that there are other 19 indicators substantiating that employees are willing to 20 raise concerns. Are those the other graphs that you are 21 going to be talking about?

22 MR. AMERINE- Yes, ma'am. Yes, ma'am.

, 23 CHAIRMAN JACKSON: Okay.

24 MR. AMERINE: Okay. The recond criterion that I 25 will discuss is the effectiveness of line management in ANN RILEY & ASSOCIATES, LTD.

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32 1

handling issues, like the first, we are currently meeting 2 this success criteria.

3 This next graph shows the average age of our 4 Condition Report Evaluations. Our goal is not to have an 5 adverse trend in this indicator. The average time of 6 Condition Report --

from a Condition Report initiation to 7 evaluation was approximately 23 days during the month of '

8 January, e

9 The last three weeks the average age of the 10 Condition Report Evaluations has increased from 26 to 34 11 days. Most of those not achieving the goal are exceeding 12 the130 day target by only a few days. This is due to the 13 priorities, sur engineering work force being directed to 14 respond to the Independent Corrective Action Verification 15 Program, support the transition to Mode 4 and respond to the 16 NRC inspection activities.

17 However, for the week of February lith, of average 18 age of completed Condition Report Evaluations dropped once 19 again to 30 days. We believe we are effectively managing 20 this metric and performance in this alea is currently

~

21 satisfactory.

22 CHAIRMAN JACKSON: Okay. So let me make sure I ,

23 understand. What you are saying is that even though this 24 average length of time has gone up, you are saying that you 25 understand it because the work force that would be ANN RILEY & ASSOCIATES, LTD.

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33 1- addressing these have been diverted to other things?

2 MR. AMERINE: That is correct.

3 CHAIRMAN JACKSON: And that even with that, you 4 have dropped from the 34 days to the 30 days?

5 MR. AMERINE: In this past week, that is correct.

6 CHAIRMAN JACKSON: In the past week.

7 MR. AMERINE: Now, that took increased management.

8 CHAIRMAN JACKSON: And that's what you mean when 9 you say tracking the status?

10 MR. AMERINE: Yes, ma'am. And we were responding 11 to our trend in this case, in this performance indicator.

12 So We have brought it back down to the 30 days.

13 The next graph -- the next graph shows our current 14 Condition Report Evaluation score. This score is developed 15 by averaging all the Condition Report Evaluations which are 16 reviewed by the-Site _ Management Review Team during each 17 month. The Condition Review -- the Condition Report 18 receives a 4 if the Evaluation is accepted without comment, 19 2 if it is accepted with comment, and 0 if it is rejected by 20 the Management Review Team. This criterion is currently

-21 being met.

22 CRAIRMAN JACKSON: Now, is there a sampling of 23 these quality ratings by Little Harbor or NRC?

24 MR. AMERINE: I am not aware of that.

25 CRAIRMAN JACKSON: Okay.

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34 1 MR. AMERINE: Okay. The next graph, this shows 2 the percentage of all Action Requests as a result of l

3 Condition Reports which are overdue. The goal is less than i

4 3 percent. Significant attention has been focused on 5 completing those actions necessary to Mode 4, as we just 6 discussed. As a result, the lower priority Corrective Actions became overdue.

7 8 how, once again, due to increase management ,

9 attention in response to this EPI, for the week of February 10 lith, we once again were at the goal of 3 percent, so this 11 criterion is currently being met as well.

12 CHAIRMAN JACKSON: How quickly must they be 13 assigned? You say, you talk about the number of overdue 14 assignments. When do they become overdue? I mean how 15 quickly must they be assigned in order not to be overdue?

16 MR. AMERINE: Well, we are trying to get them 17 assigned as soon as they come in the door, and then get the 18 Evaluation done within those 30 days.

19 MR. BROTHERS: There's an Evaluation, the 20 timeliness of the Evaluation is 30 days, and then the 21 overdue is based upon the approved due date once that

• 21 Evaluation comes out. So the overdues are looking at 23 something that has gone past the due date that was approved 24 by the Management Review Team.

25 CHAIRMAN JACKSON: Okay.

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35 1 MR. AMERINE: Thank you. The third criterion I 2 will discuss is the effectiveness of the Employee Concerns 3 Program. We now evaluate our performance in this area 4 satisfactory.

5 The next slide shows the average age of unresolved 6 concerns. In the December 12th presentation, the success

[ 7 criterion was that 90 percent of all investigations are 8 completed within (a days. It was also indicated at that 9 time we were assessing the validity of this indicator, of 10 the effectiveness of our Employee Concerns Program. This is 11 because an undue focus on timeliness can result in 12 degradation of other areas of the Employee Concerns Program, 13 We have altered our criterion to look at the 14 average age of unresolved concerns to more effectively 15 assess the ability of-the organization to keep up with its 16 receipt rate, without sacrificing any of the other aspects 17 of the concern processing. No adverse trend with regard to 18- this average age of unresolved concerns exists at this time, 19 so_this_ criterion is cur.rently being met.

20 The next slide shows the percentage of employees 21- who have used the Employee Concerns Program, that would use 22 it again if they had the need.

9 The first three data points 23 are really Little Harbor consultant numbers since we were 24- not_ tracking this parameter during the early part of 1997 25 In December of 1997, we commissioned the Employee Concerns ANN RILEY & ASSOCIATES, LTD.

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36 1 Oversight Panel to ascertain a certain value for this 2 metric. This was determined to be 75 percent, which is the 3 lighter shade bar. At the same t.ime, Little Harbor, their 4 estimate was 83 percent.

5 CHAIRMAN JACKSON: When do you plant to do your 6 next survey?

7 MR. AMERINE: We are going to have them 8 commissioned to do that from now on. In fact, I talk about 9 that at this moment.

10 CHAIRMAN JACKSON: On what frequency, I mean?

11 MR. AMERINE: I am not sure of the frequency, but 12 it is going to be -- they are just getting into this metric 13 now.

14 CHAIRMAN JACKSON: You haven't decided what the 15 frequency will be?

16 MR. AMERINE: Yes, ma'am.

17 CHAIR!RN JACKSON: Okay.

18 MR. AMERINE: We are continuing to refine this 19 metric to determine additional factors such as the areas 20 that we would be looking, reasons for dissatisfaction and so 21 forth, and we are going to fold that into determining, you

• 22 know, what the answer to your question would be.

23 At this moment, though, based on both Little 24 Harbor and our initial one, we assess this metric as meeting 25 expectations and expect to gain further useful information MRT RILEY & ASSOCIATES, LTD.

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37 1

for it to become a more effective measurement as we use the 2 Employee Concerns Oversight Panel data. So, therefore, 3 right now, we believe this criterion is being met.

4 The fourth criteria is our effectiveness if 5 recogniting and remediating problem areas within the 6 Millstone organization. Although the performance in this 7 area has improved, we are not currently meeting our 0 9tandards, t

9 The first slide here is simply a compilation of 10 our current status of training to our supervisors and above 11 at Millstone Station. We are committed to get above 95 12 percent on the first three training categories, and we 13 believe that we will have all three of those above 95 14 percent by mid-March. The other one that is shown on there 15 is our Forum for Leadership Excellence, and we will have the 16 work force above 95 percent by mid-1998.-

17 CHAIMCW JACKSON: Is this in-house training that 18 you do, or you bring in outside?

19 MR. AMERINE: It is a combination.

20 CRAIRMAN JACKSON: Combination. And tell me about 21 the Forum for Leadership Excellence.

22 MR AMERINE: That is a program that, in fact, my 23 first two days at Millstone were spent in that Forum for 24 Leadership Excellence. And we get, at various levels, we 25 have brought together the managers and supervisors and we ANN RILEY & ASSOCIATES, LTD.

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38 1 are working our way on down through the organization, and it 2 ic facilitated by an outside contractor who has done this at 3 other utilities, to basically develop communication skills 4 and techniques and team work approaches and so forth, and we 5 have found it to be very useful.

6 One of the things that I have seen that it does is 7 it starts to develop a common language across the site.

• 8 Okay. Next slide. This slide shows our current ,

9 trend of Employee Concerns alleging instances of harassment, 10 intimidation, retaliation and discrimination with 50.7 11 implications. We use a conservative classification of HIRD, 12 including not only explicitly stated alleged activities, but 13 also any inferred from the Concern Statement, including fear 14 of possible future retaliation.

15 The HIRD classification includes matters such as 16 race discrimir tion and sexual harassment, as well as the 17 chilli.g effect and adverse actions related to protected 18 activities. So we are using a conservative definition in 19 looking at this.

20 But, regardless, we have zero tolerance for all 21 HIRD instances, especially those leading to potential ~

22 violations of 50.7.

23 We have completed a review of 218 concerns between 24 December 1st, 1996 and January 31st, 1998, which reveal that 25 approximately 50 percent of the concerns had one or more ANN RILEY & ASSOCIATES, LTD.

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39 1 HIRD elements, and approximately 25 percent had 10 CFR 50.7 2 potential implications. These proportions are consistent 3 with previous classifications, but we are working hard to 4 br 4 ~ ' those down. =

5 Our criterion is that substantiated instances of 6 potential 10 CFR 50.7 violations are rare and are handled 7 responsibly. The top line shows the total numbers of 8

concerns receiveu and the bottom line on the chart shows

{

9 those concerns with potentia] 50.7 implications.

10 The bar, in August 1997, represents three 11 instances of substantiated potential 50.7 violations. These 12 thrse were all as a result of the MOV event which occurred 13 in July-August time frame. Now, as of February 17th, these 1

l 14 are the only substantiated cases of potential 50.7 15 violations which we have had during the period of 16 May-December 1997, 17 There are additional cases that are still under 18 discussion with a third party which have the possibility to 19 be substantiated as potential 50.7 violations.

20 This criterion, we feel at this time is being met.

21 However, extensive executive invalvement in any confirmed 22 case of HIRD, regardless of whether or not there are 50.7 23 implications, will ensure that Corrective Actions, up to and 24 including reassignment and removal, are effective at 25 eliminating HIRD at Millstone.

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40 1 CHAIRMAN JACKSON: If you have zero tolerance, 2 what is your satis $ctory performance criteria?

3 MR. AMERINE: Well, in the discussion that Bruce 4 Kenyon had about that before, where we are headed is to get 5 the instances of this to be very rare and the total impact 6 to be as low as possible.

7 CHAIRFDJJ JACKSON: I guess I'm really trying to 8 probe the thinking, I mean you have this lump-up here in the ,

9 November-to-January time frame, but you f eel that your 10 performance is satisfactory, and is that because at this 11 stage of the game, even though you have the potential 12 concerns, they haven't been substantiated? ~I guess I'm 13 trying to understand these relative to the trend on the 14 graph what the definition of satisfactory is.

15 MR. AMERINE: Right. As I was saying before, this 16 looks similar and it is very similar to the previous graph I 17 had on this, and these are alleged concerns that have come la in, and again I believe that we're seeing this spike up, 19 which is now coming down, and if we make a linear 20 projection, February will be a 20, whereas January is 27.

21 CHAIRMAN JACKSON: Ah, you can't make a linear 22 projection.

23 MR. AMERINE: Oh, I'm not saying --

24 CHAIRMAN JACKSON: Can't do that.

25 MR. AMERINE: You're absolutely right. But if we 1031 RILEY & ASSOCIATES, LTD.

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41 1 were, the number would have come down --

2 (Laughter.)

3 MR. AMERI!1E : But again, as I said, my experienc-4 at both Davis-Besse and the Defense Waste Processing 5 Facility was that they went up and started to come back 6 down.

7 CRAIRMAN JACKSON: I understand all that. But 8 what I would suggest that you -- I think it's -- you don't 9 make linear extrapolations with something like this.

10 MR. AMERINE: No.

11 CHAIRMAN JACKSON: That's No. 1. No. 2, it is 12 bett'er to keep the emphasis on what's substantiated and 13 what's not.

14 MR. AMERINE: Right.

15 CHAIRMAN JACKSON: And 3, if you think that there 16 are explanatory statements you can make, which is probably 17 buried in here, you know, just list them in the margin, 18 because I think that you don't want to affect your 19 credibility about statistics and talk about extrapolation 20 here.

21 MR. AMERINE: I understand.

22 MR. KENYON: Could I just -- I agree with what you 23 said, Chairman Jackson. These HIRD items, just to 24 emphasite, these are either alleged --

25 CHAIRMAN JACKSON: I know.

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42 1 MR. KENYON: By the concerned or inferred --

2 CHAIRMAN JACKSON: Right.

3 MR. KENYON: Or just a chilling effect. I mean, 4 it is a pretty Droad definition.

5 CHAIRMAN JACKSON: Right. And all I'm trying to 6 say is that it is better to talk about it that way, in that 7 way, then to talk about linear extrapolation.

8 MR. KENYON: We understand.

9 CHAIRMAN JACKSON: Right. Please.

10 COMMISSIONER DIAZ: Also, when you look at all of 11 this graph, it might be appropriate to, you Know, look at 12 any one of them and say, you know, right now is not 13 satisfactory, but the trend is not declining, but some of 14 them you put a criteria and then you said well, you know, I 15 look at any one of them, you know, criteria is less than 3 16 percent, and obviously the last four months is over 3 17 percent. Without extrapolation, using some averaging, 18 you'll still be above three.

19 So you have not met the criteria, but you can make 20 an explanation if that is not significantly above the 21 criteria, and that is not trending adversely. But, you 22 know, I think making a statement that, you know, it's ,

23 satisfactory or we met the criteria, it doesn't track with 24 your graph. It's better to say it doesn't meet the 25 criteria, but it doesn't meet it by a little bit, and is ANN RILEY & ASSOC 1ATES, LTD.

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43 1 not, you know, tracking adversely. And I think that would 2 be a little better from my viewpoint.

3 CHAIRMAN JACKSON: Right. And I mean I think that 4 all of these things are consistent. But, you know, and I 5 realize you've had quite a bit of prior experience, but 6 each, you know, entity and each organization is different, 7

and therafore linear extrapolation's a very dangerous thing.

B MR. AMERINE: Okay. If I could have the next i.

9 slide, please.

! 10 This slide shows our total number of problem areas 11 at Millstone Station. In fact, successful action plans have 12 broOght the number of problem areas down from 33 to 11.

13 Four of the problem areas' action plans are nearing 14 completion, four of the 11 that are left at this time, and 15 are expected to be effective in mid-March.

16 Now a problem area is any area in which a 17 uafety-conscious work environment may not exist. Problem 18 areas are identified by inputs from the employee concern 19 program, from the employee concern oversight panel, from 20 Little Harbor Consultants, or from the culture or leadership 21 surveys, or a combination thereof.

22 Our criterion is that the total number of problem 23 areas not indicate an adverse trend. While we meet that 24 criterion, we have not yet demonstrated the ability to 25 proactively identify and remediate problema- prior to them s

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44 1 becoming obvious problems.

2 i

The nuclear oversight problem discussed by Bruce 3 Y.enyon notwithstanding, ve have several examples of 4 pror.ctive responses to potential prcblem areas in the recent 5 past. In other words, we have successfully prevented some 6 potantial areas from becoming problem areas by effective 7 intervention. We expect this performance level to continue 8

to improve and the orgenization's ability to identify and .

9 prevent problem areas to take precedence over our ability to 10 remediate problem areas which have been allowed to occur.

11 Increased senior human resource management and legal i

12 presence on site is helping in our responsiveness.

13 Returning to our six succese criteria as we 14 reported during the December 12 NRC Commissioners meeting, 15 we are meeting our criteria for employees' willingness to 16 raise concerns and line management's effectiveness in 17 dealing with issues raised by employees. We have made 18 significant and meaningful progress towards establishing an 19 effective employee concerns program. Today we feel we're 20 meeting the success criteria in that area.

21 The fourth success criteria, our ability to 22 recognize and address problem areas, is where we still need 23 to improve to meet our success criteria. Significant 24 progress has been made over the last few months. This area 25 will continue to be our focus going forward.

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The remaining two success criteria, employee 2 concerns oversight panel and Li .tle ';crbor Consultant 3 concurrence, are under way and expected to support the Unit 4 3 restart schedule, 5 Now speaking of going forward, our next focus in 6 the area of safety-conscious work environment is the 7 development of the plan that Mr. Kenyon mentioned. As we 8

have consistently stated, our overall recovery strategy is 9

the startup and then power ascension, and then the long-term

-10 performance improvement plan. Mike Brothers is also the 11 executive sponsor for the long-term performance improvement 12 for' Millstone station, as well as the safety-conscious work 13 environment, which is a subset of that.

14 Included in this plan are some plan enhancements 15 to our processes which will support the safety-conscious 16 work environment. Thesa include but are not limited to 17 clarification of employee concern program responsibilities, 18 long-term organizational alignment within the areas that I'm 19 responsible for, first-line supervisors' handbook, and a 20 safety-conscious work environment manual. This plan should 21 be finalized in late February or early March.

22 CHAIRMAN JACKSON: Thank you.

23 MR. AMERINE: If there are any other questions, 24 I'll pass the baton to Marty Bowling.

25 Thank you.

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46 1 MR. BOWLING: Good morning.

2 Before I begin, let me clarify my response to your 3 question, Commissioner. In terms of the five Level is and 4 the one Level 1 -- Level 2 on Unit 2, we have responded to 5 three of the Level is and the one Level 2, and that was done 6 in '97. The responses for the remaining two Level is are in 7 final preparation and will be provided shortly to Parsons. "

8 In my August and December briefings to you I ,

9 discussed the status of corrective actions at Millstone, 10 Today I want to update you on our progress.

11 In general terms it's my view that the corrective 12 asclons continue to be on track to fully support both Unit 3 13 restart and the continuing recovery of Unit 2. We have a 14 program that is designed to industry standards. This 15 program has been implemented, personnel trained, and 16 self-assessments of both the process and the quality of 17 results are being performed. I think this is the key 18 attribute, in that it's not a perfect program, but when we 19 find we've made a mistake, we're looking at it in its 20 broadest extent to understand the extent of the problem and 21 making sure that we get that fixed. And this issue that 22 you've brought up will go right into that process.

23 Also, nuclear oversight is providing weekly 24 independent surveillance of the program.

25 This slide shows the four major programmatic ANN RILEY & ASSOCIATES, LTD.

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47 1 elements and the supporting attributes of corrective action 2 in the broadest sense. This slide, which focuses on Unit 3, 3 is color-coded to represent the current status toward 4 restart readiness for Unit 3.

5 My purpose is to give you a balanced sense of the 6 robustness of our corrective actions at this stage of the 7 recovery. The first two elements, problem identification 8 and problem evaluation, were discussed last December and 9 continue to be satisfactory. As you will note, the two 10 elements of problem resolution and corrective action 11 effectiveness are not yet satisfactory, but are on track.

12 Indicators are provided in the issue book for most of these 13 areas, and include both restart and postrestart items.

14 With respect to problem resolution and corrective 15 action effectiveness, the principle issues that I will focus 16 on are the restart backlogs and configuration management 17 effectiveness. Both Mike Brothers and I will also discuss 18 postrestart backlogs. Mike will also discuss repetitive 19 issues and Unit 3 organizational readiness.

20 The restart backlog or remaining tasks required 21 for restart of Unit 3 are shown in this slide. These 22 remaining tasks include all of the items required to restore 23 compliance with the design and licensing basis for safety 24 and risk-significant systems as well as NRC regulations. As 25 you can see, this indicator is showing steady progress and ANN RILEY & ASSOCIATES, LTD.

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48 1 it's tracking to satisfactory. As of February 17, 684 2 restart tasks remain.

3 CHAIRMAN JACKSON: How many, 683?

4 MR. BOWLING: 684.

5 CHAIRMAN JACKSON: 684. And that's as of the 6 7th -- 17th.

7 MR. BOWLING: Yes, 8 This slide and the next give a better perspective ,

9 of the remaining tasks required to restore compliance. As 10 Bruce indicated in his remarks, progress continues on the 11 key organizational and progr . .nmatic issues. This slide 12 shoss that most of the significant items, that is, those 13 issues that could affect the operability and functionality 14 of safety and risk-significant maintenance rule equipment, 15 have been addressed.

16 In addition, substantial progress has been made in 17 responding to the NRC's significant-item list relating to 18 manual chapter 0350 process.

19 Finally, we are meeting our commitments to the 20 NRC. Just to update you where we are as of yesterday on the significant items with 50.54 (f) it's 252 items remaining for 21 22 the MC0350 significant items list there are six.

23 CHAIRMAN JACKSON: You had indicated in your 24 executive summary that you would expect that all the 25 significant items list packages to be submitted to the NRC ANN RILEY & ASSOCIATES, LTD.

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49 1 by mid-February. Did you -- were you able to meet that?

l 2 MR. BOWLING: There are still six, i

3 CRAIRFDM JACKSON: Oh, that's what you mean when 4 you say there's six.

5 MR. BOWLING: Yes. Yes.

t 6 CHAIRMAN JACKSON: Okay. I understand.

7 MR. BOWLING: I will discuss our responses in more 8 detail. That number's substantially less And for open NRC 9 res*' art commitments, it's at 77.

10 The next slide.

11 This slide shows the corrective action resulting 12 from the NU-performed reviews to restore compliance to 13 design and licensing basis. As you can tell, a substantial 14 number of the corrective actions have been completed.

15 The next slide, please.

16 Now moving to the second element, corrective 17 action effectiveness, I want to concentrate on configuration 18 management program effectiveness.

19 The program for reviewing the Millstone Unit 3 20 design and licensing basis was developed in the spring of 21 1996. The methodology used was to perform a diagnostic 22 review of key design and licensing basis documents. Based 23 on the diagnostic results which were provided to the NRC in 24 July of '96, the scope of the configuration management 25 project was determined. In summary, this was a graded ANN RILEY & ASSOCIATES, LTD.

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_]

50 1 review based on risk and safety significance. Still, it was 2 comprehensive in scope with 88 maintenance rule covered 3 systems, 19 topical areas, environmental qualifications, 4 energy, line break, fire protection, and portions of 5 approximately 60 other technical programs. Also, the FSAR 6 and technical specifications were reviewed to determine if

~

7 they were being complied with.

8 CHAIRMAN JACKSON: Let me ask you, you have a 9 meeting this afternoon --

10 MR. BOWLING: Yes.

11 CHAIRMAN JACKSON: -- with the NRC staff on the 12 recirculation spray system, and it's a system, you know, 13 that I happened to look at when I was there, and to a large 14 extent, you've reconfigured that system during your 15 shutdown. Can you describe the problems you've had and how 16 you assure yourselves that the system now is operable' 17 Would you just kind of walk through that in a succinct 18 fashion?

19 MR. BOWLING: Okay. And I may ask Mike Brothers 20 for some help here as well.

21 CHAIRMAN JACKSON: Sure. Okay.

22 MR. BOWLING: In initial startup, there were flow 23 stability problems through the heat exchangers of that 24 system which required restrictions on flow, and the various 25 analysis has been to assure that the flow stability is ANN RILEY & ASSOCIATES, LTD.

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51 1 .cceptable, and that has required both reconfiguration of 2 the lineups in terms of injecting into the reactor coolant 3

system directly as well as supporting other ECCS pumps, and 4

it has also required physical modification such as orificing 5 in order to get the flows right.

6 Also there was a timing issue in terms of 7

operators being able to do lineups in the required amount of 8

time, and that time was extended to give them the adequate 9 time to perform these evolutions.

10 Mike?

11 MR. BROTHERS: Yes, I would break the problems 12 with the recirculation spray system up into, as you 13 described, the original problem, too much flow through the 14 heat exchangers when we went into the injection mode, which 15 was changed in 1985 and called into question in our process.

16 When we shut down, we identified fluid temperature 17 problems with a failure of service water which resulted in a 18 fluid system excedent, ambient temperature problems, and the 19 fact that we treated the containment temperature profile 20 . during a large break LOCA as a transient event, that was 21 called into question.

22

. We had water hammer events that came from the 23 generic letter as a result of the Haddam Neck problem that 24 they had had on their containment air recirculation fans.

25 It wasn't in the same system, but it was a water hammer ANN RILEY & ASSOCIATES, LTD.

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52 1 event.

l 2 We had the ECS valve erosion event, the single l

3 most significant event we had, an industry event, which says 4 that the valves were throttled down ao far that if you can 5 imagine a line going to the break, the loop that the break 6 is in, that the position of that valve being throttled is 7 supposed to eliminate or reduce the amount of flow that's 8 being robbed and going to the break, but the valves were 9 found by EPRI to be in the cavitating range and they fail 10 quickly. Orifices were installed for that as well as the 11 air entrainment issue that was identified in the tier 1 12 inspection.

13 So all those in addition to the original design 14 problem of too much flow were in the recirculation spray 15 system.

16 CHAIRMAN JACKSON: Okay.

17 MR. BOWLING: We have put on the docket a fairly 18 comprehensive discussion of how the system is performing 19 today versus its original licensing basis and all the --

20 explaining all the changes.

21 CHAIRMAN JACKSON: Thank you.

22 MR. BOWLING: As I stated, the configuration 23 management effort was graded based on risk and safety 24 significance. Initially, the scope was focused on the areas 25 of weakness identified in a diagnostic review; however, we ANN RILEY & ASSOCIATES, LTD.

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53 1 recognized that self-assessment would be critical. Simply 2 stated, we know that we must be able to find our own 3

problems and fix them before they become more significant, 4 In addition, the ICAVP review process has resulted 5 in findings that have also required us to determine the need 6 for additional reviews. In a number of cases, we have 7

performed the necessary additional work to provide added 8

assurance that we have identified all of the important 9 issues.

10 This slide shows the additional areas that have or 11 are currently being addressed. A number of issues have been 12 idedtified by these reviews, but none individually have had l

l 13 high safety significance or have resulted in a reportable 14 event under 10 CFR 50.73.

15 Two of these reviews cover areas recently 16 addressed in a pre-decisional enforcement conference. The 17 principal concern was for the potential for air binding of 18 safety required pumps which was identified by the NRC in 19 their Tier 1 out-of-scope SFFI and was mentioned _by the NRC 20 in the December Commission meeting with you as a potential-21 high safety significant issue.

22 At the January 13th pre-decisional conference 23 which was open to the public, we provided the NRC staff with 24 information demonstrating that this issue posed no safety 25 impact and that the Millstone ECCS systems were operable and ANN RILEY & ASSOCIATES, LTD.

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54

1. functional. We are also providing the NRC staff the 2 technical information we_ relied upon so they can 3 independently review our conclusions.

4 The other issue concerns the use of operating 5 experience, especially NRC information notices. The Unit 3 6 configuration management effort did utilize a significant 7 amount of operating experience, but the scope did not

• 8 explicitly require a review of NRC information notices. As 9 a result, despite several opportunities, we missed the RSS 10 air-binding issue.

11 To address the extent of the potential for air 12 binding as well as any other operating experience issues 13 that relate to system-to-system interactions, we expanded 14 our reviews to an integrated system functional review. This 15 review, which drew heavily upon operating experience, looks 16 specifically at system interfaces and system-to-system 17 interactions.

18 The team consisted of a multi-discipline group of 19 engineering, operating and operating experienced personnel 20 and has been in place since late October of last year. The 21 team is also performing reviews of the FSAR with a 22 particular focus on the interface between the AE and the 23 NSSS design safety system functions.

24 Additional reviews of NRC information notices is 25 - also currently taking place to ensure that our scope has ANN RILEY & ASSOCIATES, LTD.

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l l

55 1 been adequate. With respect to the other items on this 2

slide, reviews and any needed corrective actions are being 3 pursued.

You will note that several of these items are 4 consistent with the preliminary ICAVP contractor DR trend 5

results to be presented later by Sargent & Lundy.

6 CHAIRMAN JACKSON: Has your management team in any 7

way been surprised at the amount of work necessary for you 8

to regain your assurance of conformance with the design and 9 license basis?

10 MR. BOWLING: I don't know if surprise is the 11 right word. Clearly, we have learned a lot as we have gone 12 thr6 ugh this process, and I have to say that it started --

13 the process started with an organization that was not at the 14 level of performance that we have today or that met a 15 standard, so it's a process of increasing standards.

16 The other aspect of this which I think is 17 important is that I mentioned several times that we did a 18 graded safety review. In other words, this review stopped 19 when conformance to design and licensing basis was

2. 0 confirmed. The ICAVP review goes deeper in the sense that 21 it's looking at essentially all calculations and drawings 22 that relate to the systems that are in scope. I think this 23 is the explanation tor a lot of the Level 4's.

24 CHAIRMAN JACKSON: Let me ask you one last 25 question given what you just said. You know, when I was on ANN RILEY & ASSOCIATES, LTD.

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-. - - - - . . - .~ . . . . - - - . . . ~ . - . - . . . - . - . . - _ .

56 1 site, I met a number of contractors.

2 MR. BOWLING: Yes.

3 CHAIRMAN JACKSON: You know, I was walking around 4 to meet employees, and I did that, I met a number, but I 5 also met a lot of contractors, and I guess -- what is your 6 assessment today? One has to do with standards, but the 7 other actually has to do with actual capabilities, of the 8 strength that the organization has in engineering, you know, ,

9 given that a lot of these kinds of issues, at least, that we 10 are discussing at the moment, depend on that area, and one 11 of these days, the contractors are going to be gone.

12 MR. BOWLING: Right. Certainly, the knowledge 13 transfer is a critical issue for us. I would say that in 14 our system engineering area that we are less reliant on 15 contractors, and they have been involved heavily in the 16 -process. In addition, we have done a lot to document with 17 design basis summaries of the key safety-related functions 18 and systems so that we have that record.

19 CHAIRMAN JACKSON: Okay.

20 MR. BOWLINGi We are also looking at the ICAVP 21 Discrepancy Reports, DRs, and although, individually, most 22 are not safety significant, in aggregate, they may indicate 23 an area requiring program enhancement. We will make tnese 24 enhancements upon confirming that the DRs and the trends are 25 valid.

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57 1 The trends that we are currently evaluating do not 2 indicate any programmatic weakness or breakdowns, but will 3 likely afford an opportunity to improve.

4 With respect to the DRs, we are on track to 5 respond to all that have currently been received from the 6 ICAVP contractor by the end of February. We currently have 7 212 remaining to respond to.

8 As of February lith, we have responded to 634, 9 subsequently we have responded to more, as I indicated.

10 The single level 2 DR for Unit 3 relates to a 11 number transposition error and a degraded voltage 12 calculation. This error was in a non-conservative 13 direction, but sufficient voltage is available for the 14 effected safety-related equipment to perform its safety 15 function and the design basis was met. We have responded 16 with the technical information to support a level 4 17 reclassification of this issue, which we believe the ICAVP 18 contractor will confirm.

19 Again, the remaining DRs are scheduled to be 20 responded to by the end of February.

21 CHAIRMAN JACKSON: Let me ask you, you know, and-I 22 know the focus has been on Unit 3, but from where you sit, 23 is there a difference, or a detectable difference in the 24 threshold for calculating level of significance between 25 Sargent & Lundy and Parsons?

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1 1

58 1 MR. BOWLING: Yes.

2 CRAIRMAN JACKSON: Would you speak to that for a 3 second?

4 MR. BOWLING: I am not sure I can give you the 5 answer that you are looking for. I do see a difference in 6 the determinations of significant levels, but I think maybe 7

the NRC staff would be better able to answer that.

e 8 CHAIRMAN JACKSON: Okay.

9 MR. BOWLING: If I could have the next slide.

10 Based on the 634 responses that we have made through 11 February lith, and recognizing that only about 30 percent 12 hav6 been closed by the ICAVP contractor, we can generally 13 conclude that the Unit 3 reviews have identified most of the 14 design and licensing basis issues. To date, NU has 15 confirmed that only seven of 634 DRs are of level 3 16 significance, which is a design and/or licensing basis 17 issue, Dut does not affect or operability or functionality, 18 and which has been characterized to be of low safety 19 significance.

20 This slide shows the safety significance of what 21 has been identified during the Millstone Unit 3 reviews and '

22 the ICAVP inspections. It is important to note that no LERS 23 have resulted to date from any of the over 600 ICAVP DRs 24 that we have reviewed to date. This provides a strong 25 indicator that the Unit 3 reviews to restore conformance to ANN RILEY & ASSOCIATES, LTD.

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59 1

the design and licensing basis were effective in identifying 2 significant safety issues.

3 With respect --

4 CFA.IRMAN JACKSON: What percentage did you tell me 5 were closedi 6 MR. BOWLING: Thirty.

7 CRAIRMAN JACKSON: Thirty percent.

8 MR. BOWLING: Approximately.

With respect to the 9 NRC inspections, a number of potential violations have been 10 identified, as well as several issues that have been 11 determined by us to be reportable, and from yesterday, that l 12 has'gone up to four items.

13 These issues and potential violations also have 14 not been of high safety significance, at least the three 15 that I have on my slide. Nonetheless, as previously 16 discussed, we have already taken both the NRC preliminary 17 findings and the ICAVP contractor DRs into account in our 18 self-assessments to determine the need for additional 19 reviews, 20 As you know, we have informed the NRC staff, in 21 response to Question 2 of 10 CFR 50.54(f), that over 4,000 22 items may be deferred to after restart of Unit 3.

Question 23 2 cast a wide net by essentially asking for all items that 24 will not be completed prior to restart, irrespective of 25 either safety or business significance. Both Mike Brothers ANN RILEY & ASSOCIATES, LTD.

