ML20138D606
| ML20138D606 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/03/1997 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20138D595 | List: |
| References | |
| NUDOCS 9705010178 | |
| Download: ML20138D606 (126) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
4 i
. PRESENTATION OF RESTART READINESS PLAN b- by MAINE YANKEE ATOMIC POWER COMPANY Y
Maine Yankee Atomic Power Company Energy Information Center Wiscasset, Maine Thursday, April 3, 1997 9705010178 970418 7 PDR ADOCK 05000309 T PDR ,1 THE REPORTING GROUP
. Mason Lockhart Hagopian & Ramsdell N
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4 NRC STAFF: l
! Richard Conte l Charles Hehl f
. Daniel Dorman j John Zwolinski i- William Ruland Jimi Yerokun l d (
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i MAINE YANKEE REPRESENTATIVES: !
t Michael.Sellman Daniel Keuter l
- Michael Meisner l 3 Graham Leitch !
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THE REPORTING GROUP l Mason Lockhart Hagopian & Ramsdell j i
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(" 1 PROCEEDINGE [2:30 P.M.]
V]g 2 MR. CONTE: Good afternoon, ladies and l
3 gentlemen. I'm Richard Conte. I'm the Chief of Reactor 4
4 Projects, Branch No. 5. Bill Hehl has some opening 5 remarks to discuss the purpose of this meeting.with 6 Maine' Yankee on the licensee's Restart Readiness Plan. i
~
'7 Let me begin to introduce the staff here. All the f I
8 way to my right is Dan Dorman, the Project Manager for i
9 Maine Yankee. He works-for the Office of Nuclear ;
10 Reactor Regulation, and he is a member of the Maine l 11 Yankee Assessment Panel which was just forned. You'll 12 hear a little bit more about that during the course of 13 the day.
14 Coming closer to me is John Zwolinski who is the 15 Assistant Director in Reactor Projects, also in the 16 Office of Nuclear Reactor Regulation, overseeing the 17 licensing process for Maine Yankee.
18 To my immediate right is Bill Ruland who is the
- 19 Chief of the Electrical Branch in the Division of 20 Reactor Safety, Region I; and he is a member of the i
l 21 Assessment Panel. ,
22 Myself, I am the panel leader; and also my normal !
1 23 function is to oversee the inspection program at Maine 24 Yankee and Vermont Yankee and currently Pilgrim which is .
25 being transferred to another branch in a couple of l
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell l
4 O 1 weeks.
U 2 To my right is the Division Director of Reactor 3 Projects -- that's the other right -- to my left is Bill 4 Hohl'who is the. Division' Director of Reactor Projects; 5 and he is the oversight manager for the panel.
6 To my left is -- further.left.is Jimi-Yerokun; and 7 he is a member -- he is the senior resident at Maine 8 Yankee and also a member of the panel.
9 MR. HEHL: Why don't we go ahead and let Maine 10 Yankee introduce the folks.
11 MR. CONTE: Okay. Let me just get the staff in the 12 back here. Rick Rasmussen is the resident inspector for 13 Maine Yankee. Gene Gunthrie is reactor engineer for O 14 Project Branch 5 in Region I. And Cliff Anderson is the 6
~
15 technical assistant for the Maine Yankee Assessment i 16 Panel.
17 At this point I'd like the members at the table for
! 18 Maine Yankee to identify themselves, and we'll come back i 19 here for Bill Hehl's opening remarks.
22 To my right is Dan Keuter. Dan is going to make I
- 23 the presentation today. Dan is the author -- principal ,
24 author of the Restart Readiness Plan.
25 To my left is Mike Meisner, vice president in THE REPORTING GROUP
- Mason Lockhart Hagopian & Ramsdell
5 l
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,r 1 charge of licensing. And to Mike's left is Graham i
2 Leitch, vice president in charge of operations. We have t 3 several members of our staff nearby to help us with l
{
4 questions that come up. ;
5 MR. HEHL: Okay. Let me -- I'll be very brief.
6 The purpose of the meeting here today is a -- is a 7 meeting between the NRC and -- and the folks from Maine ;
I 8 Yankee basically to get a -- an overview presentation of :
9 the Readiness Restart Plan that they submitted to the --
t 10 to the NRC with their letter of March 7th, 1997. !