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60 1 and I will discuss these deferrals in our presentations, but 2 I wanted to make clear that the items required to restore 3 compliance with the design and licensing basis, as well as a

4 NRC regulations, will be completed prior to restart in key 5- areas such as RSF prior to Mode 4 entry.

6 For the deferred items under Question 2, we will

. 7 docket our approach for managing and monitoring the '

8 post-restart backlog. In our February 9th, '98 letter to 9 the NRC, we committed to the Corrective Actions for any 4 10 deferred level 4 DRs by the end of the next refueling l 11 outage, as well as providing periodic status on the level 4 12 Corrective Actions.

, 13 This slide shows the number of our deferred tasks 14 resulting from both the Configuration Management Review and 15 the ICAVP Reviews. The 705 configuration' management tasks 16 will be addressed and either completed, scheduled or I 17 cancelled based on the value added that can be provided.

18 Enomples of what is included in the deferred 19 backlog are listed. About 30 percent of the 705 relate to 20 minor drawing enhancements for labeling, pointers and 21 designators which are not relied upon by the operator or the '

4 22 design engineer when using the drawing. Only a few, 23 approximately 12 items, are related to the FSAR and reflect 24 grammatical or editorial preference or applied to a 25 non-safety system.

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61 1 Procedures constitute about 30 percent and include 2

enhancements which do not affect functionality. However, a 3 significant number of the procedure deferrals are 4 significant, but consist of procedures, primarily, 5 in-service inspection, in-service testing, that will not be 6 required until the next refueling outage. These will be 7

completed prior to the next refueling outage.

8 It is also worth noting that the size of the

9 backlog was originally 948 and is currently 697 Our intent 10 is to work this off as quickly as possible.

11 CHAIRMAN JACKSON: Now, the numbers you are 12 shoking here, subsets of the, quote-unquote, "5,000 open 13 items," --

14 MR. BOWLING: Four thousand, yes.

15 CHAIRMAN JACKSON: Four thousand.

16 MR, BOWLING: Forty-two.

17 CHAIRMAN JACKSON: Forty-two-hundred.

18 MR. BOWLING: And Mike Brothers will discuss the 19 remainder of that.

20 CHAIRMAN JACKSON: Okay. All right. And so there 21 are other catego?.ies?

22 MR. BOWLING: Yes.

23 CHAIRMAN JACKSON: Okay-24 MR. BOWLING: Which Mike will discuss. But I 25 wanted to discuss those that may bear to one degree or ANN RILEY & ASSOCIATES, LTD.

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62 1 another on the design and licensing basis.

2 Now, with respect to the ICAVP DRs, please not 3 that these deferrable tasks of 215 represent the DR 4 Corrective Action assignments, not the number of DRs being 5 deferred.

6 Now, I mentioned that we would docket our approach 7 to this backlog. I have several back-up slides that discuss 8 that approach and our planned commitments to the backlog, if ,

9 you would like to see those.

10 CHAIRMAN JACKSON: We'll go on. But let me --

11 MR. BOWLING: We are working with the staff on 12 that.

13 CHAIRMAN JACKSON: Let me ask you a question here.

14 You have a slide 62 that is further on, that says, 15 " Discipline work prioritization process applied to identify 16 items deferrable until after restart." I see the 705 on 17 that.

18 MR. BOWLING: Right.

19 CHAIRMAN JACKSON: But I don't see the 215.

20 MR. BOWLING: The 215, once they get their 21 assignments, are collectively included in the first number '

22 there, the assignments. They are not further bend at this

23. point.

24 CHAIRMAN JACKSON: So they will be additive to 25 this list?

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63 1 MR. BOWLING: No , they are inclusive.

2 CHAlE Jdi JACKSON: Okay. 3 see. All right.

3 okay.

4 MR. BOWLING: Again, nona of these deferrals will

5. affect conformance to design and licensing basis.

6 In addition to restoring conforming to design and 7

licensing basis, we have also strengthened the programs 8

necessary to maintain the design and licensing basis going 9 forward. This required correcting longstanding issues with 10 the Design Control, Document Control, Safety Evaluation and 11 many other programs that are required to maintain 12 operational changes in conformance with the design and 13- licensing basis.

14 The tier 3 portion of the ICAVP looked 15 specifically-at these programs, and it is worth noting that 16 the NRC preliminary conclusion at the Public Exit on January 17 28th was that the Millstone change control process satisfied 18- 10 CFR 50,_ Appendix B, and would serve to maintain a design 19 and licensing basis.

20 'It should be noted that this NRC inspection also 21 identified several issues which will need to be corrected 22- prior to restart.

23 In our August 6th meeting with you, I discussed 24 two new and innovative organizations that we have added, a 25 Configuration Management organization for each unit and an ANN RILEY & ASSOCIATES, LTD.

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64 1 Engineering Assurance function. These organizations which 2 increase our confidence that future changes will be made in 3 conformance with the design and licensing basis are now 4 staffed and functioning for both Units 2 and 3.

5 In addition, there is a dedicated Nuclear 6 Oversight Surveillance of the configuration control change 7 process and we have completed most of the specialized 8 configuration management training for over 1200 personnel in .

9 Unit 3 and the groups that support Unit 3. Unit 2 training 10 is currently ongoing.

11 Finally, self-assessment and performance 12 monitoring is being utilized to evaluate the effectiveness 13 of the Configuration Management Programs. '

14 In summary, the actions that have been taken to 15 date to restor and maintain conformance to the design and 16 licensing basis, and to address longstanding safety, 17 programmatic, organization, human performance and technical p:x 18 issues are being effective. Still, we recognize that all 19 Corrective Actions necessary to restore full compliance have 20 not'yet been completed. However, the work completed has 21 been substantial and to acceptable standards. ~

22 The remaining work to support the restart 23 readiness is on track and will restore conformance with the 24 design and licensing basis and NRC regulations. The 25 organizations, programs and processes are also in place to ANN RILEY & ASSOCIATES, LTD.

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65 1 ' maintain conformance.

2 The ICAVP Reviews to date indicate that Millstone 3 3, Configuration Management Review and Programs have been 4

effective in identifying almost all of the issues of safety 5 significance, including those issues necessary to restore 6 compliance with the design and licensing basis. In saying 7 this, I recognize that the entire Millstone organization 8 must continue in its pursuit of a healthy respect for 9

regulations from both an intent and compliance standpoint, 10 and that we must continue to demonstrate timely and 11 effective Corrective Actions.

12 In conclusion, I do believe that our overall 13 Corrective Actions approach is robust and that we have the 14 programs and organizations in place to now support the 15 conduct of safe operations.

16 It there are no---

17 CRAIRMAN JACKSON: Thank you.

18 MR. BOWLING: If there are no further questions, I 19 will turn it over to-Mike.

20 MR. BROTHERS: Good morning. The purpose of my 21 presentation today is to discuss the readiness of Millstone 22 Unit 3 to return to power operation. My assessment of 23 Millstone Unit 3's readiness is as follows: The Unit is 24 tracking as satisfactory with regard to readiness to support 25 power operation. This assessment is made up of four broad ANN RILEY & ASSOCIATES, LTD.

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66 1 areas, physical readiness, regulatory readiness, 2 organizational readiness, and operational readiness.

3 The start-up and power extension plan in 4 supporting organization support is satisfactory t( support 5 restart. This.is currently satisfactory. The Unit backlogs 6 are tracking as satisfactory to support restart.

7 The metrics oresented on the next slides are 8 designed to support these conclusions. One overall point to ,

9 make is that the slides that you have are up-to-date as of 10 February 6th, 1998. Because we are rapidly readiness to 11 enter Mode 4, these small numbers of remaining items are 12 decreaaing rapidly. I will give you the current numbers in 13 my presentation today.

14 CHAIRMAN JACKSON: Can I get you to slow down a 15 little bit?

16 MR. MORRIS: You're working on the same issue we 17 are-working on.

18 MR. BROTHERS: There's a contrast between me and 19 --

20 CHAIRMAN JACKSON: Mr. Bowling set you up.

21 MR. BROTHERS: Next slide. Under the topic of 22 physical readiness, this slide shows the number of 23 modifications which remain to support restart. As of 24 February 13th, 1998, there were five modifications 25 remaining, of which one is working in the field. The four ANN RILEY & ASSOCIATES, LTD.

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l 67

( 1 are engineering modifications that don't require physical 2 work.

3 It should be noted that the total number of 4 modifications required for restart that have been performed 5 to date is 216. The five remaining modifications bring the 6 total to 221 modifications required for restart. This does 7 not include the potential mod required to resolve the RHS 8 MOV 610 and 611 cycling problem that we discussed earlier.

9 CHAIRMAN JACKSON: Do you have emergent mods? I 10 mean when was the last new mod added? Are there ones that 11 are popping up?

~

, 12 MR. BROTHERS: Yes. We had a mod added on 13 Saturday that was associated with a DWST, demineralized 14 water storage tank uncertainty. It is not a physical mod, 15 but it's a modification to support the calculation. So they 16- are coming up, and they get assessed per our PI 20 criteria 17 as to whether or not they're required for restart.

18 This metric is tracking a satisfactory.

19 Continuing on our physical readiness, this slide 20 depicts our current status of online orders. The total 21 number of work orders remaining as of February 11 is 665.

22 All of these work orders have been individually assessed as 23 meeting our deferral criteria. We are on track to work the 24 existing numbers down to our goals of 500 power block and 50 25 . maintenance rule or PRA significant work orders prior to ANN RILEY & ASSOCIATES, LTD.

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68 1 resuming power operation. In my discussion of backlogs I 2 will give a more detailed breakdown of the 665 remaining 3 work orders. This metric is tracking a satisfactory.

4 Now shifting to regulatory readiness, Marty talked 5 earlier about the completion rate of NRC commitments 6 required for restart. To recap what he said, we' currently have 77 remaining commitments to address prior to restart.

7 8 none of which are overdue. The total number of commitments 9 which have been addressed up to now is 691. This metric is 10 tracking a satisfactory.

11 CHAIRMAN JACKSON: And you don't anticipate asking 12 to defer any of these?

13 MR. BROTHERS: That's correct.

14 Also under regulatory readiness this slide shows 15 our current significant items list status, As of February 16 12, 1998, we had six packages remaining to submit out of a 17 total of 216. This list corresponds to the 86 ones in the 18 NRC's Millstone 3 specific attachment to manual chapter 19 0350. We are on track to have all the packages submitted 20 for review and closure to support unit restart. We believe 21 that the quality of packages continues to be good. This 22 metric is tracking a satisfactory.

23 This slide shows our current status on the 5054F 24 significant items required for vestart. As Marty said, as 25 of February 17, 1998, we have 252 items remaining to be ANN RILEY & ASSOCIATES, LTD.

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69

-1 closed out of a total of 4,284 items. The 4,284 is 2 different than the 3,876 shown on a previous slide. The 3 reason for that is because of the way as Bruce characterized 4 the net being cast as TRs come in and they do in fact become 5 automated work orders, they become deferable or 5 nondeferable. So that is a movir.3 number. So we have 252 7 out nf 4,284 items. These items are also on track to 8 support Millstone 'Jnit 3 restart. This metric is tracking a 9 satisfactory.

10 This slide shows our current LER submittal rate 11 for Millstone Unit 3. The solid portion of the bars are 12 Current LERs, and the cross-hatched portions are historical l

13 LERs. This slide shows that we are below the industry 14 standard of approximately two LERs per month, although we do 15 acknowledge that the fact that we are in Mode 5 makes this a 16 non-like-to-like comparison. In addition, the 5072 prompt 17 report that went out yesterday will be an LER.

18 The historical LERs being reported shows that our 19 low threshold and questioning attitude continues to be 20 fostered at Millstone station. As we return to power 21 operation we will monitor our performance in this area.

22 This monitoring, however, will be on a strictly benchmarking 23 manner to preclude the adverse consequences of trying to 24 directly improve this indicator. This metric is 25 satisfactory.

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70 1 The third broad topic under unit readiness is 2 organizational readiness. This slide shows our 3 organizational readiness assessment as of February 10, 1998.

4 This methodology complements the nuclear oversight restart 5 verification plan by assessing departmental readiness, 6 whereas the nuclear oversight restart verification plan 7 assessas the issue of programmatic readiness.

8 An easy distinction between the two assessments is 9 to concrast this assessment of the corrective action which 10 addresses the departmental effectiveness of the correction 11 action department versus the nuclear oversight restart 12 verification plan assessment of corrective action which 13 addresses the broader implications of the effectiveness of 14 the corrective action program at Millstone Unit 3.

15 With the above explanation in mind, let me discuss 16 the organization is assessed as not yet a goal but tracking 17 a satisfactory for Millstone Unit 3. As of February 10 the 18 operations department is assessed as tracking a satisfactory 19 based upon training that is required for Mode 4 and not yet 20 being complete for all shift personnel. As of today that 21 should be in fact done.

22 This will be completed prior to Mode 4 and the 23 operations departs.ent will be satisfactory prior to entry 24 into Mode 4.

25 Work planning outage management is assessed as ANN RILEY & ASSOCIATES, LTD.

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71 >

1 tracking a satisfactory based upon schedule adherence not 2

yet being at our operational goal of 75 percent of planned 3

activity starting on time and 70 percent of those planned 4 activities completing on time. Our current percentages are 5 62 percent and 55 percent respectively. This is not 6 expected to be a goal before entry into Mode 4, but will be 7 a goal prior to entry into Mode 2.

8

. Maintenance planning is assessed as tracking a 9

satisfactory based upon the restart backlog goals not yet 10 being a target, but all the items are tracking a 11 satisfactory. These goals are also Mode 2 goals.

~

12 Training is assessed as tracking a satisfactory 13 based upon the fact that we have not yet completed our 14 evaluations as to the extent of the systems approach to 15 training problems within training and the Millstone Unit 3

-16 shift technical advisor program status. Both of these two 17 areas will be satisfactory for Millstone Unit 3 prior to 18 entry into Mode 4.

19 Licensing is assessed as tracking a satisfactory 20 based upon the continued need to extend an excessive 21 percentage of commitments. This is expected to be evaluated 22 as satisfactory for Millstone Unit 3 prior to entry into 23 Mode 4.

24 Finally, management is assessed as tracking a 25 satisfactory based upon greater than five percent of CR ANN RILEY & ASSOCIATES, LTD.

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72 1 evaluations taking longer than 30 days. As discussed by 2 Dave Amerine in his discussion on CR evaluation timeliness, 3 the average age of evaluations is less than 30 days, and the 4 quality of evaluations continues to remain high Increased 5 attention is being applied to this area, and we will assess C overall management ef fectiveness as satisfactory prior to 7 entry into Mode 4.

8 In summary, we expect all departments with the ,

N 9 exception of work planning, outage management, and 10 maintenance planning to be assessed as satisfactory prior to 11 entry into Mode 4. In addition, all of the departments will 12 be assessed as satisfactory prior to entry into Mode 2, 13 This slide under the overall topic of operational 14 readiness shows our current number of temporary 15 modifications which are installed on Millstone Unit 3. Our 16 goal is to nave less than 15 temporary modifications 17 installed prior to entry into Mode 2. We currently have 18 18 temporary modifications installed, three of which are for 19 outage support. We are on track to meet this goal prior to 20 entry into Mode 2. This metric is tracking to satisfactory.

21 Continuing under operational readiness, this slide '

22 shows our current status on control room and enunciator .

23 deficiencies. Our goal is to have less than ten 24 deficiencies prior to entry into Mode 2. As of February 11, 25 1998, we have ninc deficiencies. This metric is

=-

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8 u

73 I satisfactory.

2 This slide shows our current number of operator i 3 workarounds at Millstone Unit No. 3. Our definition of an ,

4 operator workaround is based upon industry standard

! 5 definition. Our goal is to have less than ten operator i

6 workarounds prior to entry into Mode 2. As of February 8, j' 7 1998, we have eight operator workarounds. This metric is 1

8 satisfactory, j 9 This slide shows our percentage of low 10 significance or precursor events as a percentage of all 11 human error events. It is desirable to have a high 12 percentage of Icw-significance errors to total errors to 13 allow for the implementation of corrective action at a lower 14 threshold, thereby preventing more significant events. An 15 example of a precursor event will be a tagging error caught 16 by the individual performing the second check of the_ tag.

17 A higher level event or near-miss would be the 18 same error missed by the second checked but caught by the 19 worker prior to commencing work. A breakthrough event would 20 be a failure of all the barriers, the initial tagger, the 21 second checker, and the worker, and then work actually being 22 performed on an incorrectly tagged component.

23 We have set an extremely high percentage goal in 24 this area of greater than or equal to 95 percent of all 25 human errors being classified as low significance precursor ANN RILEY & ASSOCIATES, LTD.

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1 74 1 errors. Although in December we fell to 92 percent, in 1

l 2 January our performance was once again at goal, and as this 1

4 3 slide shows, our general performance exceeded goal for the j 4 last seven months.

5 During that same time, there have been no 6 treakthrough events in which all the barriers failed or

7 significant consequences have occurred. This metric is 8 satisfactory.

9 This slide shows our current errors per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> l 10 worked for technical and administrative procedures at 11 Millstone Unit 3. We show an increase in both the technical 12 and' administrative e.*or rate in December. As Bruce pointed 13 out in his summary remarks, this caused us to change our l

i 14 assessment from satisfactory to tracking to satisfactory in 15 the area of procedure compliance.

16 January's levels returned to approximately our 17 previously low historic values, but continued good l

18 performance in this area is required before we once again l 19 rate procedure compliance as satisfactory for Millstone Unit 20 3.

21 CHAIRMAN JACKSON: Why do you feel you have the 22 problems in the administrative procedures area this far down 23 the line?

l 24 MR. BROTHERS: We have taken a look at that. I 25 think what you had was the same type of thing we Alai RILEY & ASSOCIATES, LTD.

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75 1

demonstrated in the timeliness evaluation during the January 2 time frame. The December period of work at Millstone Unit 3 3 was the most extensive period of work that we had for the 4

last two years, and I think we saw the corresponding --

S CilAIRMAN JACKSON: You said because of the 6 concentration of the work?

7 MR. BROTHERS: Yes, the physical work and driving 8

to complete the integrated leak rate test in the beginning 9 of January was compressing, and in our view was what caused 10 things to happen.

11 This metric is tracking to satisfactory.

12 This slide shows an overview of our heat-up, 13 start-up and power ascension program. I have seven points 14 to make here.

15 We have an approved procedure which governs a 16 heat-up, start-up and power-ascension of Millstone Unit 3 17 which takes into account the fact that we have been in cold 18 shutdown for approximately two years. We have a dedicated 19 start-up crganization which has been in place since January 20 12th, 1998, to provide integration and management support as 21 the unit returns to power operation.

22 We currently have in place shift mentors for 23 operations which we will expand with NU and non-NU senior 24 reactor operators as the unit returns to service.

25 Our operating crews are visiting operating plants ANN RILEY &_ ASSOCIATES, LTD.

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76 1 and have observed plant start-ups during the last few 2 months.

3 Specific heat-up and start-up training will be 4 provided to all operating crews. Training on modifications 5 has been largely completed and will be completed for all 6 crews prior to entering mode four.

7 Finally, the dates and the days given here are to '

8 provide a framework for planning only. We will conduct a ,

9 measured and controlled return-to-power operation, taking 10 whatever time is required. Unit management will not rush to 11 return this unit to service. My unit and engineering 12 directors will recommend to me and receive permission from 13 me prior to making any mode change as the unit is sequenced 14 back to power operation.

15 This slide shows the current numbers for the seven 16 broad areas which make up our deferrable items. I have 17 previously discussed the corrective maintenance, operator 18 work-arounds, control room deficiencies, and temp mods, and j 19 Marty has discussed the configuration and management items l

20 in his presentation.

21 The remaining items, corrective action 22 assignments, corrective maintenance, and engineering _,

23 backlogs have been individually reviewed by our management 24 review team and expert panels.

25 The next three slides further characterize our ANN RILEY & ASSOCIATES, LTD.

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77 1 current progress in the areas of corrective action 2 assignments, corrective maintenance and engineering backlog.

3 This slide gives a breakdown of our deferrable 4 corrective action assignments. Roughly half of these items 5 fall into the area of minor procedure or documentation 6 improvements. None of these, or any of the remaining 7 deferrable items, affect the design or licensing basis of 8 Millstone Unit No. 3.

9 A review by our probabilistic risk assessment 10 group has been conducted on all of these assignments. This 11 review first screened the 2260 items to look at only 12 maintenance rule items. As you know, the maintenance rule 13 includes systems which are risk and safety-significant, 14 systems which are risk or safety-significant, and systems 15 which are in scope, but are neither risk nor 16 safety-significant.

17 This screen reduced the 2260 items to i 18 approximately 1000 items, These 1000 items were 19 individually reviewed by a team in our PRA group. This 20 review identified approximately 250 items which required 21 additional information to verify that they were in fact 22 deferrable.

23 Additional information was provided on those 250 24 items, and the final result was the identification of 11 25 items out of the original 2260 for further consideration by ANN RILEY & AS MCIATES, LTD.

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78 1 line management. This consideration is under way.

2 1 do want to point out that this leview has not 3 yet been conducted on the engineering backlog that you see 4 in two more slides. Within that engineering backlog was the 5 RHS issue that we discussed earlier. That review will 6 occur, however, prior to entering mode two. ,

7 I consider this an excellent cooperative effort 8 with our organization that gives us added assurance that our ,

9 deferrable items are properly characterized.

10 This slide shows our breakdown of our corrective 11 maintenance backlog. Approximately 52 percent of this 12 backlog is associated with maintenance rule systems, and 13 none of these items affect system operability.

14 Let me just describe what these headings mean. An 15 example of a non-functional component which does not affect 16 system operability would be a non-functional local 17 temperature indicator on a piping system. The system is so 18 operable with a non-functional temperature indicator. It 19 should be emphasized that this classification cannot be 20 applied to any component directly covered by technical 21 specifications or used to ensure continued operability for 22 any technical specification, component or system. .

23 Equipment which is functional characterization 24 covers minor degradation which does not in any way affect 25 component or system operability.

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79 1

The remaining 48 percent of our power backlog is 2 associated with non-maintenance rule systems, so they are 3 not risk, not safety-significant, and not in scope. ,

4 Thic slide characterizes our current engineering 5 deferrable items. 65 percent of this backlog is associated 6

with enhancements or modifications which have been screened i 7 by unit management as appropriate for future consideration, i

8 but unnecessary to perform at this time. 20 percent of the 9 engineering backlog is devoted to component level 10 engineering in which, for some reason, an exact replacement 11 part is not available.

12 The remai'41ng 15 percent is made up of items such 13 as administrative tetions or organizational / programmatic 14 enhancements. As i described earlier, our corrective action 15 assignment backlog nas been screened for individual and 16 aggregate impact by our PRA group.

17 As we approach mode two, we are continuing to work 18 down all of our deferrable item areas. As such, we will 19 perform another assessment of the aggregate impact of all 20 deferrable items shortly before entering mode two.

21 It should also be emphasized that we have 22 benchmarked ourselves against recent industry experience for 23 all the metrics I have presented today. Millstone Unit 3's 24 goals, when stacked against these goals, compares favorably 25 to units which have recently started up after extended ANN RILEY & ASSOCIATES, LTD.

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80 1 outages.

2 In summary, we believe that Millstone Unit 3 wi.! i 3 shortly be ready to enter mode four and begin the controlled 4 sequence which will lead us to meeting all our goals and 5 satisfying the prerequisites for mode two by late March of  !

6 1998. Millstone Unit 3 is on track to return to power 7 operation with the unit ready from a physical, regulatory, 8 organizational hnd operational standpoint. ,

9 Our start-up and power ascension program is in 10 place and ready to support the unit. Our backlogs are at 11 reasonable levels and have been screened both internally and 12 ext 6rnally, from an individual and aggregate impact 13 standpoint, to fully support our plans to be ready in all 14 aspects by late March of 1998 to return to power operations.

15 If there are no questions, I'll turn it over to 16 Dave Goebel to discuss nuclear oversight's current 17 assessment.

18 COMMISSIONER DIAZ: Yes, if I might go back to '

19 your figure on Table 62 of slide 62, I'm sure that Mr.

20 Morris saw this and understood very well every one of these 21 ~ items, but I didn't. And I know that now you have gone and 22 explained it. This figure, when I saw it yesterday, you ,

23 know, created some concerns because, you know, we started 24 with a series of 6000 issues, and then we classified them.

25 I would recommend that, you know, when you get back in here, ANN RILEY & ASSOCIATES, LTD.

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81 1

you take this and do like what you did in your quick 2

presentation, you know, like saying there are only 11 of s 3 2260 items Phat are being considered. That narrows the I scope down significantly.

4 If not, it looks like an 5 insurmountable task to be done, you know. And clearly, you 6 know, there'are differences in here that need to be reviewed 7 to determine the risk significance, and obviously you have 8

been doing all of those things, and I hope you keep doing  :

9 it. But it's not obvious from this table when you look at 10 it. And I strongly recommend it, please. You know, ,

11 separate them, even when you put them in a table that, you 12 knok, it's not clear at all what the meaning of these things 13 are.

14 MR. BROTHERS: Thank you.

15 MR. GOEBEL: Good morning. Today I would like to 16 present the current status of the nuclear oversight restart 17 verification plan for Unit 3. The data is shown on this 18 slide.

19 I would like first to review what the slide 20' depicts. There are 21 issues; each is listed on the left-hand side of the slide.

21 These were taken from the 16 22 in the summary book which we provided you, and selected 23 other issues which I feel are important.

24 One item in the latter category is materials, and 25 another is engineering.

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82 1 Attributes are evaluated _for each issue, and those 2 attributes are derived from the NRC's manual chapter 0350, 3 INPO guidance, in particular 96-006, and other relevant 4 documents. The attributes are evaluated throughout a 5 two-week period and the summary scores derived. A roll-up 6 of the scores in a given area resulting from this look is then related to a color, either red for significant,-yellow 7

B for improvement needed, or green for satisfactory. Those ,

9 colors are then displayed on this slide.

10 In general, for an issue to change color, two 11 evaluation periods at the new level are needed.

12 Since our last meeting, there is leadership, 13 corrective action, configuration of management, regulatory 14 compliance, conduct of operations, and environmental 15 monitoring have turned green, while procedure quality and 16 procedure adherence has gone from green to yellow, as 17 problems once fixed have resurfaced, and this has been 18 discussed previously.

19 You will note a green dot adjacent to the 20 emergency preparedness area. If all goes well, this area 21 will turn green this week. .

At the last evaluation two weeks 22 ago, it had exceeded the limit to move into the green area. ,

23 There are three key areas which are in yellow that 24 are impacting our moving forward. There are others that are 25 yellow, but today I am comfortable with their status. The ANN RILEY & ASSOCIATES, LTD.

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83 1 three areas which require increased management attention are 2 procedure quality adherence, training, and work control and 3 planning, and those have been discussed by other gentlemen 4 at this table earlier.

5 1 would like to discuss each area as each is 6 clearly defined activities which require improvement. It is 7 my opinion that if these activities are completed, these 8 areas will achieve a green status and be ready for restart.

I j 9 The first is procedure quality, procedure 10 adherence. Procedure quality has improved since the last 11 briefing, but adherence issues have resurfaced. Those areas 12 which require increased management attention include 13 increased coaching by the first-line supervisor. You recall 14 the last time I stated that increased first line supervision 15 time in the field is the most beneficial change we can make 16 in this area.

17 Another area requiring attention is providing 18 feedback to all affected workers on problem areas, and the 19 third is holding people accountable for adherence problems.

20 Additionally, we need to prioritize and complete 21 the remaining procedures which are required for restart. I 22 don't see this as a problem, but additional work must be 23 done in this area.

24 In the area of work control and planning, which is 25 another area requiring increased management attention, we ANN RILEY & ASSOCIATES, LTD.

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84 1 need to improve our schedule adherence, and Mike Brothers 2 has mentioned that.

3 The primary sources of schedule adherence '

4 difficulties are work package quality, work release start 5 times, work prioritization, and schedule development 6 assumptions.

7- Among the issues in this latter-category -- that 8 is schedule development assumptions -- we need to improve ,

9 the coordination between operations and the various work 10 groups in establishing a schedule.

11 Additionally, we need to obtain management support 12 and' accountability for accomplishing this schedule as it is 13 laid out.

14 In the training area, the training area is one of-15 great importance to the organization and has been discussed 16 previously, as the others have.

17 Increased attention is required in several areas.

18 Complete the qualification of systems engineers prior to 19 final system verification of readiness for start-up must be 20 done. We need to ensure that the system's approach to 21 training is functioning for Unit 3 as it was designed. We

• 22 need to ensure that items from the corrective action plan 23 which resulted from the shutdown of training are properly 24 clcsed, and on a longer _ term basis we need-to verify that 25 the proper staffing skills are present within the ANN RILEY & ASSOCIATES, LTD.

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1 85 1 organization. 1 2 As I said, these three remaining areas provide the 3 biggest barrier to near-term success, and additional effort 4 is needed to ensure that success.

5 Subject to any questions, I'll pass it back to l

6 Bruce for his closing remarks.

7 CHAIMUd1 JACKSON: Tall me again about the s

8 -emergency preparedness area that's been tracking steadily 9 yellow.  !

10 MR. GOEBEL: Right.

( At the last session, which 11 --and I hold these sessions -- the people do the work on a 12 dall'y basis. We have a roll-up on a two-week basis, and at 1

- 13 the last roll-up two weeks ago, it will be reviewed again 14 today and tomorrow, but two weeks ago, with a score that 15 could drive it into the green area as being a 70 cut-off, it 1

16 received a score of 80. So far a two-week period preceding >

l

17 that, it was essentially green, but we have an internal 18 process where we don't change the color because we want it 19 to sustain and hold; we just don't want a fluke up or down.

20 So if it goes well this week, then I expect it to sustain i

~

• 21 and stay at that level, and my information from my people 22 who are doing this week are the indications that it will 4

t 23 stay there, it will go up. I need to wait and get the 24 score.

25 CHAIRh9JJ JACKSON: Okay.

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86 1 MR. KENYON: Chairman Jackson and Commissioners, 2 we appreciate the opportunity to brief you regarding our 3 progress. Certainly as a result of recent events and this 4 meeting, we recognize the need to deal with the RHS valve' 5 cycling issue. We will do that. We will look at it for its 6 implications, and we certainly understand that we need to 7 test that against what it means for the credibility of our

)

1 8 deferred items list, and we will do that.

9 We also have what I have referred to as the 10 oversight event playing out, and I need to get the remaining 11 information there, but I want to assure you that I will take 12 appropriate action in due course and with every intention of 13 demonstrating that this organization can and will handle, 14 with careful deliberation, even of a serious event such as 15 this, and this really should set the stage for an 16 understanding of how this organization -- it's not that we 17 never have an event, but it's when we have one, we know how 18 to handle it and handle it responsibly.

19 We have an understandable concern on your part on 20 the nature of the backlog, and Commissioner Diaz, we 21 understand-the need to make our -- whereas we are 22 comfortable, we have a responsibility to portray the ,

23 information in a way that'b clear as to what's outstanding.

24 We need to do it in a way that makes a clearer statement as 25 to its relevance, its significance, and we will do that.

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~_ . . _ _ . _ . - _

i l

1 87 t 1 Having said all that, I think we are close.

We 2 have a manageable amount of work remaining. I think that  ;

j 3 performance indicators show that, and certainly I look '

t i 4 forward to our next bc!efing, and the work force and the 1

5 leadership team is starting to get excited after a long i 6 haul.

7 Mike, do you want to add?

8 MR. MORRIS I would just close with one comment, i

! 9 Chairperson Jackson. You asked a question about whether we i

j 10 were surprised on the amount of effort that it's taken to 11 get to where we are today, particularly with the license and 12 design bases. I think we are impressed with what it has 13 taken, deeply impressed with what it has taxen, and by that 14 I mean to say that we understand what it would be like, I 15 think, to be on the other side of > ts gap again, and I 16 think this team is prepared, from the comments that you have 17 seen today and the data that you have seen today, that if j 18 you believe with us that we are ready to come back on line, j 19 we understand what it is going to take to stay there,

20 because we never want to have to do this again. It is an

21 impressive amount of work.

22 Thank you.

?

• 23 CHAIRMAN JACKSON: Well, thank you, h 24 Normally I would wait till the very end to make ,

a 25 some comments to you, but I wil], and they nre in the way of i

. AMN RILEY & ASSOCIATES, LTD.

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88 1 reinforcing some things that in fact Mr. Kenyon has already 2 spoken to.

3 You know, we have a responsibility in making our 4 decisions with fairness, and that creates a very narrow line 5 that we end up having to walk, and many times the question 6 is raised of, well, if any other unit or licensee in the 7 country had the degree of scrutiny that you folks have had, 8 would not these kinds of issues have turned up then? And ,

9 wouldn't we find some lack of conformance with design or 10 licensing basis issues? Would we not find some of the kinds 11 of employee concerns, difficulties, et cetera, that the l

12 licensee has had? And, you know, I tend not to get into 13 those discussions, and I will tell you why: fundamentally 14 because we can't do that, because we are where we_are, and 15 that's what we end up having to deal with in the end. And 16 even though most of you who are the incumbents in the 17 position today were not in these positions when at least 18 this latest episode began, the organization _got to where it 19 is because of its historical problems and historical 20 patterns and the longevity of those problems, and a history of perhaps pencil-whipping problems away, and in some sense 21 22 you come to a point where in a way that something that you ,

23 are struggling with is the issue of if we can't have 24 confidence relative to the little things, it raises questions about the confidence with respect to big things.

~

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89 1

And that's what the results in the end have to demonstrate, 2

that it is a comprehensive approach to dealing with things, 3 such that, yes, at any given time there can be items that 4 pop up, items that are unresolved.

5 The obvious confidence one is going to have is G

particularly the things that have the greatest safety

?

significance are addressed, but that is undergirded by an j

8 approach and a philosophy and a way of doing things that 9 says one aggrensively goes'after issues and gets to the root i 10 of them, and therefore, in looking at how deferred items are 11 evaluated, how they are addressed, what you do ends up 12 having to be evaluated in that regard. It's not --

it may 13 not make you happy, but in the end it does come to that, and 14 that's why the recent issue -- and we all recognize that it 15 has to be fully evaluated and all of its implications drawn 16 out -- but why it is troubling with regard to everything I 17 have laid out. Because of its implications for 18- self-discovery of problems, robustness of evaluations. And 19 so it is very important that it-get reviewed, not just for 20 the issue-specific clarification or, yes, if it's a Part 21 21 issue, then we are going to have to deal with that from the 22 broader perspective.

0 23 But you have to look at it from both its generic 24 implications, but it's important that you give everything, 25 whether it's 4200 or 5000, whatever the number is, a ANN RILEY & ASSOCIATES, LTD.

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90 1 complete scrub, obviously with respect to safety 2 significance. That's the base line.

l 3 But one really does have to ask the question of if 4 there are historical-items, then you are kind of on the spot 5 as to say why, particularly if they are in a 6 safety-significant system, but just generally because of-7 what I said. If it's historical, why should you continue to 8 defer it? And I'll say more at the end. And I appreciate ,

9 the comment -- I think it's implicit in something you said, 10 Mr. Brothers, about having the total review of all of the 11 engineering items. And so the question is, as you go 12 forsard to do that, then you have to ensure that you don't 13 miss things like this, because we are where we are.

14 MR. MORRIS: We fully understand that.- We will 15 tighten the mesh on our acreen and rerun. We understand 16 your point. Thank you.

17 CHAIRMAN JACKSON:- Thank you.

18 We will now hear from Sargent & Lundy.

19 As is structured, we are going to hear from 20 Sargent & Lundy, and then from Parsons Power.

21 MR. ERLER: As we have done before, Sargent &

22 Lundy will provide some lead-in to cover both overall review 23 process and then the details on Unit 3 review that-it 24 completed. I am Brian Erler, the project director for the 25 ICAVP for Unit 3 for Sargent & Lundy, and Don Schopfer, the SJUJ RILEY & ASSOCIATES, LTD.

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91 1 project manager for the review team.

Don will present the 2 summa ry .

3 MR. SCH0PFER: Good morning.

4 The first niide we have is again it's sort of a 5

refresher of the structurL of the ICAVP, and I'll go through 6 these rather briefly. I know you have seen them before.

7 The structure of tha ICAVP is broken down into 8 three tiers as required by the Commission paper 97-003.

9 Tier 1 is the system verification to confirm that the system 10 selected meets the licensing and design basis, and system '

11 functionality.

12 Tier 2 is the accident mitigation system review to ,

13 determine that those systems that design parameters meet the 14 requirements in the FSAR, 15 And Tier 3 is the programmatic review, or the

-16 review to verify that configuration control processes have 17 not introduced changes into the licensing and design basis.,

18 CHAIRMAN JACKSON: Now you can always depend upon 19 me to do this, If I look two slides down the road at these 20 tiers, you marked them_ complete. Now when yon say that, do 21 you conclude that you have made the verifications that are 22 laid out in each of these tiers?

23 MR. SCHOPFER: We have.

24 CRAIRMAN JACKSON: Or does it mean something else?

25 MR. SCHOPFER: It means that we have completed the ANN RILEY & ASSOCIATES, LTD.

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i 92 1 discovery process and the reviews, and have identified all 2 of the discrepancy reports, preliminary discrepancy reports 3 from those tiers. Now the resolution of those preliminary 4 DRs has not been completed yet, but the review process and '

5 the discovery process and identification of any 6 discrepancies is complete for those items.

7 CHATMOUJ JACKSON: Okay. So discovery, review and 8 identification of the DRs --

9 MR. SCHOPFER: Correct.

10 CHAIRMAN JACKSON: -- is what you mean when you 11 say complete?

12 MR. SCHOPFER: Correct.

13 CRAIRMAN JACKSON: Okay. Thank you.

14 MR. SCHOPFER: The scope of the Tier 1 system 15 review is as shown here. It lists the 15 maintenance rule 16 group 1 and 2 systems that comprise our grouping of four 17 systems which we have used the shortF7nd designation at the 18 botMom of the page in bold that describes service water, 19 RSS, NVX, which we termed the ventilation systems, 20 supplemental leakage collection and release system is what 21 SLCRS stands for, and the aux building ventilation 22 safety-related portion of the aux building ventilation and 23 the emergency diesel generator room ventilation system. And 24 then the DGX system consists of the diesel generator and all 25 the associated auxiliary systems supporting the diesel i

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93 1 generator and the electrical 4160 volt distribution system. l 2 As four, I'd like to mention that the scope of the 3 review for these systems also includes the review of the 4 electrical power feeds from each component in these systems 5 up to the first motor control center, and then a load path 6 review from that motor-control center to the diesel 7 generator. Also the I&C signals that interface with these 8 systems from other systems are included in the review 9 process.

10 CHAIRMAN JAChSON: I see.

11 MR. SCHOPPER: And any supporting systems from a 12 mechanical standpoint also.

13 CHAIRMAN JACKSON: So let me ask you a question 14 about the RSS. VHlat is your assessment of the difficulties 15 that the licensee has had with the recirculations crisis?

16 MR. SCHOPFER: I am not sure I understand the 17 question, Chairman Jackson.

18 CHAIRMAN JACKSON: Well, it seems that it has 19 taken a long time to kind of, you know, come down the line, 20 pin the problems down, get, you know, comprehensive fixes, 21 et cetera. But I don't want to say it, I want you to talk i

22 to me.

23 MR. SCHOPFER: Well, there have been a number of 24 issues and problems associated with that, and Mike Brothers 25 identified those.

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94 3

C11 AIRMAN JACKSON: So you basically agree with his 2 assessment?

3 MR. SCHOPFER: Well, I agree with -- you asked 4 what the problems were, and there were a number of those.

5 And it has -- there have been a number of modifications made 6 to this system after we started the review. And, in fact, 7

as you will see on the next slide, there are some additional

• 8 modifications that the staff has asked Sargent & Lundy to ,

9 look at that have just been completed or are being 10 completed.

So -- which came out of some of the earlier 11 reviews of the previous mod. So it has been a continuing 12 process for the RSS system in particular.

13 The basic system review in Tier 1 and the Tier 2 14 and Tier 3 reviews, as we discussed a few minutes ago, is 15 complete from the standpoint of discovery being complete, 16 and the Discrepancy Reports being issued. The two items 17 remaining from -- associated with Tier 1 is these additional 18 recirculation spray systems mcdifications that were given to 19 us for review $n late November of '97 and we have completed 20 that first set of reviews.

21 .

We also have these additional four modifications 22 that the staff has asked Sargent & Lundy to look at, and 23 those were just completed this past week or the week before, 24 We are in the process of receiving those packages, that 25 calculations, those modification documents and completing ANN RILEY & ASSOCIATES, LTD.

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1 l  !

4 95 1 that review. We expect to get those documents this week and  ;

j 2 we will complete our review in about two weeks after we 3 receive everything.

4 CHAIRMAN JACKSON: Was the RSS system -- RS system

! -5 operable before these modifications?

l

, 6 -- MR. SCH0PFER: I guess -- I don't know the answer l_'

i 7 to that. They are modifications that are improvements, j*

8 certainly, to some of the cycling of the valves that were l 9 occurring in the changes they made. The other changes go 10 back to a direct injection system into the vessel that was j 11 one of the original design and sort of undoes one of the 12 cha6ges, and I think the licensee had determined recently 13 that that was an unreviewed safety question, so there were

' 14 significant issues.

j 15 I guess I don't know the answer.

l 16 CllAIRMAN JACKSONi I am going to ask the staff i 17 that, so I am giving you a heads up.

18' MR. SCH0PFER: The second issue of items that are 19 being completed is the Tier 1 Corrective Action i 20 Implementation Review, and that is there was a Corrective 21 Action Review as part of the Tier 1 system of some 1500 3

22 Corrective Action documents. We selaJted and screened and 23 came up with about 250 to 260 specific Corrective Action

, 24 documents that the staff wanted us to look, I'll say at more 25 detail in the implementation, not just the Corrective Action 1

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96

) 1 plan, but what the results of those Corrective Actions were 2 in terms of, again, engineering activities, analyses, 3 evaluations, calculations and those sorts of things.

j 4 We are still obtaining some of those documents i 5 from Northeast Utilities and expect those this week and next ,

6 week and, again, have about a two week completion date after

, 7 we receive those documents.

• 8 The final report, as noted here, is already in ,

9 preparation. We expect to be able to issue that final 10 report approximately the end of March, based on the current 11 schedule of completion the resolution of the Discrepancy 12 Reports that we have issued and NU's comments earlier about 13 their schedule for completing their responses to us.

14 Just a brief, again, lesson or reminder of how our 15 Discrepancy Report process works with the -- with both 16 Sargent & Lundy and Parsons, and then I will address the 17 comment -- the quCstion you made about the difference l 18 between Sargent & Lundy and Parsons, threshold, perhaps, if 19 I can.

20 CRAIMCW JACKSON: All right.

l 21 MR. SCHOPFER: The NRC staff and Sargent & Lundy 22 and Parsons have developed this common process for reporting ,

23 the findings identified during the review process. An 24 individual reviewer initiates a preliminary DR. It 25 undergoes an internal review process within Sargent & Lundy a-ANN RILEY & ASSOCIATES, LTD.

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i i

97 l

1 or Parsons. Upon completion of that process, the 2 preliminary DR is issued to Northeast Utilities, the NRC and 3 the NEAC, the state of Connecticut agency, and is posted to 4 the web site.

I 5 Northeast Utilities evaluates the preliminary DR 6 and submits a response, and we review that response and 7 either return it wi'.h additional comments or questions, or 8 close the DR. That DR --

9 CHAIRMAN JACKSON: Let me ask you a question.

10 Closure -- is closure based on the response, or if it 11 involves a physical non-conformance or something that has to be done, is it closure after that which has to be done is 12 i

13 done? Is that what closure --

14 MR. SCHOPPER: Closure, in our process, means that

15 we have reviewed their response, accepted their Corrective J

16 Action plan and, in some cases, we do wait to see that 4

17 action, if it is an engineering action. If it is a 18 significant engineering action, I guess I should say. We do-19 not, if they say they are going to correct the FSAR, we do 20 not hold that open until they correct that FSAR. That will

[* 21 go into their Corrective Action process and make sure that 22 that happens. But if they need to make a calculation change i 23 or a drawing change, or a licensing document change, and

, 24 they commit to doing that, that allows us to close the DR 25 frem the standpoint of the ICAVP. '

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f 98 1 The response from NU is expected to include 2 whether the condition identified as a discrepancy, whether l 3 they had previously ident$fied this issue in their 4 Configuration Management Plan, what action has been or will  ;

5 be taken to correct the deficiency -- the discrepancy,

! 6 whether they agree with the significance level that we established and assigned to the DR, if there is any impact

?

8 on plant hardware and, in the case of generic or 9 programmatic issues, the response should also address the i

10 extent of condition.

11 The DR may be closed based on acceptable response, i 12 and'it is categorized as a confirmed DR, meaning that they 13 agree that it is discrepancy that they had not previously

• 1 14 ident ified,_ or it may be identified as something that they 15 did previously identify during their process, or it may be l 16 considered non-discrepant based on additional information,

17 technical information that has been provided by NU and we 18 agree with that.

19 CHAIMWui JACKSON: Now, looking ahead again, your 20 last slide indicates that your preliminary conclusions 21 include that you have -- it was judged that calculation 22 control and radiological calculations are weaknesses. So 23 does that mean that besides individual DR closures, that you 24 actually trend and assess the more programmatic weaknesses?

25 MR. SCHOPFER: Yes, we do.

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99 i

The next slide does show tha .ignificance level, 2 the DR significanca *vels that have been assigned, created 3

by the NRC staff ano both Parsons and Sargent & Lundy use 4 this criteria to assign significance level. To address your 5 comment, the question that you had earlier, is there a 6 difference in threshold, I will answer to the extent that I 7 can in tertas of how we do it.

8 The criteria is not so specific between level 3 9 and level 4 that there are -- there can frequently be some 10 level of opinion whether something should be a level 3 or 11 level 4. The criteria between level 1 and level 2, or 12 between a level ?. and level 2 versus a level 3 is more 13 clear, and I think that is probably where your com.uents were 14 directed, is at level 1 and 2 versus level 3 and 4, but that 15 is a gue s on my part.

16 The level 1 or 2 means that the system, based on 17 the finding, the discrepancy, was not able to perform its 18 design function, either one train or both trains. And our 19 approach has been, if we are able to determine that via the 20 review and say that, then -- then we classified it as such.

21 If we were -- if there was a discrepancy that needed

.. 22 evaluation by NU to determine the extent, we classified it 23 as level 3 with words to, in the Discrepancy Report, asking i

24 them to evaluate this so that the final significance level 25 can be determined, and that's the approach that we have ANN RILEY & ASSOCIATES, LTD.

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100 1 taken.

2 If we are able *o say it doesn't function, from 3 our review, we don't do L.ie calculations or evaluations to 4

determine the final outcome, that is NU's responsibility and 5

we ask them in our DR to evaluate that so that a final 6 significance level can be determined.

7 CHAIRMAN JACKSON:

So if it requires some 8

additional analysis, you essentially -- the default position ,

9 is level 3?

10 MR. SCHOPFER: Correct.

11 CHAIRMAN JACKSON: And so the ultimate 12 catbgorization depends upon this additional analysis?

13 MR. ERLER: They must complete the analysis in 14 order to establish a significance.

15 CHAIRMAN JACKSON: And then as part of your 16 yg closure, you go back and evaluate that that analysis has 17 been done, and that the proper -- and you concur that the

.? level assignment is what is suggested?

14 MR. ERLER: That is correct.

12 0

' CHAIRMAN JACKSON: That you accept it or reject 21 it, is that correct? .

22 MR. SCHOPFER: Yes.

23 CHAIRMAN JACKSON: Okay. But the default position 24 is level 3. I didn't know that, that's interesting.

25 MR. SCHOFFER: That's the position that we have ANN RILEY & ASSOCIATES, LTD.

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^-- --

101 1 taken to the processes.

2 CHAIRMA1; JACESON: And you are going to speak to 3 how you do that, wh<sn you --

4 MR. CURRf: Yes, ma'am, I can't make a comparison, 5 but I can talk about how --

6 CHAIRMAN JACKSON: Please.

7 MR. SCHOPFER: The next slide shows the Summary 8 Table of the Discrepancy Reports that have been issued. The 9 first column is the number of -- total number of Discrepancy 10 Reports that have been issued, broken down by the 11 significance level. These numbers will be different, or are 12 different than the numbers you saw on the Northeast 13 Utilities alide because they are taken as of a different 14 date. These are as of Monday of this week. I think the NU 15 numbers were from a different date.

16 The second column is their responses and, as Mr.

17 Bowling said, these numbers change now very rapidly. Their 18 number is well over 700'now, and our number of responses in 19 the system and evaluations are going up. Also, as the next 20 slide will show. But NU, as of this date, had responded to 21 approximately 75 percent of the DRs that had been issued as 22 of that date, and we have evaluated approximately 40 percent 23 of those submitted.

24 We have been utilizing face-to-face meetings and 25 conference calls in accordance with established protocol to ANN RILEY & ASSOCIATES, LTD.

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102 1 resolve the mor$ difficult technical Discrepancy Reports and 2 --

3 CHAIRMAN JACKSON: What does resolution involve?

4 MR. SCHOPFER: Resolution, i .' their response 5 doesn't address all the issues that I laid out as what we 6 expect on a response, if they have a technical response that 7 our reviewers don't agree with, or don't have sufficient 8 inf ormation to agree with, then, usually, a conference call ,

9 or a meeting will be held to lay out those concerns, from 10 our standpoint, for them to provide any responses to 11 questions that we. may have about their response.

12 We had a series of meetings last week at Millstone 13 where we did it by topic, where the HVAC filter unit, we had 14 a number if discrepancies written on that, and we had a 15 _ meeting that discussed about 12 or 15 individual DRs on that 16 subject, so that we had the right people there and provided 17 the information, and the basis for why we thought it was a 18 particular issue, not in compliance with a requirement, and 19 they gave their response to that.

• s 20 CHAIRMAN JACKSON: So let me make sure I 21 understand the statistics. You say that NU has responded to 22 75 percent of the DRs, and that you have reviewed 40 23 percent.

24 MR. SCHOPFER: Forty percent of --

25 CHAIRMAN JACKSON: Of the 75 percent. So we are ANN RILEY & ASSOCIATES, LTD.

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103 1 talking 30 percent?

2 MR. SCHOPFER: Thirty percent of the total.

3 CRAIMUW JACKSON: Of the total. Okay.

4 MR. SCHOPFER: The next slide is a graph of the 5 response, the submittal and response rate, and for the 6 people in the -- here are the copies that were handed out.

7 Unfortunately, the color section, the yellow doesn't show, 8 but it does on the screen here somewhat, and that shows the 9

fact that NU has turned up the response rate dramatically on 10 the Discrepancy Reports, as-you can see, and our evaluation 11 rate will follow this curve with aboat a two week lag to it, 12 for'us to receive the information, put it into our system 13 and put it through the review process.

14 CHAIRMAN JACKSON: So you are saying you are going 15 to be able to keep up with this, with NU's response rate 16 with about a two week lag?

17 MR. SCHOPFER: Pretty close. We have started 18 turning it up, as you can see from the blue line, and this 19 week it has gone up dramatically also. So I expect we will, 20 yes.

t 21 We expect to resolve the majority, the great 22 majority of the DRs by about the first week, or early in the 23 second week of March, that's our current plan based on NU's 24 comment t o complete the response by the end of February.

25 A summary of the closed or confirmed Discrepancy ANN RILEY & ASSOCIATES, LTD.

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104 1 Reports is provided next. Of the 211 DRs that have been 2 accepted and closed, there have been 111 confirmed DR

3 discrepancies. Forty-two were previously identified by NU 4 and 58 were considered non-discrepant after their response 5 and Sargent & Lundy's review of that response.

6 Of the 111 confirmed discrepancies, five have

{ 7 categorized as level 3 and 106 as level 4. There are also 8 four pending discrepancies and I should note that pending is ,

3- 9 that we have accepted their Corrective Action Plan, they 10 agree that it is a discrepar.cy. We have accepted their 11 plan, but there is some engineering document that we want to

~

12 see before we call it closed, an evaluation, a calculation, 13 some action that they needed to take that we want to see 3

14 that result before we close it again because the

15 significance level may be affected by the results of that.

^

16 But their Corrective Action Plan on resolving it was 17 _ satisfactory.

18 CHAIRMAN JACKSON: Can you talk about the most 19 significant of the level 3, the five level 3 confirmed 20 discrepancies?

f 21 MR. SCHOPFER: I'll talk about all eight, because 22 there three pending --

23 CHAIRMAN JACKSON: Okay.

24 MR. SCHOPFER: --

and I have some information 25 about that, or at least seven of the eight. They are in l

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105 1

various areas, and you can see on the next slide, actually, 2 how they are broken down. But those, we had one under 3 Design Control, one level 3 under Design Change Process, 4 that was basically a use of unverified information and-5 procedures, and NU accepted that and has made a procedure 6

change to make sure that they don't have the ability to use 7 unverified information in procedures. That was a level 3 8 from a procedural Design Control standpoint.

9 There were three or four calculations; four shown 10 here. One was an embedment plate that was overstressed 11 because the loads were -- certain loads were not considered.

12 There was a calculation for ventilation in the pump house 13 for the service water pumps that did not consider two-pump 14 operation. That one is actually in the pending category and 15 they're doing that calculation to see that it would or would 16 not have been more significant.

17 I

There was a calculation on auxiliary building 18 ventilation system filter unit bypass leakage calculation 19 that did not consider everything that it needed to consider.

20 There was two in the corrective action areas that 21 there we judged their corrective action not adequate, 22 meaning that they're on different issues, but their 23 corrective action process was not complete or not adequate.

24 One issue dealt with control-of vendor information used in 25 procedures, and the other was the environmental ANN RILEY & ASSOCIATES, LTD.

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106 1 qualification of terminal blocks.

2 And the one that shows up as component data on the 3 next slide was an auxiliary building ventilation fan 4 basically not meeting its design and licensing equipment .

5 requirements for vibration design.

6 Those are at least I believe seven of the eight 7 that we've identified as Level 3s.

8 The slide that shows the again confirmed and ,

9 pending DRs that should add up to the 215 are distributed 10 across various configuration control processes and products 11 as we've identified here and categorized them at the 12 beginning of the job.

13 The notable trends here are that the number of t

14 discrepancies in calculations, there have been minor drawing 15 errors, and I'm looking more at the -- we've talked about 16 the Level 3s. I'm talking more to the numbers of Level 4 17 discrepancy reports on calculation issues, drawing errors --

18 minor drawing errors -- differences between the design and i

19- as-built configuration, which is categorized or called i

20 installation implementation. Licensing documents would be 21 FSAR inconsiatencies, handling of corrective actions, and i 22 components not in compliance with their design specification .

23 or their licensing commitment. That's the type of what 24 these have shown for the confirmed DR so far.

25 And the last slide I have is the preliminary ANN RILEY & ASSOCIATES, LTD.

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107 1 conclusions slide that you mentioned earlier. Based on --

2 and I've termed this preliminary conclusions because we in 1

! 3 fact have looked at about a third of the -- or a little 4 less, perhaps -- of the responses, and conclusions really 5 won't be-drawn until we've completed that DR resolution 6 process, but that based on the numbers of findings that have 7 remained Level 3 are determined to be significant to Level 8 3, we have a preliminary conclusion that the effectiveness 9 of their CMP was relatively good in determining design and 10 license basis deficiencies because of the minimum number of 11 those things that we have found baced on the total number of 12 things that we've in fact looked at.

13 The conclusions about conffguration management 14 going forward, we have reviewed their design control manual 15 and we think it will be able to provide configuration 16 control in the future. -There are some aspects of their 17 modification process that we have discussed with NU and the 18 NRC that could be improved, but they have not resulted in 19 issues that were unacceptable, that are improvements or 20 enhancements to their process.

21 Programmatic issues that have jumped out at us are 22 calculation control, and we've discussed these issues again 23 with both the NRC and NU. They have a -- and they have 24 programs in place to deal with that, but we found it very 25 difficult to deal with the calculations, what is the ANN RILEY & ASSOCIATES, LTD.

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l 108 1 calculation of record for a particular system and aspect of 2- a system, what -- which calculations used as input to others 3 and superseding of calculations that may have been used as 4 input. So there are a number of issues like that related to 5 calculation control.

6 And we also found some issues in general with 7 radiological calculations that were not of the same quality 8 and control of the calculations as the other calculations ,  ;

9 done recently on site. The radiological calculations are a 10 little bit more difficult to deal with. They have not shown 11 as good of conformance to the licensing basis. So those are 12 two'of the issues that again we have discussed with NU and 13 the NRC.

14 CHAIRMAN JACKSON: Thank you.

15 MR, CURRY: Good morning, Chairman Jackson.

-16 CHAIRMAN JACKSON: Good morning.

17 MR, CURRY: My name's Stan Curry, and I'm the 18 project director for the Unit 2 ICAVP, and with me today is

.19 Eric Blocher, my deputy. I'm very pleased for this 20 opportunity to talk about Unit 2.

21 As you see from the agenda, we'll get -- on the <

22 third bullet there we'll get down to discrepancy reports, ,

23 and I'd like to cover those issues that have been previously 24 mentioned at that point.

25 Our Tier 1 review is continuing as similar with ANN RILEY & ASSOCIATES, LTD.

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109 i Sargent Lundy, we have four major systems have been selected 2 which also encompass significant numbers of additional 3 systems which are touched as interfaces or as major 4

components that have been added to define a single system.

5 Our high-pressure safety ejection, today we have 6 finished our discovery in following on with the definition 7 given previously. That means that ve've finished our 8 discovery. We're finalizing the discrepancy reports to 9 submit on that particular system. And then the corrective 10 action review is indeed ongoing in that particular area, 11 The auxiliary feed water system is on hold as 12 we've indicated there, and we expect based upon NU's 13 information to start receiving some information to allow us 14 to restart our efforts in that particular area in the 15 mid-March time frame.

16 CHAIRMAN JACKSON: Now there were changes made to 17 that system. Is that the --

18 MR. CURRY: There were additional calculations 19 that needed to be redone. In order to establish the design

.20 and licensing basis and to make it efficient for our reviews 21 it did not seem prudent to proceed until those were 22 complete.

23 On the two other Tier 1 systems we are proceeding 24 in the design and licensing basis. As indicated there our 25 work is in progress and we're going through the normal AUN RILEY & ASSOCIATES, LTD.

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110 1 process of a Tier 1 inspection on those two systems.

2 Our Tier 2, which again is the accident analysis 3 review, we've gotten our critical design characteristics ,

4 approved. The 29 events are in review. As you notice, the 5 major bullet there that we will reevaluate the ten events 6 that Northeast Utilities is currently working on to ,

7 reanalyze. We have a process that will allow u's to work 8 around those for a period of time. Those other analyses are ,

9 not affected by the reanalysis work.

10 L i then we have a process which allows us to take 11 placeholders but will require us to come back and validate 12 once they have completed their calculations on Tier 2, 13 Our Tier 3 proceeds. There is the one outstanding 14 area of vendor manuals as far as the selection of the sample 15 that we will be reviewing. The other is progressing well 16 and we're 75 percent complete with that tier.

17 Discrepancy reports. Just to review what's 18 currently on the slide before I proceed for some other 19 comments. As you see, similar in definition, 57 discrepancy 20 reports are closed, are confirmed pending, and of the 39 21 that have been confirmed as discrepancies, and again those 22 are in.a manner that we have agreed with the licensee on the ,

23 particular issue and the action that will be taken. Closed 24 indicates that we have seen their final piece of paper that 25 would allow us to agree, and if they've not yet implener :ed ANN RILEY & ASSOCIATES, LTD.

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111 1 it, we would close it, and it would move to the corrective

2 action portion of our review.

3 To follow up on the earlier questions that have to 4 do with the elevated discrepancy reports. Mr. Bowling has 5 already made a remark about the actual number that we 6 received, and I'd like to discuss a little bit the process 7 we've developed to utilize on what we call elevated DRs,

-8 anything that are in Category 3, 2, or 1 in particular, with 9 specific emphasis on is and 2s.

10 And as you can imagine, most of these are not just 11 open a book and find the issue. These were fairly complex 12 isodes. And because of that we and the licensee and the 13 staff and the State of Connecticut have developed a process 14 by which we sit down and discuss any one of these to make 15 sure that everyone understands what those issues are.

16 This process was not in place before we issued the 17 initial elevated DRs. We are now using those. And to 18 the -- I think to the credit of the licensee they're 19 bringing significant amounts of staff to those meetings to 20 make sure that they understand those issues before they 21 begin to respond.

22 Again, these issues in many cases are driven out 23 of the accident analysis reviews rather than simply the 24 systems that they have across the plant implication, so it's 25 not just a single system issue. And I have seen from them a 7dai RILEY & ASSOCIATES, LTD.

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l 112 1-very sincere desire to understand and make sure that we 2

fully appreciate what their response will be and why we can 3 accept that response.

4 In many cases again as we've discussed in the past 5

there are -- this is an older plant, and sometimes you reach 6

the point where the data provided does point you to an 7 elevated definition or would be met, and then further .

8 research may turn up additional information which may allow ,

9 all parties to agree that indeed the situation is 10 nondiscrepant. And clearly that's some of the things that 11 we're seeing coming out of those.

~

12 CHAIRMAN JACKSON: Do you have the comparable 13 default position in terms of --

14 MR. CURRY: We do, but I should tell you, I mean, 15 we certainly do, and I think Mr. Schopfer adequately

! 16 discussed that. When it's indeterminate, we indeed send it 17 back to them and indicate at this point without us redoing 18 calculations and that's not part of our scope. It is 19 indeterminate what's the exact level, but we believe it is 20 as a minimum of three.

21 .

Now again sometimes the information provided does 22 meet the criteria to identify it at that time as a potential .

23 Level 1 or Level 2. As I've mentioned, sometimes that 24 potential goes away when more information is provided. But 25 you deal with the information that you have-at the time when ANN RILEY & ASSOCIATES, LTD.

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113 1 the licensee provides all informatior that he thinks he has 2 to address that issue. As we've seen in the past, there was 3 one particular item that we were unaware and did not receive 4 an LER from the licensee. Upon receipt of tilat LER, that 5 starts helping us understand where they are on that <

6 particular -- resolution on that particular item.

[ 7 These meetings have resulted on the elevated DRs 8 and they have taken the opportunity to go back and, on three 4

9 of those particular items, do a further evaluation and they 10 will be shortly getting back to us as far as what they have 11 seen to evaluate the potential, whether or not there is a 12 problem or not.

i 13 Again, I would like to emphasize that they have 14 shown significant commitment to me as far as making sure t-15 they were bringing the right people to the table. There has t

16 been no lack of their dedication in that area.

17 Were there other questions about DRs that -- our 18 schedule, as we show here, we have coordinated these dates 19 with the staff to make sure that, as we currently have 20 indicated here, that they will support the staff'r 21 inspection of our work on both Tier 2 and Tier 3 as well as 22 in Tier 1 and the corrective action review.

23 CHAIRMAN JACKSON: So given the date you have for 24 the HPSE, does the high-pressure safety injection system 25 meets its design and licensing basis?

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114 a

1 MR. CURRY: At this point, our discovery is 2 complete. We obviously have several outstanding DRs related l 3 to that system, and you have to wait until you get those 4 answers. -

5 Okay.

CHAIRMAN JACKSON: So you're waiting fsr 6- what?

~

7 MR. CURRY: We have several outstanding i

8 -discrepancy reports on-HPSE and also on the corrective 9 actions to be performed on HPSE, and there's a significant 10 number of corrective actions the licensee has identified 11 that they will be performing.

12 CHAIRMAN JACKSON: Okay. So this feedback process 13 and the re-review has not been done.

14 MR. CURRY: That's correct, yes, not yet been 15 done, 16 Our current target, based upon our current 17 knowledge of what we're doing and certainly the Northeast 18 Utility's current schedule, providing us the information 19 that I discussed earlier, some of the design basis 20 calculations and the accident analysis, based upon those 21 schedules and a process, a normal proceeding of resolutions 22 for discrepancy reports and corrective actions, we look to 23 have a July the 10th date for our final report.

24 CHAIRMAN JACKSON: Okay.

25 Any questions? Yes?

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115 1 COMMISSIONER McGAFFIGAN: The Level l's that you 2 tentatively identified, five Level l's, what is the nature 3 of some of them? Apparently NU has responded on three of 4

them, and you're presumably looking at their response, but 5

what is the nature of some of these Level l's?

6 MR, CURRY: Eric, would you like to characterize 7 those for me?

8 MR. BLOCHER:

l9 Right. The elevated DRs that exist 9 to date, one of the Level l's deals with water intrusion 10 into the diesel fuel storage tank that would render both 11 trains inoperable.

There is another Level 1 DR that deals 12 with the RC flow, RPS trip set point being in a 13 non-conservative direction and certainly would violate or 14 potentially violate a fuel integrity limit.

15

) There is an issue dealing with enclosure building 16 integrity, both from a pressurization,and overall leakage 17 point of view.

18 The fourth one deals with steam generator narrow 19 range level trips point dealing with potential cause of 20 drawing inconsistency resulting in an over-leak, 21 under-conservative trip set point.

22

. Then there is the fifth Level 1 DR deals with the 23 containment sump valves, potential vulnerability to pressure 24 binding and pressure locking, therefore rendering them 25 inoperable.

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116 ,

1 Our one Level 2 DR deals with accumulator tank, an 2 air supply that provides backup air to safety injection 3 discharge valves, and the mounting of that accumulator tank 4 is in question.

5 MR. CURRY: I again would say that, again, those 6 are potential DRs at this point.

7 CHAIRMAN JACKSON: Anything else? h 8 Thank you very much.

9 We'll now hear from Little Harbor Consultants.

10 Let me see if my Commissioners would like a break.

11 No? Keep going?

~

12 ' Pause.]

13 C..:/;. iAAN JACKSON : Good morning.

14 MR. BECK: Good afternoon.

15 CHAIRMAN JACKSON: It is afternoon. It was 16 morning when we started.

17 MR. BECK: I'm John Beck, president of Little 18 Harbor and team leader of the independent third-party 19 oversight program at Millstone, and I have with me this 20 morning -- this afternoon John Griffin, who is a deputy team leader, and Billie Garde, a member of our oversight team.

21 22 Our presentation today will be very similar to 23 that we gave in December. Since then, we have presented an 24 interim report to Northeast Utilities and the NRC staff in a 25 public meeting on January 27 at Millstone. Today's ANN RILEY & ASSOCIATES, LTD.

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117 1

evaluation of NU's success criteria was conducted earlier 2 this week and is thus very current and re; ssents the 3 consensus opinion of the LHC team.

4 Before we report on the NU success criteria, I 5 would like to briefly discuss the evaluation system we use 6 to measure each of our safety-conscious work environment 7 attributes. While our evaluation system which we discussed 3 in December remains the same, we have modified this 9 particular slide to more clearly define our criteria.