11 Certainly we're continuing to review that plan; and l 32 really I think what we want to try to accomplish today I 13 is to get a better understanding of the -- of the O~ 14 overall plan; and I think we'll probably be asking 15 questions to get clarification. But certainly --
t 16 certainly the interest is ensuring that the scope of the 17 plan is sufficient to cover the issues I think that -- l 18 that are on the table before us. The specifics of the 19 plan we'll be looking at over a period of the next .
20 several months with particular focus on the 21 implementation of the various aspects of the plan.
22 So with that -- and also we'll be -- we'll be 23 looking at some of the details on the specifics of the 24 confirmatory action items and some of the other outage- ,
25 related work that's ongoing.
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell l
6 l 1 But with that, we turn the meeting over to you.
2 MR. CONTE: One further -- excuse me, before we go j i
3 to you, Mike, I just want to go through a few ground 4 rules for the meeting. And that is this meeting is..
5 between Maine Yankee and the NRC and subject to.public ;
6 observation only. -There will be no participation-from r
7 the audience. It is being transcribed, and that 8 transcription will be docketed. There is a meeting l 9 tonight at 7 o' clock at the Wiscasset Middle School to j t
10 receive public comment. :
r 11 It's our understanding that the licensee's prepared 12 presentation will be about an hour. But we will be ,
e 13 asking questions during the-course of that, and.f_t may 14 go an hour or two. Hopefully, we'll be finished about 15 4:30 or 5:00, but we're not restricted to time at this i l
16 point. )
17 Most of the -- it will be a question and answer 18 forum; and there may be some unanswered questions which 19 we may formally submit in a letter subsequent to this 1
20 meeting. And representatives of the state government 21 are here but are in the audience for observation only at 22 this point, at their request.
23' With that, I'll turn it over to you, Mr. Sellman.
Thanks, Rich. I'm going to make some !
24 MR. SELLMAN:
25 very brief introductory comments. Then I'll turn it i
THE REPORTING GROUP l Mason Lockhart Hagopian & Ramsdell l l
7 4
1 over to Dan for the meat of the presentation.
2 We're here to discuss our Restart Readiness Plan, 3 and this is the issues and actions that we feel are-4 necessary for us to take part in the restart.- The plan ;
- 5 itself is comprehensive and comes at the issues of Maine 6 Yankee from three different directions. We're going'to ,
) 7 look at the plan through system assessments. We're .
8 going to look at processes, procedures and programs t
9 through programmatic assessments, and we're going to ;
10 look at people through department assessments. ,
J :
11 Actually, the restart plan is one part of an 12 overall improvement plan which has three phases to it.
I 13 Phase 1 is the restart plan, those actions that-we 14 believe must be taken prior-to restart. We have a lot 15 :of other actions that will be taken in a short term.
16 That will be Phase 2, something within the order of six
^
17 months after restart. And then over the next few years 18 we'll be implementing improvements through our business 19 plan process.
20 As I said, this is really part of our improvement 21 plan, so it's to our benefit. It goes beyond regulatory 4
22 requirements. We're going to be focusing on long-term, 23 sustainable improvements. We're going beyond the NRC 24 restart guidance. We intend to address both known 25 issues and through intrusive looks at the plant find THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
8
(~ 1 other issues and address those as well. The criteria
\
2 also go in our opinion beyond the regulatory compliance 3 , requirements. The plan evaluates the extent of 4 condition, and also resolves underlying causes 5 associated with it.
6 With that very, very brief introduction, I'm going ,
7 to turn it over to Dan.
8 MR. KEUTER: Thank you, Mike.
9 What I would like to do is step through the plan.
10 The first part of the plan is -- there's 10 sections 11 that lay out how we do business in the plan. And then 12 there's an appendices which really has the eight major 13 significant issues that we want to resolve for restart.
())
Q.
14 So I'll spend about half the time talking about the plan 15 itself and then spend the other half of the time really 16 talking about the major issues which is where the meat 17 is.
18 The purpose of the plan obviously is to identify 19 and correct any deficiencies or improvements with the 20 plant, whether it be people, programs or the plant 21 equipment itself. It's based on previously approved NRC 22 restart plans from several different plants. We tried 23 to take the best out of each of those plans and put it 24 into our plan. It's also based on the NRC Guidelines
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25 0350 for restart, but the main thing it's based on are THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
9 the specific issues applicable to Maine Yankee.
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2 There is.a section in'there on background which is 3 basically the background of how we got to where we are.
4 It's just a summary'of events over the last year, and I 5 wasn't going to cover it in any detail.
6 The organization is really in two parts. We have 7 the normal -- coming down, the overall responsibility 8 for the organization is under Mike Sellman as president, l
9 comes down to Graham Leitch who is the vice president of i 10 operation, and he has overall responsibility for the ,
l 11 restart plan, both the physical work and the 12 assessments. Coming down this side we have the plant 13 manager, and he is responsible for, you know,:the normal ]
2 14 operation of the plant, whether it be an outage or 15 non-outage; and he is responsible for the physical-work ;
16 that comes out of the plant. Coming down this side is ;
17 the restart manager, myself. And we have two 18 subcommittees, the restart subcommittee chairmen that i
19 look at -- one is dedicated to looking at the hardware )
20 issues, assessing those, and then verifying that we're 21 ready for restart, and another program manager that is 22 looking at the software of the programs and the people 23 and verifying that those are ready.
24 Some of these issues, you know, for example, they
/~%i 25 might look at twice. For example, you know, the us I j THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
10
(~'N 1 hardware committee might -- like, if there is a learning N] 2 bank issue on a MOB, they might look at it as a hardware 3 issue. The same issue might come over to the software 4 committee, and they look at it as a programmatic issue.
5 So some of these things will be touched on twice, and 6 our whole intent here is to look at it from different 7 directions to make sure we cover the issues.
8 MR. CONTE: Excuse me, Dan. Are all the managers 9 on this chart in place? I know you're still staffing 10 people.
11 MR. KEUTER: This is in place. We actually got 12 this in-place before we submitted the plan. The 13 subcommittees have been operating now since the first of
(~%
%-] March; and we've -- the restart subcommittees here have 14 15 been meeting -- they meet three times a week. They have 16 been for several weeks. The steering committee meets 17 twice a week, and again they've been meeting for several 18 weeks. And the plan is actually in place and working, !
l 19 and we had it up and going even before we submitted the j 20 plan on March 7.
21 MR. HEHL: At some point in time are you going to 22 talk about the level of oversight that exists between 23 the restart steering committee and the individual 24 hardware and non-hardware oversight groups?
(N 25 MR. KEUTER: This is probably a good time to talk b
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
11 1 about it. I have another section on oversight, but we 2 can go ahead and talk about it now. ,
3 Basically, what happens is the restart steering -
4 -committee assessses the overall direction for the 5 restart. It's a senior level committee with vice 6 -
president and senior management levels. They oversee 7 not only the two subcommittees but the physical work.
8 The subcommittee chairmen come into our Tuesday steering 9 committee meetings, give briefings on 10 where they are in each of the subcommittees. Also I 11 members -- for example, myself, I'm on the steering 12 committee -- will oversee and attend certain meetings 13 and judge for themselves where they're going. >
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14 For example, next week, next Tuesday, the full l l
15 . subcommittees are going to meet in a combined meeting )
16 with the steering committee and go over any open issues 17 or directions that are concerns at that time.