10 Specifically, we have indicated that a green evaluation 11 means world-class performance. Previously this was labelled 12 " meets expectations" and left unsaid that the expectations 13 referred to were meant to represent ideal performance or 14 world-class performance.

15 CHAIRMAN JACKSON: This is not a re-normalization 16 MR. BECK: It is not a re-normalization.

17 We have also added a line to show, as we discussed 18 in December, what level of performance we consider to be 19 acceptable for restart. These changes, as well as the 20 addition of positive and negative factors which I will get 21 to in a moment, were made based on feedback we received from 22 members of the public following the December meeting.

23 Our oversight plan defines twelve attributes of 24 the safety-conscicus work environment, and we have mapped 25 these twelve attributes into the four success criteria ANN RILEY & ASSOCIATES, LTD.

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_a

1 118 1 utilized by Northeast Utilities to measure the 2 safety-conscious work environment. We evaluate each of our 3 twelve attributes, discuss the f acts gat' ared and observed 4 in our work, and then strive to reach a team consensus on 5 the evaluation for each of those attributes.

6 CHAIRFDJJ JACKSON: And do each of those attributes all have to be above the line individually in order for you 7

8 to make an acceptable determination?

9 MR. BECK: For all practical purposes, I would say 10 yes, although there could be an exception. I don't believe 11 there is at this time, and certainly we would point it out

~

12 and justify why, if it didn't quite meet the line, that 13 would be the case. But I don't believe it is as we stand 14 here today.

15 CHAIRMAN JACKSON: So I want you to, again, to 16 state for the record, when you said earlier it meets 17 expectations, you were saying implicit in that was meets 18 world-class expectations, so it's not a re-normalization?

19 MR. BECK: For the green rating, that's correct, 20 it is not a re-normalization.

21 Within roll-up, our twelve attributes into the 22 four NU --

23 CRAIRMAN JACKSON: Excuse me.

24 COMMISSIONER DICUS: On this slide in question, 25 what would yellow declining mean? Put the slide back up a ANF RILEY & ASSOCIATES, LTD.

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119 1 minute. You've got these different categories and you show 2

whether it's improving or declining, but what if you had a 3 yellow declining? Is that the same thing as yellow 4 negative?

5 MR. BECK: No. If it were a middle yellow or a 6

neutral yellow declining, that would not meet our acceptance 7

criteria for restart of the unit.

8 COMMISSIONER DICUS: Okay, 9 MR. BECK: It has to be at least neutral yellow 10 holding steady. If it were declining, that would not meet 11 our criteria.

12 CHAIRMAN JACKSON: So minus means it's declining 13 and plus means it's improving?

14 MR. BECK: No. The arrow indicates improving, 15 steady, or declining 16 CHAIRMAN JACKSON: Did you get the answer to your 17 question? Okay.

18 COMMISSIONER DICUS: Close enough.

19 CRAIRMAN JACKSON: Okay.

20 MR. BECK: We're trying to keep a very close 21 finger on the pulse.

22 We then roll the --

23 , CHAIRMAN JACKSON: Let me back you up --

24 MR. BECK: Sure.

25 CHAIRMAN JACKSON: -- since you're showing I

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- - --= -._ . ..

120 1 performance indicators.

2 MR. BECK: Yes.

3 CHAIRMAN JACKSON: What does plus mean relative to 4 the arrows at the bottom of the page? What do plus and 5 minus mean?

6 MR. BECK: Plus -- the absence of a plus or minus 7 or the middle yellow and the minus yellow are three 8 gradations in that yellow range, plus, neutral or minus.

9 The arrows indicate a trend --

10 CHAIRMAN JACKSON: I see. Okay.

11 MR. BECK: -- at that gradation level.

12 COMMISSIONER McGAFFIGAN: Where is yellow minus 13 improving? Yellow minus with an up arrow, is that above or 14 below the line?

15 MR. BECK: Below.

16 COMMISSIONER McGAFFIGAN: It's below. Okay.

17 MR. BECK: You could look at it, although we try 18 to stay away from it, as A, B, C, D and F.

19 As stated earlier, the information we're about to 20 present-was developed by Little Harbor in meetings held 21 earlier this week and represents our consensus.

22 The first of the success criteria is to

-23 demonstrate a willingness to raise concerns. We have 24 evaluated this criterion as neutral, yellow and improving, 25 or an up arrow. We consider this criterien to be acceptable IJN RILEY & ASSOCIATES, LTD.

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121 1 for restart and it represents an improvement from our last 2 evaluation.

3 This slide shows the five Little Harbor attributes 4 which will appear as Slide 29 in your handout package, which 5 roll up into the first of these NU success criteria. And 6 you can see by examining those five attributes, each of them 7

would meet the acceptance criteria at this point, if you 8 looked at them on an individual basis.

9 This next slide lists the factors that we 10 considered in our evaluation. For example, the event that 11 occurred in January in Unit 3, mechanical maintenance, the 12 sec6nd bullet in the left hand column, made both the 13 positive and the negative lists. It was-negative because of 14 the perceptions about the event.

15 CHAIRMAN JACKSON: Why don't you give us a quick 16 summary?

-17 MR. BECK: Sure. In this particular case, a 18 change in a manager's assignment was being made, and it was 19 reacted to very vigorously by the people who were 20 responsible to this individual, and by others in the 21 maintenance department, as they felt that it was an 22 inappropriate thing to be done. They had a lot of trust in 23 this individual and they, frankly, did not want to see him 24 reassigned to other duties.

25 The action was taken on New Year's Eve day and it ANN RILEY & ASSOCIATES, LTD.

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122 1 was quite a strong reaction on the part of the individuals 2 affected by it, and the potential existed for a chilling 3 effect. But --

and those certainly were negative aspects of 4 it.

5 On the positive side of the equation was the fe.ct 6 that the employees involved and affected by it were willing 7 to stand up and question the decision by management which 8 they believed was wrong for the company. Management's ,

9 reaction to that challenge was relatively swift, and by the 10 end of the first week in January, the decision to reassign 11 this individual was reversed. A new understanding was 12 reached about the standards expected by people in the 13 maintenance department by all, management and the employees, 14 and it had, frankly, a very rapid and happy ending.

15 Moving on to the second criterion, and this is to 16 demonstrate that issues are being effectively resolved by 17 line management.

18 CHAIRMAN JACKSON: Excuse me, what is the ERB 19 review process?

20 MR. BECK: Executive Review Board is a board the 21 company has set up to review any potentially adverse 22 personnel action being taken at the Millstone site, whether 23 it be an-employee or a contractor. It is at a high level 24 and it considers all aspects of potential adverse employee 25 or contractor personnel actions and is intended as a final, ANN RILEY & ASSOCIATES, LTD.

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123

[ 1 high level review, and they have been catching a number of 2 circumstances that might have not been properly handled.

3 It has also been, not only is a catch for these 4 things, but it has had, I think, an effective --

5 effectiveness in precluding things that might have happened 6 in another day. It is serving its purpose.

7 The second criterion is to demonstrate that issues 8 are being effectively resolved by line management, and this 9 corresponds to the Corrective Action Program at Millstone.

10 We have evaluated this criterion as neutral, yellow and 11 improving. This evaluation shows an improvement since our 12 December meeting, and we find the criterion to be acceotable f

13 for restart, as we did in December, and it corresponds to 14 our Attribute No. 10.

15 We will begin next week a detailed review of the 16 effectiveness of the Corrective Action Program. Our review 17 so far has been more of a programmatic nature. Do they have 18 all the essential elements that you would expect to see in a 19 Corrective Action Program?

20 Criterion 3 is to demonstrate that the Employee 21 Concerns Program is effective. Our evaluation of this 22 criterion has also improved from December. You may recall 23-in December we evaluated this criterion to be unacceptable 14 for restart, based on seemingly high levels of 25 dissatisfaction by users of the Employee Concerns Program.

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124 1 Since that time we have interviewed over 30 2 employees who have recently used the program and determined 3 that 83 percent of those interviewed would use the ECP again 4 should the need arise. These results compare favorably with 5 evaluations conducted independently by Northeast.

6 Our current evaluation is neutral, yellow and 7 improving, which we find to be acceptable for restart. We

~

3 8 will be conducting additi-mal reviews of recent Employee ,

9 Concerns Program activity c Sr the next few weeks to 10 determine the effectiveness of Corrective Actions which are 11 intended to address and resolve the negative factors on this 12 slide.

[_ 13 CHAIRMAN JACKSON: Do you -- if you interview 14 employees who have used the Employee Concerns Program, and 15 you have asked them if they would use it again, do you ask 16 them if -- is that the question they are asked, or are they 17 asked if they felt the issue they raised was satisfactorily 18 resolved?

19 MR. BECK: The specific question that we developed 20 for this contained about 10 or 11 questions, if I recall.

21 We asked them to characterize the concern and then walked 22 them through the entire process from the day they walked in .

23 to the Employee Concerns. How were you treated? Did the 24 intake person understand your concern? All the way down to, 25 Where you satisfied with the resolution? How were you ANN RILEY & ASSOCIATES, LTD.

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125 1 treated during the process? Et cetera. So we got a pretty 2 comprehensive review.

3 COMMISSIONER DICUS: You said this was done by 4 survey?

5 MR. BECK: No , this was done by individual 6 contact.

7 COMMISSIONER DICUS: Individual.

8 MR. BECK:

9 We contacted in excess of 30 people 9 that had recently used the program.

10 COMMISSIONER DICUS: Okay, 11 MR. BECK: And talked to them directly.

12 COMMISSIONER DICUS: So it is 83 percent of?

13 MR. BECK: I don't -- we were struggling this 14 morning to remember the exact number. It was over 30, I 15 just don't recall the exact number, 16 COMMISSIONER DICUS: Out of how many-potential 17 people did you have,to intervrew?

18 MS. GARDE: When we first did the survey -- I do 19 not mean survey instrument. When we first called people, 20 that covered over a hundred files, which were the older 21 files that we had looked at, files that were open when we 22 first arrived, and then began to be developed. This group 4

23 -would come out of about 60. -

24 COMMISSIONER DICUS: Okay. But -- all right.

25 Because you are showing a change in the trend, and I am F

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126 1 trying to figure out where that came from.

2 MS. GARDE: It is from a different group of 3 people, so that the last group that we called were from 4 people who had open concerns within, I think since --

5 MR. BECK: Six months.

6 MS. GARDE: Yeah, within the last six months.

7 COMMISSIONER DICUS: Okay.

8 MS. GARDE: May.

9 CHAIRMAN JACKSON: Did you go back at all to the 10 earlier group?

I 11 MS. GARDE: In the second batch. If their case

~

12 was closed during the new time period, yes, they would have 13 been within that second group.

14 MR. EECK: The final NU success criterion is *he 15 ability of management to recognize and effectively deal with 16 alleged instances of harassment, intimidation, retaliation 17 or discrimination, including potential chilling effect on 18 the Millstone work force.

19 in December we evaluated this criterion as a 20 significant weakness, red, and unacceptable for restart.

21 Our current evaluation still classifies this criterion as a 22 significant weakness and unacceptable for restart.

23 Since December, we have seen some improvement in 24 this area and have indicated this improvement by an up 25 arrow. We believe that this issue continues to be the most ANN RILEY & ASSOCIATES, LTD.

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127 1

significant challenge for Northeast relating to the safety 2 conscious work environment.

3 The next slide shows --

4 CHAIRMAN JACKSON: Before you go to the next 5 slide.

6 MR. BECK: Yes.

7 CHAIRMAN JACKSON: What do you mean when you say 8 inconsistent handling of HIR&D allegations and 50.7 9 analysis?

10 MS. GARDE: I completed a review of all of the 11 files that raised a potential 10 CFR 50.7 issue up through r

12 the'first week of December, and what I found within those 13 files was somewhat varied approaches by the different 14 investigators that were handling the cases in terms of what 15 they -- how they individually approached a particular 16 allegation of retaliation. And that was one of our findings 17 in our last presentation, and I believe the ECP is working 18 on trying to bring some consistency so that any file and any 19 investigator will work to *he same criteria in reaching 20 determinations in that area.

21 CHAIRMAN JACKSON: Does guidance exist for them?

22 MS. GARDE: There's not written guidance now, but 23 I hope that there soon will be.

24 CHAIRMAN JACKSON: So there's no written guidance 25 fcr the investigators?

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120 1 MS. GARDE: No There are very detailed 2 procedures, but within those procedure, there is not a 3 written guidance that sets out how retaliation is to be 4 investigated.

, 5 CRAIRMAN JACKSON: And what about training for the 6 investigators?

7 MS. GARDE: They are going to get training in that 8 area. They have already received quite a bit of training in S 9 other areas. This training has to be further developed.

10 CHAIRMAN JACKSON: Okay.

11 MR. BECK: The next slide shows the five Little 12 Harbor attributes which roll up into the Northeast Utilities 13 criterion.

14 a f s I just mentioned, we have seen some improvement 15 in the criterion. If we could have the next slide? And 16 this one represents some of the positive factors and events.

17 The executive review board, which we discussed a few minutea 18 ago, has been especin11y effective in preventing events from 19 occurring, and in recent weeks, Northeast has made 20 significant progress toward resolving several longstanding 21 issues of concern with the Quality Control Department. '

22 On the nuxt slide, however,-you will see that 23 there continue to be negative high profile events and 24 untimely resolution of some incidents. We have been 25 follouing closely management's handling of the recent event ANN RILEY & ASSOCIATES, LTD.

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f 129 ,

t 1 and oversight, noting both positives and negatives. Our  !

i l 2 next report will contain conclusions about this ongoing l

]

3 matter. Bottom-line composite of these factors result in 4 our judgment that considerable effort is still required in -

! 5 this area.

l 6 CilAIRMAN JACKSON: Tell me about this management

!' 7 oversight relationship. This is -- what are the problem 8 -areas? i i

9 MR. BECK: This springs from a relationship 10 between maintenance and the quality control inspectors that 11 dates back a couple of -- three months at this point. and '

! 12 it's an issue that frankly festered for some time until it i

13 received more management attention. I think it is -

1

{ 14 definitely on a trend of improvement at this juncture, but i

)

4 15 it does represent a significant area for improvement.

1 16 Billie, you might want to add to that.

1 l 17 MS. GARDE: I think that there was a lack of i

18 understanding between the maintenance organization and the 19 quality control-quality assurance department that led to 20 some interdepartmental behaviors that we wouldn't expect to 21 see at a site la a restart mode. I think, frankly, the 22 maintenance event that John referred to earlier probably 23 brought some of those things to the forefront and is one of 24 the areas that they have been addressing more recently and 25 more aggressively.

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130 1 CHAIRMAN JACY, SON: Do you cystematically go back 2 and check or monitor the progress? v or instance, when you 3 were talking about the HIR&D and W . indicated that there 4 wasn't the kind of guidance that there needed to be, you go 5 back to see if, in fact, that has happened or that it's 6 scheduled to happened? I mean, how --

7 MR. BECK: Yes.

8 CHAIRMAN JACKSON: You do a systematic backtrack?

9 MR. DECK: Yes. We have a -- we have developed a 10 matrix of all recommendations that we've provided to date 11 and we status each of those recommendations periodically.

12 CHAIRMAN JACKSON: Okay. Very good.

13 MR. BECK: John would like to respond to a 14 question you raised earlier with Northeast, Chairman 15 Jackson.

16 MR. GRIFFIN: As I understand, the question was 17 whether Little Harbor periodically samples the data that

, 18 leads into their performance indicators. The short answer 19 is yes, we do. We either independently. verify the data 20 itself or we conduct independent data collection to verify 21 or validate that information. With probably two exceptions .

22 on the corrective action program, as John indicated, we had 23 -- well, we _ had looked at that program in the f a13, we have 24 not looked at it over the last several months, so we haven't 25 looked at the most recent data. We will begin a ANN R1 LEY--& ASSOCIATES,-LTD.

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131 1 reevaluation on Monday and we will sample that data at that 2 time.

3 The other variance from our agreement with their 4

performance indicators would be in the area pertaining to 5 the fourth performance criteria of the HIR&D, and as I think 6 Mr. Amerine had indicated, there are ongoing discussions 7

over the classification of concerns that fall into the llIR&D 8 area and into those that fall to the potential 50.7 9 violations. We're still discussing those.

10 CilAIRMAN JACKSON: Why don't you go on.

11 MR. DECK: That's it. That concludes our 12 presentation this morning. We did not intend to go through 13 each of the LHC attributes. If there are no further 14 questions --

15 CilAIRMAN JACKSON: Actually, I do have a few. Let 16 me look at the safety-conscious work environment attribute 17 status. Now, the licensee actually performs six-month 18 surveys. Do your independent surveys indicate similar 19 things, and how extensive are your surveys?

20 MR. BECK: If you recall, we did an extensive

~'

21 structured interview session last June and July, 22 CllAIRMAN JACKSON: Right.

2? MR. BECK: We are going to finish tomorrow 24 interviewing 298, I believe, individuals at the site who 25 have been selected to be representative of the site i

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132 1 population and asking them the same questions that were 2 asked last summer, so we'll have another data point 3 available. Those results will be compiled next week and our

! 4 presentation prepared, and it will be given March 3rd at the 5 Millstone site in a public meeting to NU management and the 6 NRC staff. The results will speak for themselves. I 7 haven't done the evaluation yet, so I have no predictions to .

8 make.

9 CHAIRMAN JACKSON: Let me look at attribute 3 --

10 MR. BECK: Sure.

11 CHAIRMAN JACKSON: -- having to de with senior 12 management providing training to all managers and 13 supervisors, et cetera.

14 Has hittle Harbor commented on the adequacy of 15 this training?

16 MS, GARDE: Yes, Chairman. First, we commented on 17 the inadequacy of the training that they had in place when 18 we first arrived and they made a number of changes within 19 their ongoing training programs, additional pieces that they 20 put into their programs.

21 They also added -- actually specifically developed 22 and presented in the late fall -- training to all their 23 supervisers and managers on 10CFR 50.7, what that means, how 24 to comply with it, how it's implemented. That training 25 covered three different training programs, so there were

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133 1 actually three different sessions that people attended.

2 They have also had a number of sessions off site with all 3

their mid-level managers that included training in that 4 area. So we have watched it, we have observed-it, and it 5 has been continual since I would say early fall.

6 CRAIRMAN JACKSON: How, if I look at attribute 4, l* 7 and that's the slide you have where you talk about negative r 3ectors, you seem to be primarily event driven. Do you have 9

bthur ways that you arrive at the conclusions that you 10 reach?

11 MR. BECK: Yes. Structured interview specifically 12 probes that area, and there will be results available March 13 3rd on that subject that will add to our specific 14 event-driven observations.

15 CHAIRMAN JACKSON: And that -- but in arriving at 16 this yellow steady, at the moment, that is event based?

17 MR. BECK: That's correct. That's right.

18 CHAIRMAN JACKSON: Okay. So it could go up if the 19 survey is different?

20 MR. BECK: T)Tt will certainly have an impact in 21 this area.

22 CHAIRMAN JACKSON: Okay.

. You mentioned and we had 23 talked earlier about the maintenance and oversight 24 relationship.

25 MR. BECK: Yes.

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134 1 CHAIRMAN JACKSON: Does any other group have 2 interface problems with oversight? Have you looked at that 3 MR. BECK: We certainly looked at it, and right 4 now, I can't --

I don't recall any -- remember any issues 5 that would rise to the level of the oversight QC maintenance 6 issue, no.

7 CHAIRMAN JACKSON: Have you looked at it in a 8 systematic way?

9 MS. GARDE: We haven't looked at it in a 10 systematic way other than when we're looking at the problem 11 areas, the identified problem areas, which looks at why you 12 havd a problem area. Other than that, it should come out in 13 the context of the structured interviews because there's 14 questions specifically designed to look at that.

15 CHAIRMAN JACKSON: Looking at Attribute 5, you 16 talk about the lack of trust. I'mean, in your view, how can 17 this best be regained, and is there an aspect, in fact, to 18 the " isolate the cynics" memo that is undergoing review, 19 that, in fact, pointed to trying to regain a team 20 atmosphere?

21 MR. BECK: There will be input from the structured 22 interviews on this whole question of lack of trust. And, 23 certainly, there are aspects of the oversight event that 24 will impact it.

25 CHAIRMAN JACKSON: But I am saying, are there ANN RILEY & ASSOCIATES, LTD.

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135 1

aspects -- are you going to be looking at what may be 2 positive as well as negative aspects of that event?

3 MR. BECK: Yes, we are. Yes, we are.

4 CRAIRMAN JACKSON: Okay. Let me look at Attribute 5 6. In your view, is this an area then where the licensee 6 has made a significant amount of progress?

7 MR. BE.'K: Yes. Absolutely. Without question.

8 CHAIRMAN JACKSON: Okay. Attribute 7, this 9 positive recognition, the catch of the day. Is this a 10 formal recognition process?

11 MR. BECK: Yes, it is.

12 CHAIRMAN JACKSON: Okay. All right. Attribute 8, 13 looking at incidents leading to allegations of HIR&D rarely 14-occur and management is timely ineffective in taking action.

15 What do you look at most strongly? Is it -- are 16 you looking at number of allegations or the effectiveness of 17 the Corrective Action primarily? I mean where do you put 18 the weight?

19 MR. BECK: The simple answer is both. It is 20 quality of the issue, or the seriousness of the issue that 21 may or may not have occurred. The frequency, is it 22 declining as-the work force and management become more

. i 23 sensitive to these very important relationships. And as far 24 as management's timely addressing of the issues, that is 25 certainly a matter of importance to us.

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136 1 Billie, do you want to?

2 MS. GARDE: I think -- I agree with what John 3 . aid, and I also would like to say something we said the 4 first time that we came here, and that is that it is S unrealistic to expect that there will never be an incident.

6 This is a human work force, it's a dynamic work force. You 7 could have a supervisor start today that didn't attend any 8 of the training,- and one of the things we want to make sure ,

~

9 is that that training is captured for new supervisors.

10 So, although we certainly would not expect to see 11 increasing incidents, there should be levels to catch it, 12 both below and above, and we are seeing that catch system 13 develop. They may happen. Incidents like this can occur.

14 And that is where you have to weigh and balance. And, 15 actually, an incident could occur that could have-a timely, 16 effective, immediate response and would only show up on our 17 plus side because of that reason. So it really is a balance 18 between-numbers and why it occurred and how it is handled.

19 CHAIRMAN JACKSON: And my last question for you is 20 on Attribute 8, where you talk about a negative factor being 21 manpower. What does this mean?

22 MS. GARDE: There was an incident involving some-23-- contract employees who -- employment was-terminated. The 24 issues that they raised a concern about were not 10 CFR 50.7 25 issues, that is, they didn't deal with nuclear safety, but ANN RILE'Y & ASSOCI ATES, - LTD.

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} 137 1 1 t!.ay did deal with personnel safety issues. They were let 2 go. The issue went to -- came to the attention of the l

3 Executive Review Board, which originally approved the 4 terminations, mainly because they believed they were going I

5 to go right back to work in another position. They were not 6

6 for-cause terminations.

7 CHAIRMAN JACKSON: Okay. So what you really mean 8 is Human Resources or personnel policy?

9 MS GARDE: It was a personnel -- no, not Human 10 Resources. Personnel safety.

11 CHAIRMAN JACKSON: Personnel safety, 12 MS. GARDE: That is the issues that they raised.

13 In any event, they were immediately put back on the payroll, 14 but it took over six weeks to really come to closure on the 15 issue in a satisfactory way. So, although the people didn t 16 lose salary, the condition festered for too long, and it 17 should have been resolved more promptly. And that grew and 18 it caused it a bigger problem than it needed to be, 19 CHAIRMAN JACKSON: Okay. Any other comments or 20 questions?

21 (No response.]

22 CHAIRMAN JACKSON: Thank you very much.

4

'3 MR. BECK: Thank you.

24 CHAIRMAN JACKSON: Last but not least. I think we 25 will take a five-minute break.

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138 1 [ Recess.)

2 MR. CALLAN: Chairman, we will be on our scheduled 3 start time, but as you have repeatedly admonished the Staff 4 that when it comes to Millstone, we should be immune to 5 schedule or-pressure, so in that spirit, we will --

6 C11 AIRMAN JACKSON:- That just shows if you tell 7 people things,-they will use it against you.

8 MR. CALLAN: That's right.

l ,

9 (Laughter.)

10 MR. CALLAN: With me at the table I have the 11 Director of the Of fice of Special Projects, Bill Travers, 12 a n d 'lu3 has with him also his three deputies; Wayne Lanning, 13 who is the Deputy Director for Inspections; Gene Imbro, who 14 is the Deputy Director for ICAVP Oversight; and Phil McKee, 15 who is the Deputy Director for Licensing and Employee 16 Concerns Program Oversight.

17 And with that, Bill Travers will be our principal 18 presenter. Bill.

19 MR. TRAVERS: Good afternoon.

20 Cou.'d I have the first slide, please? I am just 21 going to jump in.

22 The staff is continuing to carry out its oversight ,

23 responsibilities at Millstone.using the guidance listed in 24 Manual Chapter 0350, and, as you know, we used this guidance 25' to develop a Millstone Review Plan that we submitted to the IJ01 RILEY & ASSOCIATES, LTD.

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139 1

Commission in 9703 and it was within just a few months of my 2 becoming Director of the special organization.

3 We have for each Millstone Unit developed a 4

Restart Assessment Plan which documents the issues that the 5

staff has identified required resoluticn prior to coming 6 before the Commission with any restart recommendation for

!* 7 any of the units.

8 This slide sort of lays out the structure of those 9 Restart Assessment Plans. Importantly, some of the key 10 orders that have been issued to date in ICAVP and Employee 11 Concerns Program, Safety Conscious Work Environment, are 12 encompassed within this Restart Assessment Plan for the each 13 of the three units. The Restart Assessment Plan also 14 identified the specific NRC incpection reports that are 15 being used to document closure in specific issues, so it is 16 really a good template for assessing the progress that we 17 have been making in our reviews to date.

18 As I have done in previous meetings, I will 19 emphasize.a continuing commitment that I think we are 20 meeting, and that is a commitment to make this process as 21 open as we possibly can. We have coordination with the 22 public in the context of evening meetings that we hold every 23 four to six weeks. We have been holding most of the 24 technical meetings and exchanges that we have in the 25 -licensee and the contractors in the area of Millstone, and ANN RILEY & ASSOCIATES, LTD.

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140 1 we have been keeping organizations like the state chartered 2 Nuclear Energy Advisory Council apprised of the status of 3 our activities.

4 In fact, as it regards to NEAC, we have a 5 Memorandum of Understanding with them, they are actually i

6 participants as observers in many of our ICAVP activities, ,

7 .and we have recently expanded that MOU to include our 40500 '

8 Corrective Active Inspection and the Operational Safety Team ,

9 Inspection as well, if they choose to participate as 10 observers.

11 Before turning to a more detailed discussion of 12 status, I would like to make just a few comments about our 13 overall assessment of the licensee's recovery program and 14 their progress. As I indicated in December, the staff's is overall assessment is that NU is continuing to make progress 16 in its broad scope effort to fix problems at Millstone. The 17 NRC staff has been observing and documenting in NRC 18 inspection reports, licensee progress in essentially all of 19 the elements of our Restart Assessment Plans for Units 3 and 20 7. .

21 'Although we have closed and documented specific 4 22 items identified.in those Restart Assessment Plans, we have 23 not yet completed our evaluation of any of the key 24 programmatic issues that are the foundation of some of the 25 key problems at Millstone. And before we can complete our idni RILEY & ASSOCIATES, LTD.

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141 1

action in areas such as Corrective Action Program, licensing 2

design basis conformance, Employee Concerns, quality 3 assurance oversight, the licensee must determine for itself 4 that their Corrective Actions are complete and effective.

5 As such, our program is one that is necessarily back-ended 6 and several important inspections, some of which have been 7 postponed by the licensee, must be completed before we can 8 finish our review in these programmatic areas.

9 Currently, at Unit 3, of a total of eight team 10 inspections, five are complete, one is in process, and two 11 are planned. In a few minutes, I will present a detailed 12 listing and schedule of the remaining NRC staff inspections 13 related to Unit 3.

14 Fundamentally, of course, otir program is f ocused 15 on a thorough evaluation of the issues, and on no particular 16 schedule. We recognize that it is tho issues and their 17 resolution that drive our examination and closure, 18 Can I have the next slide, please?

19 An important element of our Restart Assessment 20 Plan is the evaluation of improvements to the Employee i

Concerns Program and Safety Conscious Work Environment, and 21 22 the Commission has heard a number of pieces of information 23 -relative to the status of Little Harbor's review and the 24 licensee's own appraisal of its status.

25 The staf f's plan for assessing these improvement s ANN RILEY & ASSOCIATES,-LTD.

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142 1 in these areas was provided as an attachment to our December 2 Commission paper, and that plan presents the staff's 3 methodology for determining if the licensee has made 4

sufficient improvements in their Employee Concerns Program 5 and Safety Conscious Work Environment to support a restart 6 at Millstone.

7 The plan purposely makes a distinction between '

8 Employee Concerns Program and Safety Conscious Work 9 Environment. The Employee Concerns Program refers 10 specifically to the licensee's organization and programs 11 that address concerns raised by employees outside the normal 12 line organization. Safety Conscious Work Environment is a 13 broader team and that refers to a work environment in which 14 employees are encouraged to raise concerns and 5.-here 15 concerns are promptly re-lewed and resolved, with timely 16 feedback to the originator.

17 The October 24th, 1996 Order issued by the 18 Director of NRR required Northeast to develop and submit to 19 the staff a comprehensive plan for reviewing and 20 dispositioning safety-issues raised by-its employees.

That 21 _ Order also required Northeast to propose for NRC approval an 22 independent third-party oversight program organization to 23 oversee implementation of-Northeast's plan to assess 24 licensee performance.

25 The Order further required that the third-party JJul RILEY - & ASSOCIATES, LTD.

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143 organization, once selected, develop and submit for NRC f

, 1 l

2 review and approval, an oversight plan. Currently, all of  !

j 1

3 these elements of that Order have been completed.

1 4 Consistent with the Order, Little Harbor, as you 5 know, is charged with important oversight responsibilities, 1

6 and the staff, as part of its overall conclusions regarding

- 7 the adequacy of ECP and SCHE, expects to utilize input for  !

8 LHC as a significant element in our decision making.

9 CHAIRMAN JACKSON: Do you havu your own criteria 10 against which you assess LHC's evaluations, as well as any .

11 either incidental or direct inspections that you do, or I 12 reviews that you do? <

13 MR. TRAVERS Yes, we do. I was-just about to J

14 emphasize that, in addition to our reliance, as I just 15 mentioned, on Little Harbor and its expertise and findings, i

1 16 we are carrying out rather extensive activities on our own,

17 independent of Little Harbor, but certainly related to what i

{- 18 they are doing. i 19 Those activities, Chairman, as you point out, 20 include an assessment of Little Harbor's-effectiveness,

. 21 because, obviously, in order to rely on what it is they are 22 doing, we need to come to a independent conclusion on their

23 effectiveness.

24 But what I have listed on the bottom section of

25 this Slide No. 3 is just a summary listing of the activities I

l 5

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144

{

1 that the NRC staff is carrying out in connection with these  !

2 iccues at Millstone. And they include, very briefly, ,

3 continued staff on-site monitoring of both the utility and l 4 the Little Harbor ac"'vities at Millstone.

5 They include recently completed team evaluations ,

6 of amployee Concerns Program and Safety Conscious Work 7 Environment. That team evaluation also was directed 8 directly at an assessment of Little Harbor and its "

9 effectiveness. We-are continuing right now to carry out 10 another inspection, the 40-500 that is focused on a broader 11 concept of corrective action programs. We have included an 12 additional team member to look at SCWE and ECP as it 13 directly focused in the area of corrective action. So we've 14 added a specific team member to augment that inspection team i

15 to -- sort of in recognition of the importance of having an 16 adequate corrective actions program and the effect that $

27 could have on the cafety environment and the employee 18 concerns program.

19 CHAIRMAN JACKSON: Let me just ask again, though, i 20 are your criteria in that area LHC's-criteria, or do you i 21 have additional -- any additional criteria that you --

52 MR. TRAVERS: I'm going to ask Phil to address it, i

23 but --

24 CHAIRMAN JACKSON: Okay.

25 MR. TRAVERS: We have laid out in our plan that we Idal RILEY &- ASSOCIATES, LTD.

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145 i submitted to the Commission basically our own performance 2 measures and criteria.

3 Do you want to --

1

4. MR. McGEE: l'll just add that in our plan we  !

5 identify for the most part their process and programmatic 6 issues that we're looking at, and we've done that as part of

?

our team evaluation and the activities that Bill described.

8 But also when you use that to compare that with 9 Little Harbor, but we've identified some additional measures 10 and issues that we want resolved in a status that we want to 11 see for acceptance for restart, and they do mesh with Little 12 Harbor's criteria in a way, and also the licensee's I 13 criteria.

14 And that includes items such as looking at their 15 corrective action program, and as we mentioned the 16 additional members seeing that issues raised by individuals 17 in that program are resolved, are resolved promptly, and so 18 forth. And also elements in the employee concern program 19 also, timeliness of case resolution. And when we do that, 20 we're looking at what the licensee has found, and also 21 Little Harbor's assessment in that area.

22 MR. TRAVERS: Just to talk a little bit further 23 about some of the measures we are using, in the next slide 24 _the plan that we're using specifies some of the broad 25 acceptance measures for determining whether or not adequate M m RILEY & ASSOCIATES, LTD.

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146 1 program improvements to support restart in fact have been 2 made. We've indicated an expectation really that the I 3 licensee needs to reach a judgment in this area and that  ;

4 we're as we mention relying to an extent on Little Harbor's 5 activities as well.

6 But some of the areas in looking at the adequacy 7 of the employee concerns program are listed in terms of 8 ctaffing, training qualifications, how they implement their 9 program, documentation, and so on and so forth. We have 10 much more specific things that we look at we have on a 11 backup slide, but these are sort of a broad treatment of 12 somb of the measures that we include in our program for 13 assessing these issues.

14 CRAIRMAN JACKSON: How many of these areas have 15 you measured to this point, and are there any preliminary 16 assessments or conclusions that you --

17 MR. TRAVERS: Yes, in fact there are. We've as I 18 mentioned completed team evaluations which covered both the 19 licensee's programs in both ECP and SEWE as well as Little t

20 Harbor's efrectiveness in carrying out their oversight 21 responsibilities.

22 The way we've documented the results of these team 23 evaluations to date is via a quick-look letter. A 24 quick-look letter is a letter that's public, it documents 25 the preliminary team evaluation findings. -It's transmitted ANN RILEY-& ASSOCIATES, LTD.

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147 1 to the licensee. We've provided it to your offices as well, 2

relatively recently, I must admit, but nevertheless it's up 3 there. So this is the mechanism that we use just prior to 4 dontmenting in a fouaal inspection report.

5 CHAIRMAN JACKSON: The Commissioner said 9:2F this 6 morning.

-7 MR._ TRAVERS: That's pretty recent.- -Yes.

l .

B CHAIRMAN JACKSON: Well, given that quick look, 9

why don' t you give us a quick summary of- what's -in the quick 10 look.

! 11 MR. McGEE: Okay. On the quick look we --

12 act0 ally there were two reports, and we're going to come out 13 with final reports in two areas. One would be to the 14 licensee, Northeast, describing our evaluation in those 15 areas, and one to Little Harbor _ Consultants. In_ summary are 16 looking at the licensee's programs. We looked extensively 17 at the employee concern program aspect because those 18 programs were more developed and established.

19 I think for the most part in summary we found 20 similar to what you-heard from Little Harbor Consultants' 21 summary that the activities and the efforts, how they're 22 dealing with intake of icaues, resolution of issues, and

-23 timeliness, that that process and programs and employee 24 concern program is working well and effectively.

25 And the safety conscious work _ environment, that's

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148 1 a more difficult area, and we're going to get that 2 additional piece when we are doing our follow-on on the 3 corrective action program which I personally think that's a 4 very important piece. But we did look at a number of 5 elements in that area as far as the licensee's dealing with 6 I think they term it their problem areas, organizational 7 areas where there's issues. And we had some findings and 8 issues there that will require -- I think Little Harbor .

9 mentioned a few of them -- followup and need some additional 10 attention.

11 And also looking at their training I think as you 12 heard before that the training in some of the training 13 sessions that our staff attended as part of the evaluation 14 we thought was good and effective, but we did find another 15 area as far as long-term planning, what are tb y going to do 16 in the long term, some deficiencies in that program. And I 17 believe I heard Northeast Utilities say that there are plans 18 to give a more detailed plan in that area, in the safety 19 conscious work environment.

20 But we're still out a little bit on the corrective 21 actions and how those issues evolve, because we've got some 22 ongoing activities in that area.

23 CHAIRMAN JACKSON: Commissioner McGaffigan.

24 COMMISSIONER McGAFFIGAN: On the slide that you 25 had up a moment ago, the postrestart elimination of l

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149 1 third-party oversight, which restart are you talking about?

2 Would they stay on board through 2, and if they reoperate 3 1-1 or how do you see that playing out?

4 MR. TRAVERS: Well, I put'this on to be inclusive l

5 of everything that's in the order, as.it's currently 6 written, and the order as written anticipated the need for 7 sustained _ performance and demonstration given these issues 8 are not ones that turn around overnight and are quickly 9 resolved.

10- Certainly the order as it's interpreted by us in 11 any case we've put in our plan an expectation that's for at 12 least six months after restart of at least the first unit we 13 would expect the third-party oversight organization to be in 14 place. That was a guess on our part. We had to pick a time 15 frame that might seem reasonable for that kind of sustained 16 performance to be evidenced, but the order simply specifies 17 that sufficient -- how is it put? -- the sufficient 18 performance sustained needs to be at evidence for the staff 19 to come to a' conclusion that the third-party oversight is no 20 longer required. So in a sense that's the only element of 21 the order, strictly speaking that rr); ins in the most 22 formal sense.

23 As I indicated within the RAP, within our restart 24 assessment plan, the conclusions that the staff has to reach 25 in ECP and SEWE are still at issue, and we need to come ANN RILEY & ASSOCIATES, LTD.

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150 1 before the Commission.

2 The last bullet, or the second-to-last bullet on 3 this slide is meant to capture that we inte 'o do that by 4 writing a safety evaluation report that covers both of these  :

5 issues and provide that to the Commission prior to restart.

6 And right now Unit 3 of course is the one that looks to be 7 the nearest term. .

8 CRAIRMAN JACKSON: Have you found -- Mr. McGee, 9 maybe you can answer this -- similar issues with the i 10 oversight and maintenance and oversight of other operating 11 organizations that Little Harbor spoke to?

12 MR. McGEE: We are aware -- and it's rather unique 13 for us to get -- and a lot of these involve personnel 14 actions and personnel issues and disciplinary issues, and 15 they are quite apparent when they come up at the site and 16 I'll do the sensitivity and we have -- are monitoring with i

i 17 our staff following along with -- I know Little Harbor gets 18 the same information following those activities. And there 19 are a number of those events and issues, and we are the most l 20 part in an observation role and looking at the licensee's

( 21 process for dealing with those issues. But our findings in 22 the events are consistent I think with what Little Harbor .

23 described in presenting their attributes.

24 MR. TRAVERS: Can I have the next slide, please?

25 It would be slide No. 5.

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151 1 CHAIRMAN JACKSON: So these quick-look reports art 2 publicly available?

? MR. TRAVERS: Yes, they are.

4 CHAIRMAN JACKSON: Okay. Yes.

5 MR. TRAVERS: Maybe I'll just list the fact that 6

in addition to the ones we've sent up the program 7

expectation is that for each inspection, at-least the-team-B inspections that-we complete from now-till the end of the 9

project we would expect to issue such quick-look reports so 10 that we can give more timely -- maybe even more timely than 11 9:00 o' clock at the Commission meeting -- information to 12 people who are interested in our team evaluations.

13 The next slide is meant to give you a quick 14 compilation of the things that we've completed since our is last Commission meeting in December. One item that's not on 16 the slide but the Chairman made reference to earlier is the 17 fact that we've issued a letter recently that is a demand 18 for information letter on the isolating the cynics issue 19 that requires Northeast to provide us with information on 20 their evaluation of the issue and handling of the issue and 21 whether they think any of what happened involves a siolation 22 of 50.7 requirements.

23 Other than that, we have continued to meet with 24 both the Licensee and Little Harbor periodically in public 25 meetings near Millstone. As I mentioned, we have completed

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152 1 our team evaluations and issued quick-look letters. We have 2 ongoing and continuing site monitoring of their activities, 3 both the licensee's and Little Harbor by NRC staff and 4 contractors whom we have working with us, and the 4500 5 inspection is ongoing.

6 Right now, similar to what you heard from both the 7 licensee and-from Little Harbor, the Staff's assessment of .

8 employee concerns program status is that by virtue of things ,

9 like staffing and training, numbers of people working in 10 that department, the timeliness of resolution of issues, the 11 quality of resolution of issues, th feedback to the 12 originators, we find that that program is running at an 13 acceptable level. We are going to, of course, continue to 14 monitor that situation and document it in our report to the 15 Commission, but at the current time we wanted to provide you 16 the benwfit of our thinking, that this is an acceptable 17 level of performance on the part of Northeast.

18 In the broader question of safety-conscious work 19 environment, our activities are continuing to assess that 20 and, again, similar to what you heard from both Northeast 21 and from Little Harbor, we think there is some additional 22 work that needs to be done, basically in the areas that you ,

23 have already heard about.

24 Through April, we have projected at least that we 25 would certainly continue to meet on a periodic basis to

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153 1

discuss status and monitor the situation at Millstone. We 2 expect to issue the formal team evaluation report, this 3 follow-on, the quick-look, and that we would in all 4 likelihood, depending upon whether or not the issues are 5 resolved and completed, develop the safety evaluation that 6 would document our conclusions with regard to both ECP and 7 SCWE.

8 Of course, I put through April, but this will be 9 when it will be, and it's just sort of a projection, a 10 planning tool right now for estimating when we might be 11 done.

12 Next slide, please.

13 The restart assessment plan for each of the 14 Millstone units includes our NRC significant items list 15 which identifies the individual and programmatic issues that 16 are at issue, and we are now presenting these in a fashion 17 similar to what you have already seen to make it clear, at 18 least fairly clear, where we stand relative to the total 19 issues and packages that need to be submitted.

20 NU is providing submittal packages for most of the 21 significant items list issues, and together with our 22 inspection reports -- rather, our inspection activities, our 23 review of these packages are being used to close out these 24 individual issues as we go forward. And as you can see, of 25 the total 216 packages, we have closed out 168 and are

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154 1 documenting our closure in inspection reports issued 2 periodically by the Staff.

3 We have heard today that there are six packages as 4 opposed to nine that are now remaining to be submitted.

5 That's an update. And we have under review essentially all 6 of the ones that haven't been completed.

7 CHA7RMAN JACKSON: Are there any items that are of 8 more concern than others, particularly in the categories of , ,

9 remaining to be submitted or --

10 MR. TRAVERS: I'm going to ask Mr. Lanning to 11 address a couple of them.

12 MR. LANNING: Well, there are some very critical 13 issues remaining to be addressed by the licensee. A couple 14 of more zmportant ones are the submittal packages for 15 Appendix R of vendor interface, inclusion of vendor 16 information into procedures, are two examples of key issues 17 yet to be addressed by Northeast.

18 CHAIRMAN JACKSON: Okay.

19 MR. TRAVERS: Next slide, p;3ase.

20 The ICAVP, which was required by an NRC 21 confirmatory order, is intended, of course, to confirm that 22 the NU collective actions have been effective in .

23 establishing that the units conform with their licensing and 24 design basis. The ICAVP is, in our view, an extraordinary 25 effort. In addition to the independent contractor ANN RILEY & ASSOCIATES, LTD.

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155 1 activities, the NRC staff is also carrying out a series of 2 team inspections, and four of five of those inspections have 3 now been completed at Unit 3. We have issued the formal 4 inspection reports for two of those. Again, quick-look 5 -letters are being issued for the remaining. We have 6 actually issued two quick-look letter reports for two of the

?_ inspections, and our fifth-inspection, the corrective action l

1*

8 inspection that is going to look at the corrective actions 9 resulting from findings in ICAVP space, is scheduled 10 Together with the Sargent & Lundy reviews, the 11 ICAVP effort involves a detailed evaluation in tier 1 of 15 12 of the 88 systems reviewed by NU, and additionally, in tier 13 2, and tier 3, as you have heard before, the ICAVP will 14 exanine critical design characteristics of some 20-odd other 4 15 systems. uso it's quite an encompassing review and --

16 CHAIRMAN JACKSON: How many people are we talking 17 about here?

18 MR. TRAVERS: Typically on each of the team 19 inspections, the five inspections the NRC is carrying out, 20 we have_about seven people, and the inspections --

21 CHAIRMAN JACKSON: And how long do the inspections 22 lact themselves?

23 MR. TRAVERS: Typically they are four weeks on 24 site?

25 MR. IMBRO: Four or five weeks -- yeah, four weeks ANN RILEY &-ASSOCIATES, LTD.

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156 1 on site. Two with a week off, and then back for another l

2 two.

3 MR. TRAVERS: Next slide, please.

4 The results of the completed NRC team inspections 5 are presented on the next few slides. The first inspection 6 that we completed -- and I have actually discun.?ed at 7 previous Commission meetings -- involved our imp)=centation .

8 inspection of Sargent & Lundy's performance against the ,

9 NRC-approved audit plan that Sargent & Lundy is using to 10 carry out its programs. This involved a fairly early-on NRC 11 assessment and we have had others since, and I will talk 12 aboot those in a moment, but largely this inspection 13 confirmed that Sargent & Lundy is carrying out its program 14 in accordance with that approved audit plan.

15 The first. system safety functional inspection that 16 we carried out, one of two, was completed in September, and 17 we talked to the Commission about the results of that 18 inspection last time. Basically from that inspection, which

?. 9 focused on the ECCS mode of the chemical and volume control 20 system operation at Millstone 3, we identified 16 ICAVP 21 significance level 3 issues. .

Last time when I came to the 22 Commission, I identified a potential significance level 1, a 23 fairly significant issue. Currently, based on information 24 thac -he utility has provided to us in a predecisional 25 enforcement conference, as well as information that we are ANN RILEY & ASSOCIATES, LTD.

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157 1 getting on the docket, this finding appears to be more 2 appropriately classified as a level 3 in the context of our 3 scheme f or ICAVP level s'qr ticar ve determinations.

4 Let me go on tc cno next inspecti on . The next 5 inspection that we completed in January involved the look at 6 both tier 2 and tier 3. In terms of tier 2, we are looking 7 at accident mitigation systems and again in the context of 8 tier 2, we are looking at plant change processes.

9 2his inspection had another component of 10 evaluating the performance of Sargent & Lundy, and in that 11 context, the inspection concluded again that Sargent & Lundy 12 is performing their process and program adequately to 13 support using their conclusions in our program for assessing 14 the overall conformance with the licensir; and design basis.

15 We did identify some issues, however, with Sargent 16 & Lundy. They have taken on those issues and they have 17 corrected or at least carried on some more activities in 18 response to the concerns that were raised by that inspection 19 team.

20 Again, we did identify some level 3 findings in 21 this ICAVP -- in this case, six, and we can categorize or 22 classify those further if you wish.

- 23 Laet inspection that we have completed is a tier 1 24 In-scope SSFI. This is a system by In-scope that Sargent &

25 Lundy has also examined, the RSS system.

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l

158 1 We have also looked at the emergency diesel 2 generator and the supplemental leakage collection and 3 release systrm. Again, the component here relating to S&L 4

performance, since it is an In-scope system that they looked 5 at, we looked at their performance by measuring what we 6 found against what they found, and again our conclusion is that S&L performed their program adequately 7

8 Again, though, we die icentify some issues, and ,

9 they have tahen on some additional reviews in response to 10 those issues, not just for this sy.atem, but for other 11 systems that they have reviewed in the context of their 12 ICAQP reviews. Sc it is both a specific finding and a more 13 broadly applied Correctisa Action, if you will, on the part 14 of Sargent & Lundy. -

15 Again, the six preliminary ICAVP level 3 findings 16 are identified in connection with this inspection.

17 Next slide, please.

18 Thus far, the most significant findings resulting 19 from our NRC ICAVP inspections, and, in fact, from Sargent &

20 Lundy's activities, as well, are at level 3. Although we 21 are not -- although we are still in the process, really, of 22 finalizing a number of these findings, and we have not yet ,

23 initiated the ICAVP Corrective Action Inspection, the 24 results today indicate that the licensee CMP, while not 25 perfect, has generally been effective in establishing ANN RILEY & ASSOCIATES, LTD.

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159 1 conformance with the Unit 3 licensing and design basis.

2 In order to reach a final determination on this, 3

of course, we are going to need to complete the program.

i 4

You have heard that only about 30 percent, or 20 percent, l 5

depending on how you count the items being identified by 6 Sargent & Lundy, have been run through the process. But I 7 did want to give you an indication, based on where we think 8 we are today, both from a standpoint of our assessment of 9 what is coming out of the Sargent & Lundy review, and our 10 own NRC team inspections, as to where we are at relative to 11 this issue.

12 We are not at end game, but, by virtue of the lack 13 of significance of the issues, we don't -- we think that, 14 and, importantly, the review that we will ultimately 15 complete on the Corrective Actions that need to take place, 16 we think hat today, at least, the findings suggest 17 reasonable conformance with the licensing and design basis.

18 In that mode, and an important element of our 19 level 3 findings, in addition to assessing the significance 20 of each finding, is our independent evaluation of the 21 licensee's Corrective Actions. For all level 3 findings, 22 the process we are using to determine whether or not to 23 expand the ICAVP scope is focused on our assessment of the 24 Corrective Action adequacy, both na rowly and more broadly, 25 and on our assessment of any trends in these findings.

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160 1 In effect, the licensee's Corrective Actions 2 associated with ICAVP level 3 findings are resulting in an 3 augmentation to the licensee's original CMP program, and to 4 our own reviews of what they are doing. The process we are 5 using would result in an additional ICAVP review if our 6 independent evaluation determines that the licensee's 7 Corrective Actions are inadequate. .

8 To date, we have not identified negative trends in ,

9 our inspection findings, but we have only begun our 10 assessment of Corrective Actions. So, again, we must 11 substantially complete the program before reaching a final 12 conclusion on the effectiveness of the licensee's efforts.

13 The last bullet on this slide is meant to indicate 14 that we have recently provided additional information on the 15 process we are using to make judgments about ICAVP scope 16 exnansion or not. There is a lot of merit in doing that.

17 We have documented that further in additional information 18 and letters to NEAC, and you and the contractors, and we 19 have had an opportunity to discuss it at our post recent 20 public meeting. It has been an issue, and people in the 21 area of Millstone have been concerned about this process and 22 how we are applying it, so we wanted to put on the record 23 more formally the types of considerations that we are 24 working through in making these judgments.

25 Next slide, please.

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161 1

The ICAVP activities projected to be completed, 2

again, through April, are the Unit 3 ICAVP Corrective Action 3 Inspection, which is scheduled to begin the 23rd of 4

February, on-site, the Unit 2 ICAVP Tier 1 out-of-scope.

5 This is the first SSFI team inspection at Unit 2 and we 6

expect, and this, again, depends upon where we are at, but 7

the projection, at Aeast right now, would have us completing 8

. our Restart Assessment Panel Evaluation of the Unit 3

.9 findings from both Sargent & Lundy and from our own NRC team 10 inspections and documenting our conclusions relative to the 11 judgment we make regarding conformance or not with the 12 licensing basis and design basis.

13 Next slide.

14 CHAIRMAN JACKSON: Let me make sure I 15 understanding something. You talked about one inspection 16 that was starting on the 23rd that was a four week on-site 17 inspection. Is that the same as --

18 MR. IMBRO: That's the Corrective Action 19 Inspection, you are referring to, Chairman Jackson. That is 20 really -- that, right now, is scheduled for three weeks 21 initially. We think we may have to, because the licensee 22 isn't -- well, because the DR process is still ongoing, we 23 may have to do part of the inspection and inspect what we 24 can of the work that the licensee has already done, and then 25 come back, you know, a week or so later and- do the ANN RILEY & ASSOCIATES, LTD.

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162 1 inspection of the Corrective Actions in response to the 2 Sargent & Lundy generated Discrepancy Reports.

3 CHAIRMAN JACKSON: Okay. But I just want to make 4 sure I am talking about the same inspection here.

5 MR. TRAVERS: Yes.

6 CHAIRMAN JACKSON: So the one you talked about, 7 this fifth inspection. --

8 MR. IMBRO: That's it.

9 MR TRAVERS: That's the Corrective Action.

10 CHAIRMAN JACKSON: And so these are both the same?

11 MR. IMBRO: That's it.

~

'2 CHAIRMAN JACKSON: Okay.

13 MR. TRAVERS: I should point out one problem with 14 this slide. I have been trying to indicate the on-site time 15 in all of the dates I have been using. The second 16 inspection includes, I think, prep. and documentation.

17 There's -- it's too long a period for an on-site inspection, 18 so I will just point that out now. Sorry.

19 CETIRMAN JACKSON: Now, I don't mean to be picky, 20 but this fifth inspection, when I asked the question, you 21 said there were seven people and it would be four weeks on -

22 site.

23 MR. TRAVERS: This one, the team inspections to 24 date on the System Safety Functional Inspection, the two 25 systems, have involved seven people for four weeks on site.

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163 1

This last inspection -- and if I misled you, I apologize --

2 the Corrective Action Inspection is right now, and it may 3 take longer, but it is right now nominally scheduled for 4

three weeks on site with -- how many people?

5 MR. IMBRO: About seven people.

6 MR. TRAVERS: About seven people.

7 CHAIRMAN JACKSON: Okay. So the first was 8 historical?

9 MR. IMBRO: Yes.

10 MR. TRAVERS: Yes. And this is the 11 follow-through. Just to give you an overall sense of all of

~

12 the inspections, at least the ones we have identified that l 13 need to take place before we could be in a position to 14 consider a restart recommendation, we have put them all down 15 on this slide, beginning with the ongoing Corrective Action, 16 or 40500 inspection leading off. This is a seven person 17 inspection and it is two weeks on site.

18 We have inspections in motor operated valves. The 19 major team inspections listed here are the, again, the ICAVP 20 Corrective Action Inspection, the Operational Safety Team 21 Inspection, which is very much an important determination 22 for the licensee's transition from a shutdown plant to an 23 operating plant. This is an inspection that needs to be 24 tied to their entry into Mode 4 and if that slips, our 25 inspection will slip to appropriately cover-the activities ANN RILEY & ASSOCIATES, LTD.

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) 2 84 - b3

164 1 that we need to observe in connection with those operating 2 mode and operator actions.

3 CHAIRMAN JACKSON: So it could be impacted by this 4 -- what turned up today?

5 MR. TRAVERS: That's my point, yeah. The Deferred 6 Items List, this is an important one because we have, to 7 date, conducted three inspections of the Deferred Items "

8 List.

9 CHAIRMAN JACKSON: Now, is this another check of 10 the Open Items List?

11 MR. TRAVERS: That's exactly right, it's just a 12 different terminology for the same thing, i

13 CHAIRMAN JACKSON: Okay.

14 MR. TRAVERS: We have been periodically received 25 detailed lists from the licensee of all of the items that 1C they consider both necessary for restart, as well as the 17 items that they intend to defer, and we have been inspecting 18 those periodically. And I think, as the Chairman pointed 19 out, we have identified an issue most recently with the 20 adequacy, in part, at least, of the most recent list.

21 CHAIRMAN JACKSON: And did that -- was that 22 surfaced through this kind of inspection?

23 MR. TRAVERS: Yes, that very inspection is the one 24 that surfaced that --

that issue. On the whc'.e, though, I 25 have to tell you that we have, in pulling the string on some ANN RILEY & ASSOCIATES, LTD.

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165 1

of these, even though this turned up a question and it may 2 ultimately be a serious one, the inspections that we have 3 craducted against the deferred items have identified a 4

fairly low threshold for inclusion of many, many things on 5 this list and appropriate deferral of items that don't have 6 particular safety significance and are not issues that 7 affect the licensing or design basis, B

CHAIRMAN JACKSON: Now, will you be giving 9

,particular attention to issuta that the licensee is adding 10 to the list late in the game?

11 MR. TRAVERS: Yes, we have one more, or depending 12 on how many days go by, weeks, we have as many as it takes, 13 but we are going to perform at least one more of these types 14 of inspections before coming to the Commission.

15 CRAIRMAN JACKSON: Please.

16 COMMISSIONER DIAZ: I have a quick question. Now 17 that my brain is. starved.

18 CHAIRMAN JACKSON: The day is young.

19 COMMISSIONER DIAZ: There will be no level 3 items 20 in the deferred list, correct?

21 MR. IMBRO: That is probably true because --

22 MR. TAh"ERS:

Level 3 items need to be addressed, 23 and that is e.he agreement.

24 COMMISSIONER DIAZ: Need to be resolved before --

25 MR. TRAVERS: Resolved, I shouldn't say addressed.

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1 l

166 1 COMMISSIONER DIAZ. And that is -- that is a clear 2 distinction?

3 MR. TRAVERS 2 To meet your licensing.

4 COMMISSIONER DIAZ: Level 4, that will be 5 considered, and could be er not?

6 MR TRAVERS: Yes. Many of those --

7 MR. IMBRO: Likely would be deferred.

8 CHAIRMAN JACKSON: Depending upon what you find in ,

9 terms of looking for adverse trend.

10 MR. TRAVERS: Yes.

11 CHAIRMAN JACKSON: But no level 3 's. That is an 12 important distinction.

13 COMMISSIONER D AZ: That is an important 14 distinction. And I guess you now realize that we have been 15 sensitized to the Deferred I* ems List, so expect to see it 16 in great detail.

17 MR. TRAVERS: I think I recognize that. Each --

18 the last point I will make on it is that each of these 19- inspections cover issues that are encompassed in our Restart 20 Assessment Plan, so that that plan, again, you know, sort of 21 captures all of this and is our method for documenting 22 closure in part.

23 Licensing restart issues are identified on the 24 next slide. The two additional issues that need to be 25 submitted-are-issues that affect Mode 2 and not Mode 4. But ANN RILEY & ASSOCIATES, LTD.

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167 1 to a large extent, our best Jense of where we are relative 2

to the ones we have under review is that they are being 3 processed reasonably, on a timely schedule.

4 CHAIRFVJi JACKSON: So are they likely to be 5 critical path? Because normally there is a 30-day Federal 6 Register notice of license amendments.

7 MR. TRAVERS: That's right. In fact, if you look 8 at the schedule for the earliest possible-treatment of even

$$1 a nonsignificant issue, it's about 45 days in terms of the 9

10 processes that we have to utilize, Federal Register notice 11 and so forth. So it could be, out right now the indication 12 we have from the licensee is they expect to get that in very 13 soon.

14 CHAIRMAN JACKSON: It depends on what they get in 15 and your assessment of what they get in.

16 MR. TRAVERS: Getting it in triggers the action 17 teat we take in handling it.

18 CHAIRMAN JACKSON: Okay. Very good.

19 MR. TRAVERS: The last twc slides are slides that 20 I have typically pre .ed to the Commission in connection 21 with these briefings, and they are our project blanning 2i schedule. They are the schedules we use to schedule our 23 resources, and it's always important to recognize that the 24 activities that are indicated on here are largely dependent 25 upon the licensee completing the actions that they need to ANN RILEY & ASSOCIATES, LTD.

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168 1

1 complete for us to come in and carry out an important 2 inspection.

3 CHAIRMAN JACKSON: So it's a planning tool.

4 MR. TRAVERS: It's a planning tool.

5 CHAIRMAN JACKSON: It does not presuppose any l 6 particular judgment. '

7 MR. TRAVERS: It certainly does not, and one thing 8 that I have changed in the presentation this time is we've ,

9 removed any -- because this is a planning tool and we don't 10 plan for the Commission, we've taken out the Commission 11 meeting date from this slide. We don't want to lead co any 12 misOnderstandings about the significance of any date we 13 might list in such a planning tool. So we've removed that 14 from the schedules. I think you could infer when the staff 15 though 'till -- could at the earliest be ready to come before 16 the Commission with a recommendation.

17 CHAIRMAN JACKSON: Right. But I think in the end 18 as you say it's the Commission's meeting date, and you have

~

19 to come and present the case, and you have to indicate when 20 you're ready to do that.

21 MR. TRAVERS: I think the best indication of our 22 not using sched"les to drive anything is the fact that these 23 schedules have changed over time, and you can go back 24 historically and look at them, and they've changed because 25 of the need on the licensee's part to complete important ANN RILEY & ASSOCIATES, LTD.

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169 1 activities to support us coming behind.

2 CHAIRMAN JACKSON: Very good.

3 COMMISSIONER McGAFFIGAN: May I ask --

4 CHAIRMAN JACKSON: Please.

5 COMMISSIONER McGAFFIGAN: You've effectively 6 amended the Unit 3 slide as it pertains to license 7 amendments in your last remarks, right? At the moment it 8 carries -- finish 3/6, and I interpret your last remarks to 9 mean finish around 4/1.

10 MR. TRAVERS: Whenever.

11 COMMISSIONER McGAFFIGAN: If you get the 12 application tomorrow.

13 MR, TRAVERS: That's right. It would take 45 days 14 min.

15 Chairman, you asked us to address a question about 16 operability of RSS and if --

17 CHAIRMAN JACKSON: Yes.

18 MR. TRAVERS: I'll just do that very quickly now.

19 CHAIRMAN JACKSON: Please.

20 MR. TRAVERS: The answer from our view is that we 21 believe that the modifications that have been made to the 22 system were necessary to make that system operable.

. The 23 licensee itself has issued at least we believe on four 24 occasions LER reports that indicate a question about 26 functionality of that system. We documented in an NRC ANN RILEY & ASSOCIATES, LTD.

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170 1 inspection report a potential escalated enforcement issue 2 associated with operability of the -- functionality of that 3 system. So the answer simply is that we believe that that 4 system was not operable.

5 CHAIRMAN JACKSON: Before the modification.

6 MR. TRAVERS: Before the modification. Of course 7 it's required to be operable in Mode 4 and above.

8 CHAIRMAN JACKSON: Right.

-3 9 Commissioner?

u J

+

10 COMMISSIONER DIAZ: I was just going to go on 11 that. Operability meaning the capability to perform n

} 12 safety function according to requirements of the license, k 13 MR. TRAVERS: Right, 14 CHAIRMAN JACKSON: Is that correct?

15 MR. CALLAN: Not necessarily.

16 r,MMISSIONER DIAZ: No?

17 MR. CALLAN: A system can be operable -- I mean, 18 can be functional but not operable.

19 COMMISSIONER DIAZ: Correct. Correct. Correct.

20 That's what I'm saying. Operability defined as capability 21 to perform a sh sty function.

22 MR. CALLAN: Operability as defined by tech specs. ,

23 COMMISSIONER DIAZ: Yes.

24 MR. CALLAN: Right. Which does not always 25 necessarily imply --

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171 1 CHAIRMAN JACKSON: Right. So you don't want to 2 give a universal. You're saying it's --

3 MR. CALLAN: No, no.

4 CHAIRMAN JACKSON: Relative to this particular --

5 MR, CALLAN: In fact, that's one of the reasons 6 we --

7 CHAIRMAN JACKSON: In this particular --

8 MR. CALLAN:

. That's why we call it a safety system 9

functionality inspection and not a safety system operability 10 inspection, because of that distinction. It's a very 11 important distinction.

12 COMMISSIONER DIAZ: I just wanted to bring it out.

13 There is a distinction. Sometimes I get --

14 MR. CALLAN: Right. And that distinction is 15 crucial. It's very important. Right.

16 CHAIRMAN JACKSON: And you don't want to go on the 17 record as saying one thing and something else is in the tech 18 specs.

19 MR. CALLAN: Right.

20 CHAIRMAN JACKSON: Good.

21 MR. LANNING: Speaking of which, may I clarify my 22 response to you on the --

23 [ Laughter.)

24 MR. LANNING: Significant items list?

25 They have submitted packages to us for the vendor ANN RILEY & ASSOCIATES, LTD.

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172 1 information. That's just a critical issue that still 2 remains to be resolved with additional packages coming.

3 Whereas with the Appendix R submittal we have not received 4 any of those packages necessary for inspection of that item.

5 CHAIRMAN JACKSON: Okay. Thank you very much.

6 Any additional questions from the Commissioners?

7 We've been here a long time. I would like to l 1

8 thank Northeant Utilities, Sarc.nt & Lundy, Parsons Power, , l 9 Little Harbor Consultants, and of course the NRC staff for 10 briefing the Commission on the progress in assessing 11 readiness for restart of che Millstone units.  !

12 And once agaL1 I will state on behalf of the l 13 Commission that we recognize how difficult it is to condense i l

14 the substance of the reviews performed by each of you into i

15 briefings like this. And that is the primary reason that 16 the NRC in November of 1996 created the Special Projects 17 Office to provide for direct oversight of all licensing and 18 inspection activities and to tailor the NRC staff's 19 guidelines for restart approval to specifically assess 20 deficiencies at the Millstone units.

21 And as I state at each meeting and I'll state 22 here, the Commission does not presuppose that any of the ,

23 three plants will restart by any certain date. The 24 Commission is primaril-f concerned in ensuring that the 25 Millstone station is a safe station with an effective ANN RILEY & ASSOCIATES, LTD.

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173 1 corrective action program and an environment supportive of 2 the raising of and resolution of-safety concerns.

3 Now with respect to the schedule for the next 4

Commission meeting on Millstone, I think it is import ant to 5 recognize that when a plant has been shut down for an 6- extended period of time, even under a confirmatory action 7

letter, which is more narrowly tailored typically, for 8 example, the licensee will usually establish dates to 9 facilitate its planning and scheduling of activities in 10 support of plant restart, and it is used as part of what the 11 staff may use in planning its work, 1

~

12 However, licensees quite often take longer than 13 they expect to complete their restart activities, leading to 14 concomitant adjustments or deAays in the schedule for the 15 staff's reviews, inspections, and assessments of a plant's 16 readiness for restart.

17 And in the case of Millstone, given the scope, 18 complexity, and significance of the issues there, it is 19 natural to expect-that the resolution of the issues may take 20 a little while longer.

21 The NRC staff, and I said this when I was in 22 Connecticut, has been directed to stay focused on doing '

23 objective assessments and to call it as they see it.

24 In preparing for any subsequent Commission 25 meetings and in reports to the Commission, I would like to ANN RILEY & ASSOCIATES, LTD.

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j

174 1 ask the staff to give particular attention to and to provide 2 information in the following ten areas which has already 3 been transmitted to the staff through a tasking memo from me

'4 to Mr. Callan, the EDO. But I will list them.