18 So it's.all three committees are living committees, 19 and they interface all the time.
20 MR. ZWOLINSKI: Dan, maybe you could address the l
21 role and responsibility of each of the three 22 committees. I'm trying to distinguish fundamentally I
23 were the hardware committee to take an action, review I 24 it, disposition it, then what would then be the role of r~h 25 the restart committee if the issue is in position or if U
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
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("' 1 .it's not? Does the restart committee see everything, or b 2 does it stop with one of these subcommittees? I guess 3 I've asked a number of questions if you can talk through 4 that.
5 MR. KEUTER: Why don't I go through the 6
presentation because I think I'm going to explain that 7 in a little more detail when I get to the flow chart of 8 the process. If I don't answer it then, make sure you 9 ask tne question again.
10 The major elements here, I think this would be 11 better if I showed it graphically; and I'll also try to 12 answer your question.
13 Basically, feeding into the restart committees are 14 the known issues. These are identified at the top.
15 These are the issues that came out of the confirmatory 16 action letter. These are the issues that came out of 17 the ISA and NRC inspections. They are the issues that 18 came out of the 50.54(f) response. Plus any other 19 issues since, employee evaluations, steam generator 20 inspection, any other issues that are self-identified 21 will feed into the subcommittees.
22 Also, we are out there -- and these are the known 23 issues; but we're also out there doing assessments of 24 equipment and we're doing assessments of the programs on I)
b 25 people. Now, these assessments here initiate and funnel THE REPORTING GROU?
Mason Lockhart Hagopian & Ramsdell
13 {
1 through the different subcommittees. All the equipment
( 2 issues will be first reviewed by the equipment l
3 subcommittee. They're looking at all the work orders.
4 They're looking at all the -- for example, the :
5 maintenance rale A.1 system, anything having to do with i 6 'the hardware.' They're looking at operator .
7 work-arounds. They're taking a review of that, and then 8 they're feeding that information back up to the steering ,
L 9 committee. f 10 The same thing over here. The non-hardware !
11 committee is looking at people and programs. They're 12 looking at the learning bank backlogs. They're looking
13 at the department assessments that we're doing. They're 14 looking at the program assessments that we're doing.
15 -And-again, they're feeding that information back into 16 the steering committee here.
17 So what the -- what we have is a multiple barrier
- 18 here. We have the initial reviews being done down here, 19 and they're being reviewed by the steering committees as 20 they feed that information back up.
21 MR. ZWOLINSKI: What's the direction that you've 22 provided as far as the folks that do the initial 23 review? Do they prioritize these items or --
24 MR. KEUTER: What they do is they compare it to the l l
. 25 restart criteria, and I'll talk about it a little bit THE REPORTING GROUP ;
Mason Lockhart Hagopian & Ramsdell ,
1
14 1 more here. But they're screening the things to see if 2 they're required for restart. And there's two parts to 3 it. Is it a safety or operability concern; or is it a 4 regulatory requirement -- you know, requirement that 5 will require us to be done for restart. So we have 6 specific criteria that they're using to screen issues or 7 potential issues and then deciding whether it's required 8 for restart or not.
9 Now, as far as doing the department assessments, 10 doing the system assessments, doing the program 11 assessments, we have specific guidance and checklists I
12 that they go through; and those are in the attachments.
13 And what they'll do, you know, through the 14 committees, the combination of the subcommittees and the 15 committees, they'll decide what issues -- they'll l l
16 basically put them into one of three phases. If it's a 17 restart issue, it will go into Phase 1. If it's an 18 important issue but not required for restart, it will go 19 into the shcrt-term plan which basically we want to 20 accomplish within six months after restart. Or_it goes 21 into Phase 3 which is our long-term plan or our business 22 plan.
23 There's three ways we track that. We have the 24 major issues that are in the appendices. We have the 1
'T 25 hardware issues which are being tracked by our work J
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
t 15
/'s 1 order list, and/or non-hardware issues which are being 2~ tracked by our Learning Bank action tracking system.