5 First, crisp, clear analyses of the issues with 5 recommendations where appropriate for the Commission. And that's because you're talking to the Commission, not to 7

8 yourselves.

9 Second, a summary of independent NRC actions, for 10 example, inspections or any other assessments, supporting 11 staff decision making. But this requires a layout of the 12 criteria that you're using to make those assessments.

13 Third, in. partial evidence that Northeast Utilities 14 has made sufficient progress and fixed the underlying 15 problems in both employee concerns and the corrective action 16 processes or not. Yet impartial evidence that the licensee 17 for instance has addressed problem identification. Root 18 cause evaluation. Resolution for the individual issue. The 19 evaluation of and resolution of any generic issues that are 20 captured by that as appropriate. And the timeliness and 21 comprehensiveness overall of problem resolution.

22 Fourth, an objective discussion of what the 23 aforementioned items indicate about the effectiveness of the 24 licensee employee concerns program and corrective action and 25 configuration management processes.

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175 1 Fifth, a discussion of and conclusion of 2 acceptability of the resolution of an and all existing or 3

previous open items including any specific employee concerns 4

issues raised and any of the previously identified open 5 items.

6 Sixth, the strength of quality assurance and 7 management oversight, 8 Seventh, resolution of issues related to 9 enforcement, allegations, and petitions.

10 Eighth, the screening process and acceptance 11 criteria for reaching conclusions including any 12 justifications or basis for allowing any open items at the 13 time of plant restart.

14 Ninth, an appropriate staf f-recommended regu3 atory 15 tool for enforcing a schedule for resolution of any open 16 items at restart.

17 And tenth, a discussion of issues impacting 18 operational readiness for restart, along with a discussion 19 of the stability of the organization for continued safe 20 operation upon restart in light of resources being diverted 21 to other units.

22 And so unless my fellow Commissioners have any 23 additional comments, we're adjourned, 24 (Whereupon, at 1:37 p.m., the hearing was 25 concluded.]

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CERTIFICATE This is to certify that the attached description of a meeting of the U.S. Nuclear Regulatory Commission entitled:

TITLE OF MEETING: MEETING WITH NORTHEAST NUCLEAR ON

~

MILLSTONE -- PUBLIC MEETING E '

PLACE OF MEETING: Rockville, Maryland DATE OF MEETING: Thursday, February 19, 1998 was held as herein appears, is a true and accurate record of the meeting, and that this is the original transcript thereof taken stenographically by me, thereafter reduced to typewriting by me or under the direction of the court reporting company.

Transcriber: Au dil' '

c~ 7e V '

Reporter: Jan del Monte e

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$4,we WT /

COMMISSION BRIEFING Millstone February 19,1998

, I

\-- .

l RESTART ASSESSMENT PLAN (MC 0350) u e Employee Concerns Program

e Independent Corrective Action Verification Program (ICAVP) l

• Significant items List I

e Licensing issues j e Corrective Action Program e Work Planning and Control i e Procedure Upgrade Program e Quality Assurance and Oversight e Operational Safety Team inspection i e Enforcement e Personnel Training / Performance j i

e Public, State (NEAC), Local, Congressional, othe agencies input ,

i 2 j t

1.]MU SPO ASSESSMENT PLAN 1 FOR ECP AND SCWE  ;

l i

• Elements of the Order Completed Staff Review and Comments on NNECO Comprehensive Plan Staff Approval of Third-Party Oversight Organization Staff Review and Approval of Third-Party Oversight Plan

. LHC Oversight Reliance e Scope of Staff Assessment Activities Staff On-site Monitoring of NNECO Activities and LHC Oversight NRC Team Evaluation of ECP and SCWE NRC Team Evaluation of LHC Oversight Activities Review Effectiveness of Corrective Action Programs -

Review of Performance Measures 3 5

....m

l

'SPO ASSESSMENT PLAN FOR ECP AND SCWE i

l e Restart Acceptance Measures Licensee and LHC Assessments of Readiness for Restart ECP Staffing, Training, and Qualifications ECP Program implementation ECP Documentation Processes and Records Management and Employee SCWE Attitude Line Corrective Action and Self-Assessment Functioning Training of Management and Employees on SCWE Elements Ability of Management to identify and deal with SCWE Organizational issues e Documentation of Staff ECP and SCWE Conclusions e Post-Restart Elimination of Third-Party Oversight 4

ECP AND SCWE STATUS Activities Completed Since Last Commission Status Briefing i

e Met with LHC and Licensee on Status and Results of Activities

• Conducted NRC On-site Team Evaluation of Licensee ECP and SCWE, and LHC Oversight Activities " Quick Look" Reports issued

• Ongoing On-site Monitoring of Licensee and LHC Activities

• Participated in Team inspection of Corrective Action Program and Oversight (IP 40500) (Focus on Assessment of SCWE)

• Staff Evaluation of ECP Acceptable - SCvVE Evaluation Ongoing l

ECP A ND SCWE ACTIVITIES PROJECTED '

TO BE COMPLETED THROUGH APRIL 1998 i i i

• Continue NRC On-site Monitoring of Licensee and LHC Activities e '

Meetin0(s) with LHC and Licensee on Status and Results of Activities e issue Report on Team Evaluation of Licensee ECP and SCWE, and LHC Oversight s Complete and Document Staff Evaluation of ECP and SCWE for Restart '

Recommendation to Commission 6

l MC 0350 SIGNIFICANT ITEMS LIST STATUS (As of February 12,1998)

UNIT 3 UNIT 2 Total SIL Packages 216 71 Remaining to be Submitted 9 39 SIL Packages Completed by NRC 168 17 Under NRC Review 39 15 7

STATUS OF NRC INSPECTIONS FOR ICAVP AT UNIT 3

• Four of Five Team inspections Completed i

e Two Inspection Reports issued e Two " Quick Look" Letters issued e Fifth Inspection (i.e., Corrective Actions) Begins 2/23/98 8

't

l RESULTS OF NRC INSPECTIONS i FOR ICAVP AT UNIT 3 t

I implementation inspection (9/19/97) - Evaluation of Sergent &

Lundy (S&L) i j e S&L Determined to be Effective

e NRC-Identified issues Addressed by S&L

Tier 1 Out-of-Scope SSFI (9/19/97) - Review of the ECCS l Mode of Chemical and Volume Control System (CVCS) Operation i

e Pre-decisional Enforcement Conference (1/13/9ef j e 16 Preliminary ICAVP Level 3 Findings i

e Potential Level 1 Finding - Classified as Preliminary Level 3 Finding i

9

RESULTS OF NRC INSPECTIONS FOR ICAVP AT UNIT 3 Tier 2 / Tier .' Inspection (1/9/98) - Accident Mitigation 2

Systems and Plant Change Process; S&L Implementation e S&L Determined to be Effective e NRC-Identified issues Addressed by S&L e Six Preliminary ICAVP Level 3 Findings Tier 1 In-Scope SSFl (2/6/98) - RSS, EDG and Supplemental Leakage Collection and Release System; S&L Implementation e S&L Determined to be Effective e NRC-Identified issues Addressed by S&L e Approximately Six Preliminary ICAVP Level 3 Findings l

10

l

EVALUATION OF PRELIMINARY ICAVP

LEVEL 3 FINDINGS AT UNIT 3 l e NRC Evaluates Corrective Actions for Each Level 3 i Finding

[ -

Specific Finding Broader implications i

!,

• NRC Evaluates Level 3 Findings for Trends '

!

• Expansion ofICAVP Scope Based On:

Corrective Action Adequacy j l -

Negative Trends l

e NRC Staff Provided Additional Information on Process for Decisions Regarding ICAVP Scope Expansion Public Meeting (1/27/98) ,

Letters (1/30/98); NEAC, NU, ICAVP Contractors si

_ _ . _ _ . . _ _ _ .a

ICAVP ACTIVITIES PROJECTED TO BE COMPLETED THROUGH APRIL 1998 1

• Unit 3 ICAVP Corrective Action inspection (2/23/98 - 3/13/98)

• Unit 2 ICAVP Tier 1 Out-of-Scope SSFl* (2/17/98 - 4/3/98) e Cornplete RAP Evaluation of Unit 3 Findings and Determination of Licensing / Design Bases Conformation 1

• At the December 12,1997, Commission meeting these activities were projected to have been completed by March 1998.

12

i l '

l i

i OTHER SITE AND MILLSTONE UNIT 3 SCHEDULED INSPECTIONS i

i 02/09 - 02/20 IP 40500 (Corrective Action Process /QA) l 02/23 -02/27 Motor Operated Valves i

l 02/23 - 02/27 Emergency Preparedness Dose Assessment i

l 03/02 -03/06 Fire Protection r'3/09 - 03/12 Deferred items List i

i l l 02/23 - 03/13 ICAVP Corrective Action  !

i f i j 03/02 - 03/13 Operational Safety Team inspection (OSTI)

03/02 - 03/13 Training l

, 13

)

t i

j .

4 I

f l

LICENSING RESTART ISSUES ,

I Unit 3: 26 Completed and Closed since January 1,1997 11 issues Currently Under NRC Review i

2 Additional Issues to be Submitted i

Unit 2: 14 Completed and Closed since January 1,1997 4 issues Currently Under NRC Review j 4 . Additional issues to be Submitted Additional Licensing issues may im identified as the Licensee Continues Design Bases and Licensing Bases Problem identification.

4 14

t i

PROJECT PLANNING SCHEDULE I

MILLSTONE UNTT 3 i 2/18/96 l

i Otr 2,1997 Otr 3.1997 Ctr 4,1997 ID Took Nome Qtr 1.1998 Qtr 2,it Stort Finleh Apr l May l Jun Jul lAuglSep Od l Nov l Dec '

1 CMP UNIT 3 IMPLEMENTATION

• 6G95 Jan l Feb l Mar A4 l May 7/16/97 g j 2 ICAVP UNTT 3 IMPLEMENTATION " 5/27/97 1/30/99 i i

3 NRC ICAVP INSPECTIONS  !

7/21/97 3/13/95 4 NRC ICAVP IM.OFFrCt REVIEW / DOCUMENT 3/13/98 4/24S 8 L

5 INSPECTION PROGRAM 2/14/97  !

3/13/96 '

. r- NOurlCArION ,229. 3am.

j  :

7 EMPLOYEE CONCERNS FROGRAM 12/8/97 1/30/96  !

INSPECTION l e uCENSE AMENDMENTS 3/5/97 3 3695 .

9 OPERATIONAL SAFETY TEAM INSPECTION 3/2/96 3/13/98 lg 10 RESTART ASSESSMENT PANEL REVIEW 3/9/06 3/20/98 i 11 g i i

EDO/DIR NRR BRIEF 3/27/96 3/27/96 i g

I Configuration Management Program (CMP) carried out by the licensee.

ICAVP carried out by Sargent & Lundy contractor.

15 '

l

PROJECT PLANNING SCHEDULE M1LSTONE UNTT 2 311S96 r3.1997 Qtr 4.1997 Otr 1.1998 Otr 2.1998 Qtr 3.1998 ID TsonName Stort Finleh Aug l Sep Oct l Nov l Dec Jart l Feb l Mar Apr l May l Jtm Jul l Aug l Sep 1 CMP UNIT 2 IMPLEMENTATION

• 6/3/96 9715/97 i j l

i '

2 ICAVP UNfT 2 fMPLEMENTATION " 7/1/97 4/27/98 3 NRC ICAVP INSPECTIONS 8/2597 6/2598 4 NRC ICAVP IN-OFFICE REVIEWI DOCUMENT 6/29,98 8/7S8 g

8 INSPECTION PROGRAM 3/3/97 67/98 8 FEMA NOTFATION 7/5/98 7/1G98' f fg 7 EMPLOYEE CONCERNS PROGRAM i

12/8/97 1/3098 i NSPECTION $

8 UCENSE AMENDMENTS 5/21/97 5/22/98 3 OPERATIONAL SAFETY TEAM INSPECTION 6/15/98 6f2698 I

I E

to RESTART ASSESSMENT PANEL REVIEW 6f22/98 7/2/98 i g 11 EDOOR NRR BRIEF 7/10/98 7/1398 I

l* g Configuration Management Program (CMP) carried out by the licensee.

ICAVP carried out by Parsons Power Group, Inc. contractor.

16

& G

' ' ~

i e e Progress at Millstone Station

- Northeast Utilities Presentation for the U.S. Nuclear Regulatory Commission NRC Headquarters Rockville, Maryland February 19,1998 e

s Northeast NuclearEnergy -

% ~

f Mike Morris Chairman, President & CEO Northeast Utilities s

Northeast Nuclear Energy '

Page 1

s

'l Bruce Kenyon .

President & CEO Northeast Nuclear Energy Company s

Northeast NuclearEnergy

• 1

/

Agenda

• Station Readiness Bruce Kenyon

- Safety Conscious Dave Amerine Work Environment

- Corrective Actions to Marty Bowling Comply With Design andLicensing Bases Requirements *

• Unit 3 Readiness Mike Brothers

• Oversight Assessment Dave Goebel

+ Closing Remarks Bruce Kenyon s

Northeast NuclearEnergy

• Page 2 '

NU's Eight Restart Affirmation Criteria and Current Status

1. Root causes for decline in Millstone performance have been identified and corrected SATISFACTORY

2. Compliance with the licensing and design bases

' has been restored TRACKING TO SATISFACTORY

3. safety Conscious Work Environment has been established TRACKING TO SATISFACTORY l 4. Self Assessment and Corrective Action processes identify and resolve problems in a timely manner SATISFACTORY s NU's Eight Restart Affirmation Criteria and Current Status

5. Unit and support organizations are ready to resume operations TRACKING TO SATISFACTORY

• 6. Entire station is prepared to to properly support unit operations TRACKING TO SATISFACTORY

7. Mar.0gement controls and oversight measures are irt piace to prevent significant future performance declines SATISFACTORY

8. Restart readiness is affirmed using a rigorous process PENDING '

Page 3

Success Objective Progress '

Success Satisfactory or DMtdLYt l$nt Mitn Ernected

• High

• Leadership Yes Standards

• Regulatory Compilance Feb(U3) ,

• Strong Nuclear

• Oversight Yes Safety *NSAB Yes PhllosophY EmergencyPlanning

• Yes Rad. Protection Yes

• Proc. Quality & Adhere.

Feb(U3)

• Effective Self Assessment *SelfAssessment Yes

• Effective Corrective ' Corrective Action Yes (U3)

Action 7

Success Objective Progress success Satisfactory or QMtsilre lasyt When ErntEttd

• Restored

• Configuration Licensing and Feb (U3)

Management Design Bases 4

• Employee Safety Conscious Feb Concerns Work Environment .

+ Excellencein

• Work Control Feb (U3)

Operations

• Training Feb (U3)

• OperatorReadiness Feb (U3)

• Security Yes

• Environmental Yes Compilance a Page 4

T' ,

CEO Assessment of Challenges for Restart

• Safety Conscious Work Environment

- timely recognition and effective response to problems

- reducing the frequency of significant events

+ Compliance With Design and Licensing Bases

• - disposition remaining DRs

+ Unit Readiness

- heatup to normaloperating pressure &

terr ~perature

- manage non-restar1 backlog

+ Station Readiness

- strengthen training Northeast Nuclear Energy Longer-Term Organizational Challenges

+ Separation of Operations from Recovery

+ Additional Operational Monitoring and

, Coaching

+ Performance Monitoring, Oversight and NSAB Shift to an Operating Mode

• Long-Term improvement Plan

+ Organizational and Succession Planning Northeast Nuclear Energy

• Page5 t

i I

i Safety Conscious '

Work Environment .

Dave Amerine Vice President Human Services Northt sst Nuclear Energy ~

We Are Meeting our Rigorous Success Criteria for SCWE

• Employees raise concerns SATISFACTORY

+ Line management handles issues effectively -

SATISFACTORY

+ Employee Concerns Program effective SATISFACTORY *

+ We recognize and address " problem areas" TRACKING TO SATISFACTORY

+ ECOP and LHC concur PENDING F

Northeast Nuclear Energy

Page 6

1 i

i i

Criterlon: Leadership Survey Shows > 90% of People Willing to Raise issues to Their Supervisor

- Status: Criterion currently being met

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Criterlon: Culture Survey Shows

? 90% of Total Respondents Agree There is a SCWE in Their Area Status: Long term goalnot being met; however, current performance does support Unit 3 restart

} ,,. . .

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..,. ... . . = .. .....

{m % *_ .__ 8 pee TMs SLX las a h Goei]

Northeast Nuclear Energy "

Page 7

Cr/terlonl Concerns Requesting Confidentiality or Received Anonymously Do Not Indicate an Adverse Trend Status: Criterion currently not being met. While an adverse trend enIsts for concerns received anonymously, other \

SCWE Indicators substantiate that employees are willing ,

to raise concems.

13 1 "7 7 7 7 7 O T 7 7 7 0 p;aumr ~~~%wrsuj x

Northeast Nuclear Energy

We Have Rigorous Success Criteria for SCWE

+ Employees raise concerns

+ Line management handles issues affectively *

+ cmployee Concerns Program effective

+ We recognize and address " problem '

areas"

+ ECOP and LHC concur

~

Northeast Nuclear Energy -

Page 8 i

Criterlon Average Length of Time for a CR Evaluation Does Not Indicate an Adverse Trend

, Status: Criterion currently tracking to satisfactory 3::! _

i l!I IIi!!IIIII i . - . . . i l Northeast Nuclear Energy "

Criterlon: Quality of Condition Report Evaluation is ;> 3 on a 0-4 Scale Status: Criterion currently being met 1Illttil 1

i ii!IiiIIII!II L __ . _ _ _ _ _ _ _ - . _ _ _ _ _]

Northeast Nuclear Eneryy "

Page 9

Cr/terlon: Number of Overdue Assignments is Fewer Than 3% of Total Status: Progress is satisfactory Improvement from June 1997 (14%) to January 1998 (3%) .

a . -,-

e a: l

!i!IIiIIIIIIII i-  %-w; Northeast Nuclear Energy

• We Have Rigorous Success Criteria for SCWE

+ Employees raise concerns

+ Line management handles issues effectively '

+ Employeo Concerns Program effective

+ We recognize and address " problem

• areas"

+ ECOP and LHC concur Northeast Nuclear Fnergy '*

Page 10

Cr/terion: The Average Age of Unresolved Concerns Does Not Indicate An Adverse Trend

. Status: Criterion currently being met e

'![IllIII

'!IIiiiIIIII t ~ .-- ,

Northeast Nuclear Energy

~

r Criterton: A Substantial Majority of People Who Have used the Employee Concerns Program Would Use it Again Status: Criterion currently being met I -

- = . . -

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. I l

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Northcott NuclearEnergy ,,

Page 11

l

~

We Have Rigorous Success Criteria for SCWE

+ Employees raise concerns

• Line management handles issues effectively

+ Employee Concerns Program effective

+ We recognize and address " problem areas" '

• ECOP and LHC concur

\

Northeast Nuclear Energy * -- '

{

. I 1

7

)

Cr/terlon:;t 95% Of Supervisors Have Been Trained to Effectively Handle Employee Concerns  ;

Status: Progress is satisfactory l Representative Activities Supporting

• I Supervisory Training:

comguon  ;

+ Managing for Nuclear Safety 97.0 % .

' 50.7 Familiarization 98.6 %

+ Civil Treatment 92.7 %

+ Forum for Leadership Excellence 71.4 % t Northeast Nuclear Energy '*

I Page 12 I

Criterion: Substantiated 10CFR50. 7 Concerns are infrequent and Handled Responsibly

• Status: Performance is Satisfactory Nw=

l" V l

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Criterion: Number of Problem Areas Does Not Indicate An Adverse Trend Status: Criterion currently being met j.

~

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E93 MPP]

s Northeast NuclearEnergy

Page 13

We Are Meeting our Rigorous Success Criteria for SCWE

+ Employees raise concerns SATISFACTORY -

+ Line management handles issues effectively SATISFACTORY

• Employee Concerns Program effective SA TISFACTORY

+ We recognize and address " problem areas" TRACKING TO SATISFACTORY

+ ECOP concurs - PENDING

+ LHC concurs - PENDING

- ~

Northeast NuclearEnergy

Corrective Actions to Comply With Design and Licensing -

Bases Requirements Marty Bowling '

Vice Preskiant Millstone Unit 2 s

Northeast Nuclear Energy

Page 14

MP3 Corrective Actions are Tracking to Satisfactory Problem + Problem + Problem + [cbonW""

idenUficabon EvaluaUon Resolution W W W ter,,yy,n,,,

V

@. Low @. Operability Y .Keytatues @. Unit Organtrabonal Threshold & Report'ity Readiness

@. SelfIdentficaben @. Avg.YAge Evaluauon for

. Restart Bactiogs y .Configurabon Mgmt. Program Effecbyeness o . Mgmt. Self h. 30-Oay V . Overdue Assessment Evaluauon items

@. Trending o . MRT Quality @.RepeUUve o .Self Assessment Score issues 00 . Oversight G. Green . Sausfactory Assessment Y Yellow Tracking to Satisfactory R . Red . Unsausfaetory @.NRC SIL Closury Quality pg MP3 Restart Tasks are Tracking to Satisfactory m

M

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s Northeast Nuclear Energy **

Page 15

s MP3 Restart Regulatory and Safety-Significant Corrective Actions Are Tracking to Completion (as of 2/11/98)

Remaining Camalehd. for Restart

• Keylasues 9 7 *

• Significant items 3876 317 (Q1 50.54(f)) ,

• Significant iterns List 216 9 (Mc 0350)

• lCAVP DR Responses 634 285

+ Open NRC Restart 768 93 Commitments A

Northeast Nuclear Energy

MP3 Corrective Actions are Tracking to Satisfactory Problem + Problem + Problem idenufication + A on Evaluabon Resolution Effectiveness W - Y Y V o . Low @. Operability Y . Key issues Y . Unit Organizabonal Threshold & Report'Ity ,

Readiness

@. selfidenttfication @. Avg, yAge Evaluation

. Restart for Backlogs

@. Configuration Mgmt. Program Effectiveness O .Mgrat Mi @.7 pay @.hrdue Ast essment fyaluation items . Trending o .MRT Quality @

• Repetitive 0 .Self Assessment O

• Oversight G. Green . Satisfactory Assessment y . Yellow. Tracking to Sattwtactory R. Red Unsatssfactory @.NRC SIL Closure Quality 32 Page 16

MP3 Restart Corrective Actions to Restore Design & Licensing Bases Conformances are Tracking to Completion (as of 2/11/9m C'*

• Required Number channes nemmin

+FSAR 487 17

+ Procedures 195 5

+ Tech. Spec. 23 0

+ Drawings 138 8

+ Calculations 74 5

+ Modifications 221 8 Northeast NuclearEnergy ~ "

s Reasonable Assurance Exists that Unit 3 Design and Licensing Bases Meet NRC Requirements

+ Comprehensive reviews completed.

Trending and assessment of results continue. .

+ ICAVP results to .iate indicate NU Identified safety-significant and DBILB conformance issues.

• Post restart corrective actions will be managed to completion.

s Northeast Nuclear Energy "

Page 17 l

l -.

Configuration Management Efforts Generally Have Been Effective, and Additional Reviews are Providing Assurances of Effectiveness

+ System Interfaces / Interactions ,

+ Operating Experience (NRCInfo Notices)

+ Safety Evaluation Screening

+ Dose Analysis

+ CalculationalContrcl

+ Technical Specifications (Section 6.0-Admin)

_

• FSAR(NSSS/AEInterfaces)

Northeast Nuclear Energy

' Reasonable Assurance Exists

' hat Unit 3 Design and Licensing Bases Meet NRC Requirements i

+ Comprehensive reviews completed.

, Trending and assessment of results '

) continue.

l

+ ICAVP results to date indicate NU

! identified safety significant and DB/LB .

conformance issues.

! +

Post-restart corrective actions will be managed to completion.

x Northeast Nuclear Energy

Page 18

MP3 DRs Are On Track for Completion in February l-t-

IN ,

3 N I I I I I I l 1 I c ~ +m Northeast Nuclear Enemy

We Have Answered Approximately Two-Thirds of ICAVP Contractor DRS (as of 2/11/98)

Received Answered

+ Significance Level 1 0 0

+ Significance Level 2 1 1

, + Significance Level 3 314 203

+ Significance Level 4 S14 410 Total 919 634 s

Northeast Neclear Enemy

• Page 19

Based on the 634 NU Responses to Date

- and ICAVP Closures - MP3 Reviews ident!fied Most of the LB/DB issues

• Breakdown of 634 NU Responses

- O confirmed Level 1 DRs .

- O confirrned Level 2 DRs

- 7 confirmed Level 3 DRs

- 330 confirmed Level 4 DRs

- 79 considered previously-identified

- 218 considered non-discrepant Nonheast N.sclerr Energy "

f MP3 Design and Licensing Bases Reviews identified the Safety-Significant items (1/ss - 2 mss)

Safetv Significance 5013 LERs

+ Total (NU identified) 119 .

-low 103

- moderate 12

- high 4

+ 3 LERs resulting ; rom ICAVP

- none ofhigh safety significance

- none from DRs '

~

NorGeest Nuclear Energy **

Page 20

Reasonable Assurance Exists that Unit 3 Design and Licensing Bases Meet NRC Requirements

+ Comprehensive reviews completed.

Trending and assessment of results '

~

continue.

+ ICAVP results to date indicate NU identified safety-significant and DB/LB conformance issues.

+ Post-restart corrective actions will be managed to completion.

C-Northeast Nuc'earEnergy Corrective Action Tasks That Do Not Affect Conformance to DBILB May Be i

Deferred Under Question 2 of l

10CFR50.54(f) (data as of 2/11/98)

+ Configuration Management 705 Discovery Deferrable Tasks

-non-critical drawing updates

-FSAR enhancemente procedure enhancements

-physicalcondition enhancements

+ ICAVP DRs Deferrable Tasks -215 Northeast Nuclear Energy

• l Page 21 x . .

Reasonable Assurance Exists that Unit 3 Design and Licensing Bases Can Be Maintained

+ Configuration Management Programs ~

~ now meet 10CFR50, Appendix B requirements

+

Unit CM Organization '

- established to monitor and maintain DBILB Integrity

+

Sngineering Assurance Organization

- established to perform self assessment of the changeprocess

~

Northeast Nuclear Energy Reasonable Assurance Exists that Unit 3 Design and Licensing Bases Can Be Maintained

+ NuclearOversight

- established organization to provide -

dedicated independent assessment of Configuration Management

+ Configuration Management Training '

- has been provided

+ Performance Monitoring

- In place to assess ongoing effectiveness Northeast Nuclear Energy Page 22

Millstone Corrective Action

,_3 Program Will Support the Conduct of Safe Operations

• CORRECTIVE ACTlONS rtectivelyaddressing the fullrange ofprogrammatic, organizational, human performance and technicalissues

• REMAlNING WORK - on track for conopletion ofitems to restore design andlicensirag bases

• ORGANIZATION, PROGRAMS AND PROCESS -In place to maintain the design andlicensing bases

• ICAVP REVIEWS TO DATE -Indicate that NU revicws 5 have been generally effective In identifying safety-significant and DBILB non-conforming issues 4s

. Unit 3 Update Mike Brothers Vice President- Nuclear Operations NortheastNucles Energy a6 Page 23

Unit 3 Officer's Recainess Assessment Standards

+

Unit is fully ready for operation

• TRACKING TO SATISFACTORY

+

A detailed Startup and Power Ascension '

Plan is approved and in place SATISFACTORY

+

Backlogs have been characterized and prioritized for timely completion TRACKING TO SATISFACTORY

~; x Northeast Nuclear Energy "'

PhysicalReadiness Completion of Modifications is On Track to Support Restart ,

Work Remainin, .21 M. ,

. . . t

, E I j liII!l!IIi!l t

s Northe. stNuclearEnergy #*

Page 24

Physical Readiness On-Line Work Order Progress is on Track to Meet Power Block and Maintenance Rule Goals Prior to Restart g- n; 1 -n-,- -

-V E l

I!! IIIIIIII III

_.--o_-, CC _

Northeast Nuclear Energy *

~

Regulatory Readiness Completion of Open NRC Commitments for Restart is On Track to Support Power Operations

%%rk Remaining:93 of 768 1N w % - - we - . .

~

c-M IIIIIii!!Ii!I y- _ _ . _. ,

Nor:heast Nuclear Energy '*

Page 25

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Regulatory Readiness Significant items List Workoff is On Track to Support Restart Work Remaining: 9 of 216 ~

• M Com?

. I -..

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s Northenst NuclearEnergy

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Regulatory Readiness Completion of 10CFR50.54(f) Significant items for Restart is On Track to Support Applicable Mode Changes Work Remaining:317 ofit$1 I

13 I: 4

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a Northeast Nuclear Energy

' ;.y Page 26

Regulatory Readiness Licenda Event Reports Are At industry Standards for Current LERs

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Northeast Nuclear Enemy 53 Organizational Readiness - MP3 l DEPARTMENT READINESS ASSESSMENTS -RESTARTISSUES l I"

l venowI Training i _own 1 Engineering I c=a I matertats

,,g i Gma 1 corrective Actons A Procedu m

. , , , , im A maintenance mechanical A Radwoon Prouchon i venow1 Work Planningoutage knagement

. i G=a I tr.strument end onctrica i veno.1 mintenance Pienning Yellow Overall Restart Readiness g,g unanagement expectahans j c=n j satisfactory jyenow l ,Tr*ckla9 l Red j Unsat1* factory u

\

Page 27

OperationalReadiness Temporary Modifications Are On Track to Support Goal Prior to Restart M.

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OperationalReadin s Temp ary Modifications e On Track to Su ort Goal Pri to Restart .

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Page 28 l

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OperationalReadiness Control Room and -

Annunciator Deficiency Levels Currently Meeting Goal for Restart e., ,

!!!!IIiIIII!Ii r-y Northeast Nuclear Energy

~

OperationalReadiness OperatorWork Arounds Are Meeting Goal 1:

1: s -~-

IIIIIII 7 i!!!!!!III!IIi 1_ _ . . _ _ _ _ . . _ m ._%

x Northeast Nuclear Energy

Page 29

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MP3 Overall Human Performance is Tracking to Satisfactory i No Significant Events Resulting from Human Performance s

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Procedure Ac':.erence is a Focus Area for MP3

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Northeast Nuclear Energy **

Page 30

Systematic Startup and Power Ascension Program

, HEATUP POWER ASCE:.

a Post 44eatup 30 %

, "s0* ,O:"ra '~'a0* gs., i,,4' n -- n ,., .

, n Chef / Ch #ff *

=// $$

1 f f I I i t 1 1 l 0 *3 +9 +27 +32 +49 +50 +55 +69 476 DAYS 61 Disciplined Work Prioritization Process Applied to identify items Deferrable Until After Restart

• Corrective Action Assignments 2,260

+ Oonfiguration Mgmt. Discovery 705

• Corrective Maintenance 670

+ Operator Work Arounds 10

+ Control Room Deficiencies 9

+ Temporary Modifications 18

+ Engineering Backlog 5 14 fu oe rmio Total Deferrable items 4,246 flonheast Nuclear Energy

Page 31 s , ,.- --

1 l

l l

, l Corrective Action Assignment Characterization (Total: 2260)

• Minor Procedure or Documentation 46%

improvement *

+ Evaluation of Potentialimprovements 14%

+ Modifications / Upgrades 9% '

+ Minor Maintenance /Non-Safety Review 9%

+ Administrative Close-Out 9%

+ Other 9%

+ General Department Improvement item 4%

Nuttheast Nuclear Energy

• Corrective Maintenance Backlog Characterization (Total: 670)

+ Maintenance Rule Backlog

- Equipment non-functional .

(system operabilitymaintained) 20 %

- Equipment functional 32 %

+ Non-Maintenance Rule Backlog

- Equipment non-funci!onal 16%

- Equipment functional 32%

Northeast Nuclear Energy "

Page 32

Engineering Backlog (Total: 574)

+ Enhancements 35%

+ Modifications 30 %

+ Future Parts 20 %

+ Other 15%

Northeast Nuclear Energy

l Unit 3 Officer's Readiness Assessment Standards

+ Unit is fully ready for operation TRACKING TO SATISFACTORY

+ A detailed Start'sp and Power Ascension Plan is approved and in place SATISFACTORY -

+

Backlogs have been characterized and prioritized for timely completion TRACKING TO SATISFACTORY Northeast Nuclear E sergy "

Page 33

l l

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f e

Nuclear Oversight 3

Dave Goebel Vice President- Nuclear Oversight

\

Northesst NuclearEnergy

01.e e-v i o-.- i MP3 NORVP o1 - I og i NRC 40500 Inspection Readiness emm eersee gene sue evew one L eaoersfup avn erv e -n y t ==v == .r y :e v'v 3 = tanwl wv e-S+es I wwns I anm

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y. .in c s...

Startup & Power Ascension Wade Cheng ,  : ===s mens Power Ascensson l< eat >

tusene ses _.

68 Page 34

Satisfactory Significant Weakness S B B Y @ Manent g Not A0sessed l

NF.O40500 Ins ction Readiness 10/17/97 10/24/97 10/31/97 11/7/97 11/21/97 12/557 12/19/97 1/9/98 1/23/96  ?/658 Leadershi Y Y Y Y Y Y Y Self Assessment Y Y Y Y Y Y Y Y Y Y Corrective Action Y Y Y Y Y Y Y NSAB/Oversi ht Recove e OSTI /Startu Readin x Confi uration Mana ement Y Y Y Y

• Y Y Procedural Qualit / Adherence Y Y Y Y Y Y Y Y En ineerin Eval sterted 11/7 Y Y Work Control /Plannin Y Y Y Y Y . Y Y Y Y Y Maintenance /l&C Y Y Y Y Y Y Materials Y Y Y Y Y Y Y Y Y Y Re ufato Com liance Y Y Y Y Y Y Y SCWE Y Y Y Y Y Y Y Y Y Y Emer enc Pre Y Y Y Y Y Y Y Y Y Y Radiation Protection Trainin Y Y Y Y Y Y Y Y Y Conduct of O erations Y Y Y Y Y Y Y Chemist Y Y Y Y # k' '

Securit Environmental Monitorin Y Y Y Y ] Y Fire Protection Eval started 10r24 Y Y Y Y Y Y Y t

__S_tartup_&_P_ower Ascension Mode Chan es ..

Evaluation started 2/6/98 Y Power Ascension Euluede not commenced

..I

-O Concluding Remarks  :

Bruce Kenyon I

e x

Northeast NuclearEnemy **

Page 35

m - ..-m--.-, ,,- - - - - ------ -,. -,,, - . . - - - - - - - - - - - --------r- - - - - - - - - - - - - - - - -r---.---- , .-- , .

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t.

! -- 9 T-

.4

v. .g -

_m

MILLSTONE UNIT 2 STATUS OF ICAVP Dan Curry Eric Blocher Parsons Power February 19,1998

_ , r a n.o .

Agenda e Sta:us of Tier 1,2 & 3 Review Activities i

e Lnit 2 ICAVP Schedule s Discrepancy Report Status  !

" PARSONS oupws 2

~

Tier 1 Review Status:

e High Pressure Safety Injection (HPSI)

' Outstanding Discrepancy Reports require response before system review can be completed Corrective Action Review in progress e Auxiliary Feedwater (AFW) on hold until ,

receipt of new calculations, full impact of reanalysis unknown at this time

!=3 i

,wiws 3

." PARSONS

Tier 1 Review Status: -

e Radiological Release Control (RRC)

' Licensing Basis Definition completed - Design Basis; Review in progress Started review of Modifications and System Components e Emergency Diesel Generator (EDG)

Licensing Basis Definition completed - Design Basis Review in progress Started walkdown of electrical systems E m asc===

Tier 2 Review Scope:

CDCs Approved by NRC 29 Design Basis Events Analysis Review Completed - 25 Events Validations In Progress - 11 Events Validations Complete - 6 Events Target Completion Date - April 29,1998 Parsons will revalidate 10 events being reanalyzed by XKECo U

ome,s s >

PARSONS i

l Tier 3 Review Scope:

l e Sample Selection complete except for vendor manuals e Review completed for the following sample groups:

2 of 8 areas in Engineering / Licensing Document Group All areas in Parts Dedication, Substitution and Safety Classification Group 6 of 9 areas in Operations and Maintenance Group e Tier 3 approximately 75% complete w

-" PARSONS ems s

Unit 2 Discrepancy Reports

+ 57 Discrepancy Reports Closed or Confirmed - Pending 39 Confirmed Discrepant 1 I Previously identified by NNECo 7 Determined to be non-discrepant condition e Of the 39 Confirmed Discrepant DR's 1 - Significance Level 3 (0 closed) 38 - Significance Level 4 (12 closed) i l

03io;o, 7

? PARSONS

l i

Tier Review Status (as of Feb.13,1998) l Status Review Completion

+ Tier 1 HPSI 2/19/98 AFW 5/29/98 EDG 5/15/98 RRC 5/7/98 e Tier 2 4/29/98 e Tier 3 4/8/98 E

e,,,yg ,

> PARSONS m

s

k Final Report Schedule e Target submittal c ate for L nit 2 ICAVP Fina" Report is July 10,1998. Submittal date assumes:

All Discrepancy Reports resolved Anticipatec Discrepancy Report resolution process (3 to 5 week process)

A 1 Corrective Actions reviewed

_ , a PARSONS

i 1

SUPPLE MKNTAL INFORMATION l

PARSONS omwa m y

Parsons ICAVP Team  :

Dan Curry, VP Project Director i

George Be dler ~

g Mgr. Co. Quality Program Eric Blocher i Deputy Project Director Project Support __

Bill Meek Tech Advisory Group l5l 4 I I I Mike Akins Rich Glaviano Wayne Dobson John Hilbish Tier 1 Lead Tier 2 Lead ,

Tier 3 Lead Regulatory Affairs 66 l 13 14 5l E"

ciom ,, PARSONS r _ - _ _ - _____-

- wo~-~-..-,-..--u-.--._--.-..~,. -. , . . - - - . - . - - . . . - _a . . - . . - ~ _ - . - . . . - - - - _ _ ~ . ~ , . - . . . . --- - .-.-.-- ----- - .. . -

l 0

m C

k s

e o

+,a C

+

Z I

l 1

l l

n ,

i l

I i

E E

~

F:

i

l l System Interfaces 16, 14-e Systems 12-

interfacing 10 -

with the 8--

~

l selected l 4-l System 2/

0-HPSI EDG EBFS t

e, , , ,, " PJPARSONS I

RPSI System Interface Systems ,

Major interface System I

_ MinorInterface i -Low Pressure Safeiy l Injection Chemical & Volume Containment Spray Control Containment Sump Refueling Water -

-Containment Purification i

-Reactor Building Closed Charging Cycle Cooling Building & Equipment HIGH .ESFAS Drains PRESSURE m

. Emergency Features Room RWST Heating SAFETY "

Cooling Post Accident INJECTION _j 4160 vAC Sampling

-480 vAC 120 vAC ,

-125 vDC instrument Air Refueling Water Stor '"

Safety injection Actuation Signal Sump Recirculation Actuation Signal

> PARSONS

~

enma i ., t

ACXILIARY FEEDWATER AND CONDENSATE STORAGE INTERFACING SYSTEMS INTERFACING SYSTEMS FOR AFW SYSTEM REVIEW

l. Main Steam i

2. Main Feedwater l

3. Fire Service

4. Condensate Storage and Transfer

5. Instrument Air

6. 4160 Volt AC

7. ATWS Initiation

8. 480 Volt AC

9. 125 Volt DC

10. Reactor Protection System i1. Auxiliary Steam

12. Heat Tracing W

" PARN ew,s is

L HIGH PRESSURE SAFETY INJECTION &

REFUELING WATER STORAGE TANK INTERFACING SYSTEMS

1. Low Pressure Safety Injection

2. Containment Spray

3. Containment Sump

4. Reactor Building Closed Cooling Water

5. Engineered Safety Feature Room Air Recirculation Units

6. Instrument Air r

7. Refueling Water Storage Tank

8. Charging System (for back-up boron precipitation control)

9. 4160 Volt AC

10. 480 Volt AC I 11.120 Volt AC i 12.125 Volt DC l l

13. Engineered Safeguard Actuation System and Isolation

14. Safety Injection Actuation Signal I

15. Sump Recirculation Actuation Signal  :

l

" PARSONS omus is j l

_NCLOSURE BUILDING FILTRATION SYSTEM (EBFS)

& CONTAINMENT and ENCLOSURE BUILDING PURGE SYSTEM (CEBPS)

INTERFACING SYSTEMS l

1. Fuel IIandling Ventilation System and Radiation Monitors

2. IIydrogen Purge System l

3. Instrument Air

4. Containment Radiation Monitoring

5. Unit 1 Stacic Monitoring System

6. Condenser Air Removal

7. 125 Volt DC

8. 480 Volt AC

9. Auxiliary Steam System

10. Main Exhaust System

11. Gaseous Radwaste System (utilizes same exhaust duct to Unit I stack)

12. Engineered Safeguards Actuation System (ESAS)

13. Fire Protection 5

pyf tg yg 17

EMERGENCY DIESEL GENERATOR AND SUPPORT SYSTEMS .

SYSTEMS SELECTED

1. Emergency Diesel Generator

2. Emergency Diesel Generator Fuel Oil

3. Emergency Diesel Generator Room Ventilation

4. 4160 Volt AC and Fast Bus Transfer  ;

5. Engineered Safeguards Features Actuation System (Emergency Diesel Generator Load Sequence Only) t eiss, i.

-= 1panscms

7 ,

INTERFACING SYSTEMS FOR SYSTEM REVIEW 1

1. 4160 Volt AC 9. Emergency Lighting l

2. 125 Volt DC 10. Computers UPS

3. 480 Volt System 11. ComputerRoom A/C

4. Fire Protection 12. Containment Sampling

5. Service Water 13. Post Accident Radiation

6. Instrument Air Monitoring

7. Engineered Safeguard 14. ReactorCoolant Actuation System (ESAS) 15. Fuel Handling Building H/V

8. 120 VAC 16. Boric Acid E

omm ,, L PARSONS

Select systems

+

• Tier 1 - HPSI RMoundaries & Data G mering General u

• l Schedule k^'"*""* * -

'~ (SIN I I,ic. Docs d Mod. Review Calculations t

, Rs i hiaint Procedures

• Vendor hianuals 1 6 i

Test Procedures Completed Afods Packages IIPSI Report k 1 Specifications r' All CIRs/ACR/Ak t I t i Vendor hianuais All Calculations DBDP All Procedures (ONIT) l EQ Package i Specifications

____j Review Procedures ,

i

{_____{_____

Cc rective Action Review i

l-----f----- M i l 1 i  ;  ;

l

• *

• t System Form 2 (License 'lasis) Form 3 (Design Basis - Comp) l

! Iloundary Form 3 (Design Basis- System) Form 7 (System hiods)

Diagrams Form 5 (Klod Screen) Form 8 (Ops. Procedures) l j Form i Form 6 (Alod Listing) Form 9 (Testing) l Form 10 (P&lD Walkdown) Form 10 (Wa!Ldown) Final Systems Report i

I i

02/19N9 20

- l t

o Select Systems

+

• Tier 1 - AFW Boundaries & Data Gathering N w' General n Desion unsing E asis i Schedule '

• ^' "' * * '

y,,,

PI '7 (sys) +

MM hw A

I All PDCEs Review Check /

C.orrective

' Action  ;

l Closcout

' . All PDCRs Ops Procedures ,

1 1

i

• Maint Procedures i Vendor Minuals I I I Test Procedures 4 Completed Mods Packages i +- AFW Report k Specifications i All UIRs/ACR/AR I f 8

,' ' I Vendor Manuals All Calculatsens DBDP <

A!! Procedures (OMT)

EQ Package Specifications

____j Review Procedures

{_____{_____

Corrective Action Review l_____j_____ r e i e System Form 2 (License Basis) Form 3 (Desiga Basis - Comp)

Boundary Form 3 (Design Basis- 53stem) Form 7 (System Mods)

Diagrams Form 5 (Mod Screen) Ferm 8 (Ops. Procedures)

Forr.I Form 6 (Mod Listing) Form 9 (Testing)

Form 10 (P&ID Walkdoun) Form to (Walkdown) Final Systems Regnt 02/1938 28

Select Systeras

+ * '

Tier 1 - RRC E:oundaries & Data Gateing

- General Desio

~ '

asis A

Jk W Schedule l pal Requests

g i  !

PI-7 (sys) i PI-7 i s f

Mod. Review g

Cales (t)ti) i f I f I Checklist Modifications i Corrective Action g i i 6 Review / Cross Check /

Jk g j Ops Procedures  ; , , ,

2 Maint Precedures Vendor Manuals I i i I Test Procedures Completed Mods Packages System Report k sreifications All UIRs/ACR/AR  ! I I f f I i

! Vendor Manuals All Calculations DilDP All Procedures (OMT) -

i EQ Package Specifications I ,

, Fiel} Walkdowr; , , , , , , ____j I

i e i i 8 4 4 4 I Review Procedures

{_____{_____, ' '

, , l Corrective Action t Revinv I t t t t l_____{_____t System Form 2 (License Ilasis) Form 3 (Design Basis - Comp)

Boundary Form 3 (Design Basis System) Form 7 (System Mods)

Diagrams Form 6 (Mod Listing) Fonn 8 (Ops. Procedures)

Form ! Form 10 (P&lD Walkdown) Form 9 (Testing)

Form to (Waikdown) Final Systems Renxt 02/IONX 22

Select Systems

+

• Tier 1 - EDG Eloundaries & Data Gathering N

• General

^ Schedule mE$IEm}$EE&4ESmusul j RAI Requests ,

n

)

i P'~7 ('?5) . c Docs Mod. Review Calculations , , , , yg

{

i i i Afodifications

, Corrective Action j g i Review, Cross Check /

N g ,

Ops Procedures j , , , j i Afaint Procedures I

• Vendor Afanuals I e i l I Test Procedures Completed Atods Packages -

System Report k '

+ Specificaiions . All UIRs/ACR/AR I f I f f Vendor Nianuals t All Calculations DHDP All Procedures (ONIT) f.

EQ Package Specifications

, Fiel} Walkdowry , , , , , ,

, . . . . . , , ----i Review Procedures p _ _ _ _ _ p _ _ _ _ _ ,-- , ,

Corrective Action

• f Review f I t t t l_____1_____ I n- i I 4 i i i System Form 2 (License Ba is) Form 3 (Design Basis - Comp)

Boundary Form 3 (Design Basis- System) Form 7 (System 51ods)

Diagrams Form 6 ( Alod Listing) Form 8 (Ops. Procedures)

Form i Form 10 (P&lD Walkdown) Form 9 (Testing) j Form 10 (Walkdc an) Fimi Systems Report 02/19Ms 2J

Corrective Action Review 1

Id e a tef y A p p tec e D fe i

C o rr e c tev e _

g ,e E Oe I

~

a e tse n s D efeDases I

1r '

5oe: ana 6 e ese ee ACR eIC R el end AR e 1P R e w 3e e C o eto e see e I A c 4 6e n

_ s a t.s ,. e t e r , Reet Ceese A n a ly s es Peffeem ed 5g t if =eceesery) 3r c e s e e e it, e "O to ceeret..

A e tse n = = A e t to n T &ne in g A p p re p rto to se o A P p 'o p fle to NO 1P

/ e,epe.. DR I too.,te,y. . ..see . . , -

CA e, 1.. ..

l v

Deevm ont en F e em & -

E3 02/19an

+4 >

PARSONS

Corrective Actions I\

E AC R-C R N-3000 EAR e ACR-CR identify issues to

'N -2500 be resolved and contains

-2000 significance level i

-1500 e AR identify general actions to be performed

~1000 and identifies timing of

-soo action i . . o i

HPSI AFW HVAC EDG l

liiiii

! o2,w 23

" PARSONS 4

Corrective Action Review e Corrective Action Review Population DRs (as of February 10) 202 ACRs & CRs with system identified-O HPSI 40C oAFW 150 ,

oEDG 300 o RRC 150 ARs average 6 per ACR/CR Non-aligned ARs approximately 5000

! NRC Sample of Corrective Action Documents 80 M

enw :s PARSONS

]

Tier 2 -

Status  !

e Design Basis Event Analyses Review anc Validation in Progress e 14 Discrepancy Reports issuec based (Tier 2) e CDCs approved by NRC: Parsons has incorporated NRC CDC comments into Tier 2 1

5*

c:;,vn 2, PARSMS

Tier 2 - Design Basis Event (DBEv) Review Event Category Numberof Analpis Validation Event DBEv's Review Cornpicte Reanahsis RC FlowReduction 2 2 2 -

I Reactivity 6 6 2 1 Radioactive Releases 4 4 2 -

Overcooling 3 2 -

2 Loss ofHeat Sink 4 4 -

3 RC Pressure Boundary 4 3 - -

2 i Containment Analysis 4 4 -

2

! TOTAL 29 25 6 10 l - -

i

- nansc==

_ , , 2.

T l

Tier 2 - DBEv Review For each accident, identify CDCs as Validated /Not Validated Identify "Not Validated" CDCs as:

o Preliminary Discrepancy Report (NV-DR-xxx) e Previously identified by NNECo (NV-UIR-xxxx)

Communicate items requiring resolution to validate the CDCs e DRs tied to NV status e UIRs, CRs, etc. tied to NV Status e Place Holders (RAIs & Revised Analyses)

W

. " > PARSONS

,,my y

Tier 2 - Infonnation Needs e Critical RAIs for Accident Mitigation Systems Validation:

17 RAI's Submitted Based on Pilot RAI Process for AMSR Systems

- NNECo Provide Calculations Identified by Parsons - Complete

- NNECo System Engineers Review Calcs Listed on RAI's - Complete o Identify Superceded and Revised Cales e Identify Additional Calcs (Provide to Parsons) e 10 Design Basis Events Being Reanalyzed by NNECo o Schedule Assumes Design Inputs Available by February 13 o MSLB/LOCA Containment Reanalysis Design Inputs Received tenws 3o

." > PARSONS l

• . j

Tier 3 - Process Review Summary e Phase II sample selection complete except for vendor n .m 's s Revierv completed for following samples:

l Equivalency Substitutions and Commercial Grade Dedication Equipment / Parts Safety Classification Changes Maintenance Procedure Revisions Operations and Surveillance Procedure Revisions

Emergency and Abnormal Operations Procedure Revisions Inservice Inspection and Testing Procedure Revisions Temporary Changes / Jumpers, Lifted Leads l Setpoint Change Requests e Tier 3 Approximately 75% Complete ma omwn 3, PARSONS

1 i

I Tier 3 Su1mnal Schedule Logic l

k i N*tication scent li RAI&

Conferences Spectfy Specify

-Population 1.ist, Phase i Obtain & Review Sample ,

^I

-Understanding of Processes **I'#  !

Ibcuments Follow up RAis i Ref. Doc. etc.

- Phnso if Sample ,

= dpecity 8 Phase 11 j

RAI Obtain & Review Sample i Sample ' i

[

Items Follow up RAls  !

Ref. Doc. etc.

- Tiw 3 5 Final Report 4

! NRC COMMENTS EB i

.y PARSONS i 02/19/98 r i  :

. . } l t

1 l

Tier 3 Inspection Areas -

Status l Engineering / Licensing Documents Sample items Number Selected Obtained Reviewed Remarks Setpoint Changes (SCR) 5 5 5 5 Sample Plan Revision Specification Revisions 31 31 31 8 Drawing Revisions 32 32 32 17 Calculatton Revisions Using Tier 1 & 2 Resu!ts Sample Plan Revsron Licensing Document Changes 19 19 19 12 Non-conformance Reports,(NCR) 32 32 32 12 Engineenng Work Request. (EWR) 32 32 32 15 Vendor TechnicalInformation TBD Review on Hold Subtotal 151 151 151 69 oms,s n '"" PARSONS

l Tier 3 Inspection Areas - Status l

Parts Demi,Subshtution,& Sartple liens SafetyCassification Nunber Selected Cbtained Reviewed Remarts Cumuda!GabDedcation 32 132 132 132 FbportinPitxyess EqdwlencySdstitdicts 32 32 32 32 ReportinPrtgess FEPLSafetyCassiFcationOsnges 32 32 32 32 RpcrtinPrtgess Stbtotal M 1% 1% 1%

i oviwa u -" PARSONS !

, l

l Tier 3 Inspection Areas -

Status

=

Operatons and Maintenance Sartpb Items Number Selected Obtained Revewed Remarh Operaten Procedures (4 proced w/ mn.10 changes) 4 4 4 4 Report m Progress Abnormal Ops (4 procedures wf mn.10 changes) 4 4 4 4 Report in Progress EOP (4 procedures v/ mrt 10 changes) 4 4 4 4 Report in Progress Survei2ance (4 procedures wf mn.10 changes) 4 4 4 4 Report in Progress Maintenance (4 procedures v/ mn.10 changes) 4 4 4 4 Report in Progress IST Procedures (4 procedures v/ mn.10 changes) 4 4 4 4 ISI Procedures (4 procedures w/ rnin 10 changes) 4 4 4 4 ASME Secton XI Repair / Replace 10 10 10 8 Temp Changes /Jurrper. Ufted Lead. Bypass 25 25 25 25 Report en Prog ess Subtotal 63 63 63 61

." PARSONS enm 3s

l Project Schedule Milestones  :

(as of February 9,1998} .

Status Review Completion '

e Tier 1 HPSI 2/19/98 AFW 5/29/98 EDG 5/15/98 HVAC 5/07/98 i'

s Tier 2 4/29/98 .

e Tier 3 4/8/98 e Final 7/10/98

,ma t

ayiw, .u,  ? PARSONS l

~

. . ~; i

s Potential Schedule Impacts ,

e XKECo Information Processing e Design Basis Availability (AFW, Piping, etc.)

e Program / Topical Area Rework e Availability of 10 Updated Analyses (Tier 2) e Discrepancy Reports Number and Complexity of Discrepancy Reports

Anticipated Discrepancy Report Resolution Process 4

_ .. PARSONS

Project Efficiencies e Twice-weekly Conference Call to discuss technical issues (NRC & NEAC Monitor) continuing e Bi-Weekly Progress Report and Schedule Update e Discrepancy Report Processing

+ Added DR Response Clarification Contact

+ Conducted 2 DR Resolution Conferences e Revised Tier 1 Checklists for Corrective Action Revierv and i Modification Review l

,,,,,,, 3, w

" ; PARSONS i

e , ,

Preliminary Discrepancy Report Summary m

e Significance Level of 269 Approved Preliminary DR's 5 Level 1 1 Level 2 120 Leve!3 l

143 Level 4 e Summary by Tier for Preliminary DR's Tier 1 - 227 Tier 2 -

14 Tier 3 -

28

=a ny;ws 39

> PARSONS l

Discrepancy Report Response Suramary e 92 Responses received from XKECo 30 DR's Closec.

28 DR Resolutions PencLing 29 DR Resolutions Requiring Follow-up 0 DR Responses In Progress 5 DR's Awaiting Revised Responses from XNECo omws 40 W

." PARSONS

Discrepancy Report Summary e Of the 30 Valid and Closed DR's 12 Confirmed Discrepancies 11 Previously Identified by NNECo 7 Non-discrepant e Of the 12 Confirmed Discrepancies 0 Level 1 0 Level 2 0 Level 3 12 Level 4 -

,,,,,, 4, PARSONS

COMMISSION MEETING FEBRUARY 19,1998 ,

MILLSTONE UNIT 3 l

lNDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM STATUS REVIEW

Structure of ICAVP Tier 1 - Verify system meets licensing / design bases and system functionality.

Tier 2 - Verify that system design parameters relied on I to mitigate the consequences of postulated accidents analyzed in the FSAR are consistent with the performance of the current system configuration.

Tier 3 - Verify that the configuration control processes have not introduced changes that have put the unit in nonconformance with its licensing and design bases.

- u - ~ .. .

l Scope of Tier 1 System Review i

SWP QSS SLCRS EDG - Engine RSS. Aux Bldg HVAC EDG - Gen.

RWST EDG Rm Vent. Fuel Oil 1 i

l Lube Oil l Starting Air Exhaust Sequencer 4160 volt syst.

SWP RSS HVX DGX se* rue m t a t aw w*v"'  !

Jd3

Status of ICAVP

' i l

Tier 1 System Review Complete l RSS Modifications Docs + 2 weeeks Tier 1 Corrective Action Review Docs + 2 weeks Tier 2 Review Complete Tier 3 Review Complete Final Report Issue DR Resol + 3 weeks

- - - ~ . . .

5 m

Discrepancy Report Process Initiation of Preliminary DR Internal DR review process Issue Preliminary DR to NU, NRC, and NEAC and post to Internet WebSite NU evaluate DR and respond Review NU response

- - - ~ ...

t _- ._

Discrepancy Report Closure Process DR closure based on review and acceptance of NU response and proposed corrective action Categories of Closed Discrepancy Reports

- Confirmed DR (not identified by NU CMP)

- Previously identified

- Non Discrepant

_ _ ~ ...

. D

t DR Significance Level I

i Level 1 - the system does not meet its LB / DB and cannot perform its intended function (affects redundant trains) i Level 2 - a single train of a redundant system does not meet its LB j and DB and that train cannot perform its intended function l i

i

Level 3 - a system does not meet its LB / DB but the system is i l

capable of performing its intended function i

Level 4 - a system meets its LB / DB however there are minor errors that do not affect the results of a calculation or there are inccasistencies between documents Jl3 sorwmc a Lurwsy==*

l l

t

Discrepancy Report Summary Number NU NU Resp. S&L Eval. More info issued Resp. in system Complete Needed Level 2 1 1 1 0 0 Level 3 297 233 130 28 24 Level 4 627 45F 379 187 28 TOTALS ~ 925 690 510 2'i o 52 sn yjent & Luewty'**

DR Submittal and Response Rate 1000 900 - i 800 -

700 600 500 _

400 300 , , _

200 -

~

7 100 _ _ _

0' , , , . . . , , , , . , , . . . . . ,

24. 7- 21- 5- 19- 2- 16- 30- 13- 27-Oct Nov Nov Dec Dec Jan Jan Jan Feb Feb DRs issued NU Responses S&L Reviews sarvent a L.urwsy*"

. iI31 i

i

l Discrepancy Report Summary l

- 211 Acceptable and Closed resolutions 111 Confirmed Discrepancies 42 Previously identified by NU 58 Non-discrapant conditions I

- 111 Confirmed Discrepancies 5 Level 3 106 Level 4

- 4 Pending Discrepancies 3 Level 3 1 Level 4'

~ n u .~. ..

pR Type & Level (Confirmed & Pending DRs)

Discrepancy. Type Level 3 Level 4 Calculations 4 29 Component Data 1 12 Corrective Actions 2 12 Corrective Action implementation 0 1 Design Change Process 1 1 Drawings 0 14 Installation implementation 0 14 5 Installation Regiurements 0 3 Licensing Documents 0 11 O&M and Testing implementation 0 1 O&M and Testing Procedures 0 6 Procedure implementation 0 2 Testing implementation 0 1 J3

i Preliminary Conclusions Effectiveness of CMP Configuration ~ management going forward

- Certain aspects of the modification process Programmatic issues

- Calculation control

- Radiological calculations 1

- - m . ...

STATUS OF A SAFETY CONSClOUS WORK ENVIRONMENT AT MILLSTONE Little Harbor Consultants Presentation to NRC Commissioners February 19,1998 L

N

/

STATUS INDICATORS FOR NNECo's SCWE IMPLEMENTATION EFFORT

[' g - World Class Acceptable for -

n Restart bw Yello Yellow Not Acceptable For Restart f Significant u ,N #

Weaknesses Trends: Improving : Steady u Declining

/

1

x /

STATUS OF NNECo. SUCCESS CRITERIA FROM LHC ATTRIBUTES NNECo Success Criteria Status l 1. Demonstrate the willingness to raise concerns.

Yellow 1

x <

FACTORS CONSIDERED IN GRADING ATTRIBUTE

1. Demonstrate the willingness to raise 3 Concerns. Yellow Positive Factors Negative Factors

- ERB Review Process

• December / January ECP

. MM Event Concerns

• Oversight Event MM Event

• Training Contractor Event

- Increased Recognition / Reward

/ \

J n';:.t * /

\ /

STATUS OF NNECo. SUCCESS CRITERIA FROM LHC ATTRIBUTES NNECo Success Criteria Status

2. Demonstrate that issues are being effectively resolved by line management. (Corrective yeiiow Action Program)

/ \

s STATUS OF NNECo. SUCCESS

. CRITERIA FROM LHC ATTRIBUTES NNECo Success Criteria Status

3. Demonstrate that the ECP is effective.

Yellow

/

j

. 3 FACTORS CONSIDERED iN GRADING ATTRIBUTE l

l

3. Demonstrate that the ECP is effective. ygg[

Positive Factors Negative Factats c Customer Satisfaction Interpersonal Skills 83% . Tinaly and Coordinated a Responsive to LHC Response to Potential Recommendations " Chilling Effect" a Demonstrated - 10CFR50.7 Analysis Independence . Incot.sistent Handling of HIR&D Allegations

/

N STATUS OF NNECo. SUCCESS CRITERIA FROM LHC ATTRIBUTES NNECo Success Criteria Status

4. Demonstrate that management can recognize and effectively ijks ; .

deal with alleged instances of jk$ ' ."m HIR&D, or other circumstances which have created a chilling effect, which collectively are referred to as problem areas.

/

j

l FACTORS CONSIDERED IN GRADING ATTRIBUTE l 4. Demonstrate that management can l recognize and effectively deal with $;)1!^j l

alleged instances of HIR&D ...

l Positive Factors l

• 50.7 Training - Organizational

- Partnership 2000 Effectiveness Consultants

- GET Upgrade - ERB Review Process

- ECP Input to MFNS - SCWE Resources

- Training Reorganization - Training Contractor

- Jan 20 - SCWE Training - RE Group Event

- MM End Results - QC Inspector Efforts

/'

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FACTORS CONSIDER'ED IN GRADING ATTRIBUTE

4. Demoristrate that management can ... .

recognize and effectively deal with h alleged instances of HIR&D ...

Negative Factors a Partnership 2000 Lacks - Oversight Event SCWE Timely Resolution of

- MM Event Problems

• Maintenance / Oversight - HR/ Legal involvement Relationship Dec/Jan ECP (HIR&D)

Concerns

/ e j

- b

n -

l SAFETY CONSCIOUS WORK

, ENVIRONMENT ATTRIBUTE STATUS i

LHC Expectation Status

1. Senior management endorses a policy that places priority on nuclear safety, supports the ej&

$h workers' rights to raise safety issues and ensures that workers will not be subjected to harassment, discrimination or

intimidation if they do so.

l l

N /

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

2. Employee perceptions of the policy and its implementation are favorable. y,, , ,

l

l - -

SAFETY CONSCIOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

3. Senior management provides training to all managers and supervisors to ensure that they y, , , ,

understand and employ good management practices when dealing with employees who have safety concerns and do so with understanding.

/ \

l

'N /

FACTORS CONSlDERED IN GRADING ATTRIBUTE 1

3. Senior management provides training to all managers and supervisors to y,iio ensure that they understand ...

Positive Factors. Negetive Factors a 50.7 Training .

Partnership 2000 Lacks a Partnership 2000 SCWE a GET Upgrade a ECP Input to MFNS a ECP input to Partnership i 2000 a Jan 20 - SCWE Training '

/ \

l

x <

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

4. Members of the workforce have a sense of identity and are committed to the publicly stated ,

goals and objectives of the -

Yellow organization, have respect for each other. communicate effectively both horizontally and vertically, and feel responsible for their own behavior. ~\

/

r

_ _ _ _ _ _ _ _ _ _ . a

/

\

FACTORS CONSIDERED IN GRADING ATTRIBUTE

4. Members of the workforce have a sense of identity and are committed yg g to the publicly stated goals ...

Positive Factors Negative Factors

- MM End Results - MM Event

- Organizational - Maintenance / Oversight Effectiveness . Relationship Consultants . Oversight Event

\

___ rr 2k

N ._/

SAFETY CONSCIOUS WORK ENVIRONMENT ATTR!BUTE STATUS ,

LHC Expectation Status

5. People at all levels of the _

organization treat each other with mutual respect. yg,,

- s

\

\ /

FACTORS CONSIDERED IN GRADING ATTRIBUTE

5. People at all levels of the organization treat each other with y,,,7 mutual respect.

Positive Factors Negative Factors a Organizationa! Lack of Trust Effectiveness Consultants

/ N L - -

/

p SAFETY CONSCIOUS WORK ENVIRONMENT ATTRIBUTE STATUS

_LHC Expectation

Status l 6. Employees exhibit a " ques-l tioning attitude" toward work

! and the work environment with ,

! respect to nuclear safety. Yellow i Positive Factors

- Sludge Assessment j = Recognition of Oversight Event l

a Structured Interviews l

a MM Event

\

___________________________-r . _ _ _ _ _ ___- _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ . _

N

/

SAFETY CONSClOUS WORK l ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

7. Poc!tive recognition is given to employees who identify safety issues. y, , , ,,

Positive Factors a Sludge Assessment a Catch of the Day a Oversight Event

\ /

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

8. Incidents leading to allegations of harassment, intimidation, 1

- g . g' retaliation or discrimination y[gg ";..

rarely occur, and management is timely and effective in taking action for resolution and prevention.

/ \

/

x FACTORS CONSIDERED IN GRADING ATTRIBUTE ,

l

8. Incidents leading to allegations of ,

harassment, intimidation, retaliation or Red' discrimination rarely occur, and management is timely and effective ...

Positive Factors Negative Factors ERB (10% Intervention) Dec/Jan ECP Concerns--

- SCWE Resources HIRD

- Nuclear Engineering and

• MM issue Support Activities - Manpower

- Training Changes - Oversight Event

- QC Inspector issue \

, A e A t~ q _

js -

SAFETY CONSCIOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

9. There is no evidence that an l

atmosphere exists that has a g

" chilling effect" on the yg, I willingness of employees to report safety issues.

x /

, FACTORS CONSIDERED IN I GRADING ATTRIBUTE l

9. There is no evidence cha'an atmosphere l exists that has a " chilling effect" on the y,igo,

! willingness of employees to report safety

- issues.

lI Positive Factors Negative Factors

! ERB Reviews -

Dec ECP Concerns (Fear

! - MM Event of Management) a Oversight Event - MM Event a Training Contractor Event M g

, - - , - - , , - - - . , -- ,n,-- , - - - . - - - . - - - - - . , . - - - - - - _ - _ - _ _ - - - . - - - - - - - - _ , - - - - -

k N /

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

10. An effective and efficient corrective action program is functioning and all employees y, , , ,

recognize the normal (and I preferred method) for addressing safety issues is through the line organization.