I 3 So what we're trying to do is not inventing 4 anything new. We're using existing systems to work off 5 the work, too, whether it be a work order, whether it be 6- ~ a procedure change. We are using our normal systems. :
7 So what we're doing is -- is supplementing through the 8 restart committees and the restart organization our f 9 existing organization and -- and going through the !
10 backlogs of issues that we have, known issues, and also
! 11 assessments to find any unknown issues.
12 Once an issue is complete, it comes down through a
l
/^N 13 its normal management approval; and it's accepted U 14 there. And then it goes through one extra step which 15 'would be the subcommittees or the steering committee.
16 For example, all the major appendices are really going 17 through, you know, the subcommittees and the restart 18 steering committee. Some of the minor work orders will 19 mainly only be going back to a steering committee; but 20 they all won't go back to -- I mean through the 21 subcommittee. They all won't be going back through the 22 steering committee unless there is a major issue.
23 Now, if there's any questions at any time, you 24 know, the subcommittees come back to the steering
/~N 25 committees just like we're going to do next Tuesday to THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
16
/~'s 1 make sure everybody is in agreement of which things are U 2 restart or non-restart or if.the corrective actions are 3 adequate. {
4 Then we go back to a final review, which I'll talk 5 about in a little bit more detail, but to make sure that 6- 'everything -- an integrated.reviewerilooks at: people, 7 programs, management, makes sure we're ready to go.
8 Then we go through a step-by-step phase power ascension 9 program similar to the program that we did coming out of 10 our steam generator outage, sleeving outage.
11 MR. HEHL: I guess you're using a number of the 12 existing processes that -- that -- I guess the question
("% 13 that I have is what have you done to assure.that there i
14 is a level of confidence in those existing processes to 15 - .to accomplish this?
16 MR. KEUTER: Well, one of the things we're doing is 17 our program assessments which is our existing 18 processes. We want to make sure those processes are 19 adequate. The two main processes that we're using is 20 our work order process and our Learning Bank-process.
21 We've just gone through a complete reengineering-of our 22 learning bank process. You know, it's a good process.
23 It's a little bit more cumbersome and complex than what 24 we'd really like to have for the long range. But it's a
~
25 good process and has a good tracking system. And it's THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
. . . . .. . - . . - . __. - .~ . _ _ _ ._. --
17 1 something that's always going to improve. The same
/'
( 2 thing with the work order process. It's a good 3 process. It's a little bit more cumbersome than we want
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4 long-term, but it's a good process.
5 We're going through and identifying the major 6 ' programs and> processes,-and:we're assessing those :-np .
7 programs and processes.
8 MR. HEHL: Okay. But that's being done in parallel r
9- with the ongoing work?
i 10 MR.'KEUTER: Correct.
11 MR. HEHL: So I guess the question is how are you 12 going to address, you know, a level of confidence when 13 you have a parallel review going of the program itself 14 and then a parallel hardware activity at the same time ]
15 it's-utilizing those processes?
16 MR. KEUTER: Well, that's one of the reasons we're l l
17 having -- you know, supplementing our organization with l 18 a restart organization. We're adding extra checks and 19 balances into those existing programs and processes just 20 like we're adding an extra step here to make sure we're i 21; not relying on the process itself.- We're 22 adding another barrier here to make sure that those 23 processes -- that the physical corrective action is the 24 one that we intended. I rT 25 MR. MEISNER: Can I add something to that?
D THE REPORTING GROUP i Mason Lockhart Hagopian & Ramsdell I
18 1 MR. HEHL: Sure.
[~]'
O 2 MR. MEISNER: Yes, we're using existing processes; 3 but we're using them primarily as a tracking mechanism.
4 So the Learning Bank which is our corrective action a
5 process will contain an individual item. But the 6 process that really deals with the significance of that 7 item is -- has been overlaid on top of the learning 8 process. And that's what Dan is describing, and it's 9 something new and in addition to the existing process.