/

O

N /

SAFETY CONSCIOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

11. Senior management recognizes that some concerns may not be addressed through yg, the normal.line organization and has established an

[ effective] Employee Concerns Program (ECP) for handling .

such concerns.

N

FACTORS CONSIDERED IN GRADING ATTRIBUTE

11. Senior management recognizes ... 3 and has estaolished an ... Employee Yellow Concerns Program (ECP) ...

Positive Factors Negative Factors

- Customer Satisfaction Inconsistent HIR&D 83 % investigation

- Response to LHC Recommendations G;

/

s -

l SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

12. Independent and self- ,

1 assessments are performed periodically to monitor yg, performance and correct identified deficiencies.

N /

LHC ATTRIBLITES CONTRIBUTING TO NNECo SUCCESS CRITERIA 1 Demonstrate the willingness to raise concerns. l

2. Employee perception of SCWE... yeiir W

6. Employees exhibit a questioning attitude... yeire W

7. Positive recognition is given to employees... yeiir W

9. No evidence of " chilling effect"... yerio A W

12. Independent and self-assessments are yeiro A performed... ~

/ \

3

I LHC ATTRIBUTES CONTRIBUTING TO NNECo SUCCESS CRITERIA 4 Demonstrate that management can l recoanize and ... deal with ... HIR&D.

3. Senior management provides training to all venog managers ...

i 4. Members of the workforce have a sense of YeHoD identity and are committed to the ... goals ...

5. People ... treat each other with mutual respect. venor i

l 8. Incidents leading to allegations of HIR&D... rarely o c c u r...

RM k

9. There is no evidence that an atmosphere exists Y*"

j that has a " chilling effect."

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~ :s

1 a ... %,, UNITED STATES

[(.'?a7/l NUCLEAR REGULATORY COMMISSION Office of Public Aifairs

(+ v....*/ Washington, D.C. 20555 No. S-98-04 PUBLIC MEETING BY DR. SHIRLEY ANN JACKSON, CHAIRMAN U.S. NUCLEAR REGULATORY COMMISSION WATERFORD, CONNECTICUT February 2, 1998 C Good evening.

I would like to reiterate some points from the opening statement I made at this afternoon's press conference. Then I will answer questions that were solicited from established groups Letively involved in monitoring Millstone activities. Following these questions and answers, I will open the meeting for questions from the floor.

Before I begin, I would like to say that my being here tonight has nothing to do with any pre-established schedule, etc. I decided that It was time for me to come back and listen to you in person, again.

The licensee, and the NRC, have much work left to do before coming to the Commission for any formal decision on restarting any of the Millstone units. But, I would rather visit with you ea-lier, than later. If I, or the staff with me, cannot answer your concerns properly tonight - we will respond in writing after this meeting.

According to the tentative (and I repeat tentative - for planning purposes) time line, the Commission will have at least two Commission meetings before voting on Millstone Unit 3 restart. I have asked the Secretary of the Commission to

• block off" a portion of time during the Millstone Commission meeting which would occur prior to the Commission's fonnal vote on restart. The Commission plans to allow selected representatives from groups that have been monitoring Millstone activities to provide their views at that Commission meeting, i

W

T 2 g (PRESS CONFERENCE OPENING STATEMENT}

As you know, all three Millstone reactors are currently shut down because of safety concerns, and our concerns with respect to the pervasiveness of the licensee's non-conformance with regulatory requirements and the inadequacy of its corrective action programs.

They also are shut down because of issues related to an ineffective Employee Concerns Program which is important because employees must feel free to raise safety concerns without fear of retallation.

especially from management.

Millstone Unit I has beer, shut down for 26 months, and Units 2 and 3 have been shut down for approximately 22 months. All three of the Millstone units were placed on the NRC's Watch List in January 1996, as " Category 2" plants requiring increased NRC attention. By action of the Commission, the units were re-categorized as

• Category 3" plants in June 1996. This action necessitates Commission approval for restart of each of the units.

It was during niy last visit here, on August 6, 1996, that I informed the management of Northeast Utilities that before the Millstone Station reactors could restart, the NRC would require an independent cortective action verification conducted by an independent third party. As I said over a year ago, we initiated these measures because of NRC concern about licenseo management effectiveness in correcting problems, and the magnitude and acope of NRC findings as well as licensee identified deficiencies.

On October 24, 1996, the NRC issued a second order -- directing that before restarting any unit, the licensee develop and submit to the NRC a comprehensive plan for reviewing and dispositioning safety issues raised by its employees -- and ensuring that employees who raise safety concerns can do so without fear of retaliation. The order also directed the ifrensee to retain an independent third party to oversee implementation ! the licensee's plan.

In Nevenber, 1996. the Commiesion established the Special Projects office -- to provide for direct oversight of all licensing and inspection activities separate from NRC regional management, and to tailor and implement the NRC's " Staff Guidelines for Restart Approval" (the Manual Chapter 0350 Process), to specifically assess deficiencies at the Millstone Units.

Throughout 1997, the Commission has had " Quarterly Public Meetings" to assess the status of activities at the site. These meetings have included discussions with the licensee, independent contractors, and NRC stLff. The Commission is knowledgeable of the significant number of public meetings (about 30) held by the NRC staff of the Special

e 3 I

"rojects Office in the Waterford, CT area. The Commission has stressed the importance of taking the time and effort to ens,ure that the public remains fully informed.

The next Commission meeting is scheduled for February 19, 1998. This meeting was scheduled two months after the last meeting in order for the commission to better assess the results of some of the significant inspections that are occurring now, or that are scheduled for the near future. I have asked the Special Projects Office to-update the Commission on a more frequent basis as NRC inspection activities have increased recently. This is being done in monthly written reports.

I have reminded the NRC staff, and the licensee, not to be driven by schedule -- but by the primary task of determining whether the Millstone organization is functioning with the proper perspective and methodology for safe operation.

Aa I state at each Commission meeting, the Commission does not presuppose that any of the three plants will restart by any certain l date. I understand that plant employees are excited as they see what they believe is the light at the end of the tunnel. I understand the public anxiety surrounding the potential resta.rt of any of the units... anxiety that could be summarized with the following question:

"If they have had to be shut down for so long, how can I be sure that they are safe tc restart?"

The Commission is sincerely interested in -- and does

• hear" -- the public's concerns, whether they are expressed in the media, public meetings, discussions with the NRC staff, or in correspondence to the NRC. I am here this afternoon, and tonight at the public meeting, once again, to hear them first hand.

I spent the day touring the r' it, hearing assessments first hand from our inspectors, and meetir.g with plant employees, first line supervisors, as well as local officials and representativen from interested parties monitoring Millstone activities.

In summary, the NRC staff, and the Commission, are committed to ensuring that the Millstone Station is a safe station, with an effective Corrective Action Program, and an environment supportive of raising and resolving safety concerns.

Now - I would like to respond to questions solicited in advance.

Groups that have been actively monitoring Millstone activities were provided the opportunity to submit questions in advance in an effort )

to ensure that those groups have their important questions heard and

4 ,

addressed at this time. My staff informs me that the Nuclear Energy '

Advisory Council (NEAC) has been particularly involved in all aspects of tnis process: however, I thank you all for your interest'and participation.

NEAC #1) Among the root causes of the problems that have -lead to the current m:tuation at Millstone Station is shortcomings in the oversight and enforcament activity by the Nucleer Regulatory Commission (NRC) . The May 1997 Government Accounting Office (GAO)

Report on Nuclear Ragulation presents naple and specific evidence of the deficiencies and ineffectiveness of the NRC. What action has the NRC taken to address and correct the root causes that contributed to the shutdown of Millstone station, and how can we be assursd that the NRC will effectively ensure public health and safety and prevent the current aituation from reoccurring at nuclear power plants in Connecticut?

In respense to the events at Millstone and other related activities, the NRC conducted a broad-based review of NRC programs and guidance in the sreas of inspection, licensing, enforcement and licensee reporting. This review, referred to as the " Millstone Lessons Learned" considered, in part, Millstone and Haddam Neck inspection results, Millstone employee concerns review, the results of the fuel pool cooling and core off-load procedures review, and the results of Updated Final Safety Analysis Report (UFSAR) inspections conducted at all nuclear power plants. This effort involved individuals who were not part of the day-to-day oversight of Millstone, so that an impartial assessment of the situation could be obtained. This review was completed, and the Commission was briefed, last February.

A number of changes have already come out of this, and related reviews, aimed at strengthening our oversight and licensee performance of activities in each of these and other areas.

NRC managers currently responsible for review efforts associated with the Millstone Lessons Learned will be held accountable to take the actions necessary to ensure that weaknesses in the NRC's oversight activities have been addrested and that the lessons learned from this experience are used to strengthen the NRC's overall programs.

The GAO report of May 1997 provided three recommendations to the NRC for enhancing licensees' accountability. I responCad to the GAO's recommendations in a letter last August. I stated that the NRC had:

implemented a number of enhancements and (was) already working on a number of 1nitiatives that directly related to issues discussed in the GAO report. These actions included extensive evaluation and enhancement of the senior management meeting process, development and issuance of improved guidance regarding the content and accuracy of

5 each licensee's safety analysis report, and development of a process to improve the NRC management and verification of licensee ,

commitments. In addition, the strategies adopted in our strategic plan are aimed at correcting previously identified problems and findings in internal and external audit and investigative reports.

Let me provide more context in three areas. First, the Millstone

" Lessons-Learned" Review, and concurrent reviews of the use and updating of the Final Safety Analysis Report (FSAR) and of 10 CFR 50.59 (the very extensively used NRC regulation governing plant changes for which a licensee does not have to come to the NRC beforehand), at the Commission's direction, have been combined into an overall comprehensive review of these areas. The Commission has before it, and is acting on, a paper containing recommendations and options aimed at clarifying regulatory requirements, and strengthening our oversight of all of these areas. But changes already have occurred to strengthen our tracking of licensee commitments, to ensure the proper updating of each licensee's safety analysis report, to direct our inspectors to review the FSAR before inspecting a licensee's facility, and to be more vigilant to signs of a " chilling" environment, and to properly disposition allegations which come to us. Secondly, we have undertaken several explicit initiatives to strengthen the Senior Management Meeting to make it more objective, scrutable and fair.

The Commission has now tasked the staff to undertake a comprehensive and integrated review of our complete reactor assessment process and to cone back with a new paradigm that more explicitly and clearly lays out all of our regulatory requirements, inspects against them, assesses licensees' performance in the most objective way possible, and ensures that prompt, effective regulatory action is taken to l address the problems that are found, in a way commensurate with their l safety and regulatory significance. Thirdly, all of this is taking place ageinst the backdrop of a major reorganization of the NRC which the Commission approved one year ago. The nea structure groupo line regulatory programs in a way to enhance synergy and to help build in

! line accountability. We have created a new Regulatory Effectiveness I organization which groups and draws upon the strengths of the offices of Research, Analysis and Evaluation of Operational Data ( AEOD) ,

Investigation, and Enforcement, to allow the NRC to more properly track and trend licensee performance in key areas, to do this outside the day-to-day regulatory program areas, but to feed into them. We

, have a number of regulatory effectiveness and regulatory excellence l initiatives underway to strengthen how we conduct our business in all areas from inspection, to licensing, to enforcement, to the development of regulations. Finally, essentially all of our Senior Management Team is new, within the last year and a half. All of them are committed, and are being held accountable through performance l

l

6 standards and performance appraisals to ensure that our regulatory '

program works, and accomplishes its intended objectives, and,thereby engenders public trust. In fact, our new Executive Director for Operations, Joe Callan is here with me today. He has the responsibility to ensure that our day-to-day regulation is strong, and that the various initiatives underway come together to strengthen further our regulatory program. He and the management team he directs are committed to this.

In summary, the NRC has evaluated and assigned corrective action responsibilities, as necessary, and has taken other actions to uodress the shortcomings found by the GAO staff regarding the NRC's processes for licensee ovarsight.

NEAC #2. The volume of Deficiency Reports generated by Sargent &

Lundy at Millstono 3 is of serious concern, even though the number of Level 3 and high safety related itama has been relatively small. The findings of the Out-of-Scope Safety System Functional Inspection (SSFI) and their causes are equally troubling. What criteria will you/have you used to decide whethe; er not to expand either the Third Party Corrective Action Verification Program (ICAVP) and the NRC SSFI program. If no expansion has or w::11 be directed, how can we b.e assured that the NU CMP has and will protect public health and safety?

The NRC is fundamentally using acceptance criteria linked to conformance, or identified nonconformance, with the plant licensing / design bases for evaluating any possible expansica of ICAVP scope. The criteria lay out four significance levels being used by the NRC staff to categorize the ICAVP findings. Specifically, Levels 1-3 involve findings of nonconformance with the licensing / design bases, and Level 4 involves relatively minor findings which do not result in nonconforn; ~2.

The NRC staf f, at a ti.veting with the public last week, and, in recently-issued correspondence to NEAC, the ICAVP contractors and the licensee, recently has provided additional discussion on acceptance criteria, the findings and possible ICAVP scope expansion. The recent letter states that tha ICAVP oversight plan, as curr(7tly established, allows the NRC staff to make informed judgments based not only on an assessment of the individual issues, but also on the licensee's corrective actions for that issue including the identification of root cause(s) and causal factors associated with the issue, the proposed resolution of the issue, the applicability of the issue to other systems, and broader programmatic and operational issues. As such, an important element in the ICAVP process is the NRC staff's or ICAVP contractor's independent verification of corrective actions being taken by the licensee in response to ICAVP

7 findings. This independent verification of the adequacy of corrective actions results in additional ICAVP evaluations of the plant's licensing and design bases.

For example, even for Level 4 findings, which do not involve nonconformance with the licensing / design bases, the staff will evaluate them for any trends which might raise a question about the license / design bases and which should require additional ICAVP review.

The ICAVP, with or without any expansion of the original scope, must be judged as effective in confirming the plant's licensing / design bases before restart. If additional action by the licensee, the ICAVP contractor or the NRC staff is required to conclude, wito confidence, that the plant is in conformance - those actions will be taken before any Commission-approved restart.

NEAC #3. (a) What actions will the NRC take to ensure that the health and safety of the public is protected during the decommissioning of Connecticut Yankee? (b) Does the NRC intend to modify the existing regulations?

(a) The NRC will continue to provide significant oversight of the decommissioning at Connecticut Yankee. The resident inspector will remain onsite for the beginning of the decommissioning, and there will be specialist inspections performed by Region I, and Headquarters staff. We have a defined inspection program that covers all najor aspects of the decommissioning. Regional responsibility for the site is with a br-nch that is solely responsible tor decommissioning projects, - irther emphasize the importance of a safe and expeditious cleanup.

Contacts will be maintained with state and local groupe as the decommissioning proceeds.

(B) During recent public meetings, our regulations were criticized in that they do not require the opportunity for a hearing until the end of the process, when the licensee submits the License Termination Plan. The public wants a hearing earlier, when the Post-Shutdown Decommissioning Activities Report (PSDAR) is submitted. By regulation we must hold a public meeting within 90 days of receipt of the PSDAR, and accept public comments. Unless the NRC objects, the licensee can proceed with major decommissioning activities, at the end of this 90-day period. The public me$ tins is explicitly intended to allow public input with respect to the PSDAR. The hearing opportunity at the end of the process is meant to allow public input and appropriate intervention before the license is formally terminated.

8 There are no rulemaking changes being initiated by the staff at this '

time.

CAN #1) Given the fact that a reactor has suffered a partial melt down and you did not revoke its licenses given the fact that a l licensee has lied to the NRC and you did not revoke its licenses and now, at Millstone, you are faced with a situation of gross and systamic mismanagement that has been life threatening to the workers and the public, what will it take for the NRC to revoke a license to operate a nuclear reactor?

l I cannot spe k to all of the consiocrations that may or may not have gone into any earlier decisions with respect to possible license I revocation. However, the NRC would revoke a nuclear power plant license, if, in the opinion of the Commission, continued possession of the license would be inimical to the common defense and security or to the health and safety of the public. In other wcrds, the Commission would have to conclude that the licensee is not capable of protecting the public, in any plant condition, before a nuclear reactor license would be revoked. Normally, public health and safety can be adequately protected by ensuring a licensee maintains its facility in a shutdown condition until the significant problems are corrected (along with increased NRC oversight of the facility). Thus far, the Commission has not found it necessary to revoke a license of a nuclear reactor operator.

CAN #2) Little Harbor Consultants established 14 attributes associated with an effective Safety Conscious Work Environment. LHC believes that " requiring management action" is acceptable for the restart of the Millstone reactors even though NU has a decade long history of harassment and retaliation. A) Will you reject LHC's recommendation and hold Millstone accountable to meaningful requirements such as 9 meeting expectation?"

B) If you refuse to hold Millstone accountable to meaningful requirements, will you impose, so as to protect the health and safety of workers and the public, a 6 month dry-run period prior to start up for NU to damonstrate that they will not harass and/or fire workers who raise safety concerns?

The NRC believes the recommendations presented by Little Harbor are meaningful. Therefore, they will be an important part of the Commission's deliberations regarding restart of any Millstone facility. When the URC's October 24, 1996, order was issued, the NRC recognized that it would take a long time for employees to develop trust in a developing and evolving safety-conscious work environment (SCWE) and that it takes time for management to avoid the occasional errors and eliminate actions which may lead to a chilling effect. As specified in NRC's October 24, 1996, order, the Independent Third-Party Oversight Program (ITPOP) will continue to be implemented until

4 9

I the licensee demonstrates, by its performance, that the conditions that led to the requirements of the oversight have been corr.ected.

Factors for determining when this third party oversight program can be discontinued will essentially be the same as those required for restart of a Millstone unit except that sustained performanen, without intervention, will need to be demonstrated. Demonstration of sustained performance will be assessed using the continued findings of the third party, licensee self-assessments, performance indicators, and NRC evaluations. The NRC staff has anticipated that independent oversight will need to be in place at least six months following the restart of a Millstone Unit to provide a sufficient period to assess sustained performance related to a safety conscious work environment and a capability to handle safety concerns raised by employees and contractors. Following this initial assessment per4,od, there may be a need for periodic eva;uations by this or another third-party organization to assure that programs are maintained and that they are being effectively implemented. The licensee's current extended outage provides for an initial assessment period regarding l

implementation of the employee concerns program and establishment of a safety conscious work environment. Therefore, the NRC staff does not beliave an additional six month dry-run period is necessary to-I provide adequate protection of 9ublic health and safety. However, the Commission will weigh all factors presented to it with respect to employee concerns before it makes its final decisions regarding the restart of the Millstone units.

CAN #3) Given both the gross number of discrepancies and the two very serious discrepancies found when only 5 of the 88 reactor systems were inspected at Millstone Unit 3, will NRC incr6ase the scope of the Independent Corrective Action Verification Program and inspect additional systema?

The third party contractor has reviewed 15 of the 88 risk significant or safety-related systems as categorized by the Maintenance Rule.

Thus far the ICAVP contractor review has not identified significant issues at Unit 3.. Only one issue (a significance Level 3) involves a confirmed nonconformance with the plant's licensing and design bases.

All of_the other confirmed discrepancies have been identified as findings which are of minor significance and do not result in nonconformance with the licensing and design bases. Although these discrepancies, individually, are not significant, the NRC staff in assessing whether trends indicate that additional ICAVP review should be required.

i V

10 CRC #1) Regarding the on-going Department of Justice / Federal ' '

Bureau of Investigation, investigations into possible criminal i actions at Millstone, if that investigation is not completed prior to l restart, will the NRC at least establish that the investigation's .

scope does not cover current Millstone workers and management?  !

l The Commission has recedved closed briefings regarding the status of DOJ investigations. I will insist that the NRC staff make every effort to understand the status and scope of all investigations, as part of its assessment of Millstone restart readiness. This consideration would include an assessment of the significance and potential outcome of these pending matters, and their applicability to current Millstone management and staff, with a closed briefing of the Commission prior to any restart decision.

CRC #2) In a press conference at Waterford Town Hall on August 6th, 1996, you commented in your opening statement to the press that,

'a . . . the NRC had not always acted as it should have regarding the activities at Millstone." What assurances do we the public now have, that the NRC is new acting properly, and how has the NRC staff changed its way of doing business to assure you, and the other members of the Commission?

As I indicated in that same press conference, I stated that I am the agency spokesperson and its principal executive officer with the responsibility for ensuring that the NRC staff is responsive to Commission Policy, and overseeing and directing how it carries out NRC's regulatory program. As Chairman, I have taken action to strengthen the regulatory process, our organization, and management, as I described earlier. We have the regulatory tools necessary to ensure public health and safety. While I cannot guarantee you that there will never be another licensee that has pervasive non-conformance with regulatory requirements and severe inadequacies of its corrective action programs; I believe that the changes we have instituted should not allow this to happen. I can provide assurance that we have taken action to strengthen our regulatory effectiveness in Region I and throughout the NRC. I wil3 further assure you that not one of the Millstone plants will be allowed to go back on line until it is clear they can do so bafely.

Let me expand briefly on my earlier comments in this regard.

The NRC has initiated a number of actions and reviews aimed at improving the regulatory framework and developing comprehensive lessons-learned from Millstone. I have initiated changes to tha NRC process for evaluating licensee performance, particularly the Senior Management Meeting Process. We now have improveo performance indicators, which will be used to increase rigor and consistency in the SMM process. Based on Lessons Learned, I have instituted

4 11 i inspection program changes for the consistent reporting and categorizing of licensees' strengths and weaknesses. The NRC has reviewed inspector training requirements and completed a Job Task Analysis for resident and other region inopectors. I also initiated a comprehensive review of program and inspection guidance for oversight of the Updated Final Safety Analysis Report and nonconforming conditions related to this document (10 CFR 50.59 and GL 91.18). All of thi guidarce has been or is being changed and strengthened. Inspectors are or will be trained to them, as appropriate, and expectations to follow all new guidance have been made clear, and our staff will be held accountable to them. These are just a few additional examples of the improvements that this Commission has initiated to improve the regulatory process and to serve the public more effectively.

CRC #3) In the past the NRC has not enforced NRC regulations, and has selectively imposed violations on the licensee at Millstone, in an inconsistent manner. Could you please explain why the recent civil penalty of $2.1 million dollars is not selective enforcement, as many issues were not included in the description, and it only covered a period up to December 31, 1996? Pany violations have oc. curred in 1997, many are very substantial, and enormous amounts include repeat violations of the previous years issues. None include action against any individuals involved in retaliation, which even NU, Little Harbor Consultants, and your agency admit occurred.

The recent civil penalty was the culmination of many inspections over a lengthy period. The enforcement action was designed to focus on the very broad deficiencies apparent from these inspections rather than on all the known individual examples of the deficiencies.

Sufficient numbers of examples were included to justify the conclusions. Government agencies at all levels routinely make decisions on enforcement actions using prosecutorial discretion in order to arrive at an appropriate conclusion considering, on balance, the available evidence and the resources necessary to support the action. In the letter to the Millstone licensee accom Inying the associhred Notice of Violation, the NRC stated:

Finally, the violations described in the Notice are not the sum total of all apparent violations present or identified during the various inspections, but serve to represent the systemic nature of the significant regulatory problems existing at the Millstone facility. Other apparent violations described in the inspection reports referenced in the Notice are not being J addressed in this enforcement action. Nevertheless, they need to be considered as part of your corrective actions.

t 12 t The December 31, 1996, endpoint was an intentional decision made in '

order to permit the enforcement process to proceed. This did not mean that no further enforcement actions would be considered. In

fact, a $55,000 civil penalty-regarding physicai security violations was issued on June 11, 1997, for inspections conducted February 3-7, 1997.

The NRC is currently considering additional enforcement actions for other apparent violations identified in 1S97. For axample,' a predecisional en srcement conference was held on Jenuary 13, 1998 at the Millstone Training Center to discuss apparent vioints.ans identified during inspections conducted on August 18-29 and September 8-19, 1997. The extent that these may be repeat violari- will be considered, as always, in the enforcement process.

A number of alleged u.atances of retaliation and . .% nation remain under review by the NRC and, as such,.it i, .aappropriate to comment on them at this time. However, potential enforcement action

~

against individuals, a c, in all wrongdoir 7 matters, will be considered if the developed facts support such cc u.

I should also note that our most effective tool is the continued shutdown'of the Millstone units until the Commission decides that all the various problema and issues have been adequately addressed.

Friends #1) If an ICAVP-li,;e review were to be conducted at a SALP 1 nuclear facility, how would the results compare to the findings at Millstone Unit 3? What about a SALP 2 or 3 facility?

i Anything.I might say on this hypothetical case would only be speculation. Fowever, I-will point cut that the design problems at Millstone have resulted in an agency decision to conduct NRC design 1 inspections at other facilitias across the nation. Although these  !

, inspections are not as exten= Ave as the ICAVP effort at Millstone - l which is truly an extraordinary effort - our team inspections almost I always identify issues requiring corrective action by the licensee.

Our experience with these inspections indicates thag SALP ratings do not necessarily provide a good mechanism for correlating the extent ,

of design issues. Very often it is the age of the facility - with l older facilities having a greater number of inspection issues which l provides a better correlation.

This is very likely attributable to the fact that older facilities were licensed to earlier NRC requirements, and older plants have had more opportunities to mcdify - an3 possibly introduce errors into -

the design.

4

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3-13 k

The NRC 10 continuing to emphasize the importance of licensees maintaining their licensing and design bases, We also have, modified out inspection focus to give more attention to engineering and design issues.

Friends #2) Please characterise the safety significance of the findings /results discovered at Millstone Unit 3, whether found by NU or the NRC or it's coutractors. Was there a threat to public health and safety?

The safety significance of findings at Millstone Unit 3 varies. Some findings by both NU and NRC have a relatively high safety significance, in that they question the operability of the system or component (however, mostly during hypothesized design basis events) . 4 Examples include recirculation spray system desigP ' iiciencies, diesel generator operability during tornado conditzens, and component cooling system design temperature concerns. However, those findings did not involve a direct threat to public health and safety, but represent a compromising of mitigative features provided for a design basis accident.

Although the causes of the extended shutdowna for each of the Millstona units existed before the shutdown of the facilities, the NRC considers that the plants were operating safely before they were shut down because of the protection afforded by the defense-in 5epth philosophy. Stated otherwise, although there are safety equipment deficiencies at each of these units, t: e conservatism provided by the multiple levels of design and operating requirements reasonably assured that there was no undue risk to public health and safety.

However, the resulting reductions of the margin of safety led the staff to conclude that correction of the problems was called for before the_ restart of the plants. Additionally, the pervasiveness of the nonconformances and the significant programmatic weaknesses found warranted correction before plant restart in order to prevent recurrence of similar nonconformance problems, and in order not to have a situation, which if left uncorrected could potentially compound to cause a threat to public health and safety.

In addition tu findings having a re]atively high safety significance, many findings involving relatively low safety significance have been

' identified at Mi31 stone. Nearly all of the findings from the ongoing ICAVP reviews, being carried out by Sargent & Lundy at Unit 3, and Parsons Power at Unit 2, are minor errore (e.g., calculation errors) which do not impact the function of a safety system and do not result in nonconformance with the licencing and design bases.

m )

f 14 Friends #3) Are there generic (or specific) implications and effects '

of the Millstone issue across the nuclear industry? Kindly apeak to these implications if there are.

The NRC has initiated a number of actions and reviews aimed at improving the regulatory framework and developing comprehensive lessons-learned from Millstone. For example, the Commission issued a policy statement on " Protecting the Identity of Allegers and Confidential Sources," and " Freedom of Employees in the Nuclear Industry to Raise Safety and Compliance Concerns Without Fear of Retaliation." After issuing the 2atter policy statement, the i Commission directed the NRC staff to focus attention on cases of alleged discrimination where there are indications of a deteriorating safety conscious work environment.

As 1 diacussed in the previous answer to Citizens Regulatory Commission (question #2), I have also initiated changes to the NRC process for evaluating licensee performance; I have instituted inspection program changes for consistent reporting and categorizing licensees' strengths and weaknesses; and I initiated a comprehensive review of program and inspection gu; dance for oversight of the Updated Final Safety Analysis Report and nonconforming conditions ,

related to this document (10 CFR 50.59 and GL 91-18). This is occurring against the backdrop of t!.e organizational and management changes I have already described.

Regarding generic communication to lirensees, the Commission approved the issuance of 10 CFR 50.54 (f) letters to all Chief Nuclear Officers requiring them, under oath or af f.i rmation, to uubmit detailed h

information regarding the adequacy and availability of design bases y

, information at their facilities. The purpose of the request was to provide NRC added confidence and assurance that all licensed plants are operated and maintained within the design bases - and th-t any devie" ions are reconciled in a timely manner.

These are just a few additiona? examples of the .mprovements that this Commission has initiated to strengthen improse the regulatory process and to serve the public more effectively.

Thank y22 for listening to these questions and answcrs. I thought they were all very good questions, some of which I have asked the staff myself.

Now, -- very briefly - I would like to highlight two additional questions that I want to make sure get addressed up front.

1

q 15 How can you even consider allowinr a plant to start-up with (quote)

'5000 open iteam" (unquote)? ,

and If there is additional enforcement taken, isn't that indicative of the need for additional inspection, scope expansion, etc.?

i Regarding open items...

The question of the size of the Millstone backlog is a concern to the NRC and is being taken very seriously. Although backlogs, at restart, are expected, historical problems at Millstone have included corrective action programs that were weak in ensuring comprehensive and effective corrective actions. In the past, narrowly focused corrective actions have failed to resolve all aspects of the underlying problem. Additionally, the failure to follow up on corrective actions did not ensure effectiveness.

Since the licensee has a history of not being effective in implementing corrective actions, the NRC has been closely monitoring the remediation efforts of NU to vitalize the corrective activt.

.procass over the two year shutdown period. The NRC identified, in the Restart Assessment Plan (RAP) , the corrective action process as one of the fundamental elements of the recovery of the Millstone Station.

The specific question of which corrective actions would be proposed for deferral until after restart was addressed in an NRC demand for information (10 CFR 50. 54 (f)] letter. The information requested included: (1) the list of significant items to be completed before restart; (2) the list of items to be deferred until after restart; and (3) the process and rationale Northeast Utilities (NU) is using to defer items until after restart.

The proposed deferred items are being inspected by the NRC. Thus

'far, the NRC has carried out twc inspections, in July and October 1997, of the licensee's proposed deferred items list. The inspections include evaluat'an of the licensee's process for identifying deferable actions and for carrying out the corrective actions, including the timing of these actions, to ensure they are adequate and esmmeasurate with the safety importance of the issues. As a resuls >

, the inspections, the licensee has implemented several changes. The NRC staf f will to carry out a7other inspection of the Millstone Unit 3 lists, prior to any recommendations to the Commission for consideration of restart.

Additional insights will be gained using NRC Inspection Procedure (IP) 40500, " Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems," inspecting closure of the

i 16 Significant Items List issues, monitoring closure of licensee event t reports, and through the normal inspection program. Also, the NRC, through oversight of the ICAVP, will assess the licensee's corrective actions for degraded and nonconforming cuaditions. The operatioral Safety Team Inspection (OSTI) will also audit portions of the corrective action process. The NRC expects that the licensee will correct all safety significant areas of noncompliance before restart.

At present, the number of .tems proposed for deferral at Millstone Unit 3 is a 3arge number. Despite all of the NRC activities, which are not yet complete, it is my intention to focus the Commission 's attention on the backlogs at Millstone because of the large number and the licensee's history. Even if the Commission determines that the items are appropriate for deferral, the close out of deferred items will continue to be evaluated even after restart. In addition to routine inspections, special NRC inspections may be utilized to assure that the backlogs are being reduced. The Commission also has at its disposal a number of other regulatory tools. The Commission, for example, can and will ..nsider taking stronger action such as an l Order directing specific at .ons of the licensee to resolve these I

deferred items, including the timing of these actions.

Regarding potential enforcement...

t The bases for an escalated enforcement action, resulting from an L ICAU finding, may also result in an expansion of the ICAVP scope.

The NRC's enforcement policy, which includee safety as well as programmatic factors, details examples where escalated enforcement would likely be taken for the types of issues specified in ICAVP Significance Levels 1 and 2. Such issues involve relatively high safety significance. As a rer. ult, for ICAVP Levels 1 and 2 findings, both escalated enforcement and expansion of ICAVP scope would be expected.

ICAVP findings categorized as Significance Level 3 - which are of lower safety significance - may also be the subject of escalated enforcement due to their programmatic or regulatory significance.

For such findings, the ICAVP process requires an evaluation, including independent verification of licensee corrective action by the NRC, to determine the need for any expansion of ICAVP scope. A negative determination by the NRC on effective licensee corrective action would be expected to result in a decision to expand the ICAVP scope, j

D 17 i

Now --I will take questions from the floor.

If you would like, please identify yourself -- and also I ask you to please understand, as Mr. Sheridan has already stated, if we have to move things along in ah attempt to hear from as many people as possible.

j v' N UNITED STATES r -

NIJCLEAR REGULATORY COMMISSION 5 WASHINGTON. D, C. 20555

• 5 OFFICE OF THE ebruary 24. W SECRETAHY NOTE TO: DCS EDR

SUBJECT:

Millstone Briefing Transcript (dtd 2/19/98)

Please add the attached document "S-98 Public Meeting by Dr. Shirley Ann Jackson, Chairman, U.S. NRC, Waterford, Connecticut, February 2, 1998" to the Transcript package I sent you yesterday. It was a hand-out at the meeting that was inadvertently left out of the Transcript package.

Thanks - Darlene Wri6 ht

Attachment:

As Stated l

l l