10 It's the criteria that he'll talk about in a few minutes 11 that determines whether or not something is a restart 12 issue, short-term or long-term. And it's these
/N, 13 subcommittees that provide a level of intrusiveness and
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14 rigor in evaluating those things and ensuring that 15 they're implemented.
16 So in some sense we're using the existing processes 17 but as a convenient tracking mechanism. In another 18 sense we've overlaid it with quite a bit more to ensure 19 that the items that flow through the process are 20 addressed correctly.
21 MR. CONTE: Is there a documented review of the 22 work order process and the learning process to 23 say -- that leads you to this conclusion that it's --
24 they're viable systems to be worked in parallel with l
(N 25 these other measures?
't THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
i
' 19 .
I 1 MR. MEISNER: I guess that's what I was trying to -
2 say,. Rich, that there will be a documented review; but 3 to the extent that we're relying on those processes as a 4 tracking system, a data. base,,something that will..tell !
5 us an item exists; and we'll be able to enter its status 6 in this data base as-we go along. But.it isn't-those L 7 processes that drive resolution of *.hese items, nor is l 8 it those processes that drive the evaluation of the 9 significance of those items. It's the -- it's the new i; 10 overlay that Dan is describing here that ensures that 11 happens.
12 MR. HEHL: Why don't we go ahead and let them go 13 into -- maybe they'll answer some of those questions,-as 14 we go along. Certainly, the intrusive aspect of these, 15 we'll be interested in hearing how they're going to 16 acco=plish that. ;
I 17 MR. KEUTER: One of the issues that we want to l l
18 address here, as Mike said, is the extent of condition. !
19 And we want to not only look at these specific issues.
20 We want to see if that specific issue has any generic 21 implications or makes cure we're getting all -- you 22 know, any common causes. So again we're taking the {
23 known issues up here. We're looking at the root causes 24 that come out of those known issues. We're seeing -- i l
25 looking at the causal factors associated with those; and THE REPORTING GROUP .
Mason Lockhart Hagopian & Ramsdell l l
I
- ._ - - - . - ~. . . . - . - _. -
20 j
1 then we're coming down and doing an extent of condition
-s ~
2 analysis. !
- 3 Some of the things we ask, you know, as we pull-the 4 strings on someoof these, is-if this was a programmatic i
,5 issue, for example, on cable separation, do we have a 6 similar. issue on MOB's'or similar issues'on other (
7 things? And based on that, then we'll go back around 8 and either do additional assessments if it's a people or ,
9 a program issue or if it's an equipment issue, ask -- [
d i
10 pull those strings again and feed it through here to j 11 make sure we've identified all of the important safety ,
12 issues, not just those that are peeking above the i 13 water. So this ia our extent of condition.
\
14 We've gotten -- you know, we're already into this 15 process. I can give you some preliminary results; but I 1
16 really want to -- and it's similar to what Hub said the l l
17 last time he was here -- is, you know, the extent of 18 conditions really are in the nuclear culture of the 19 organization. What is nuclear culture? What does 20 nuclear quality look like? And really what it looks 21 like is it's a management system, and it's a 22 defense-in-depth system to ensure that adequate barriers 23 are in place to prevent bad things from happening. ,
i 24 I tried to visualize here what those barriers are.
25 The primary barrier at the top is your plant equipment.
, THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
I 21 i
i
/ 1 Is your plant equipment properly designed, maintained?
2 Does it have the proper material, proper construction?
3 That's your primary barrier. ,
l 4 In addition to that'you have the administrative- {:
5 controls. And this determines how you do the work ,
6 .within a nuclear power: plant; and.these are all your t
7 administrative procedures, your programs, your standards >
8 all determine how you do business.
i 9 You have your specific procedures which are your j r
10 specific step-by-step instructions on how you do l 11 physical work out in the plant. And this goes all the {
12 way from work orders to test procedures to detail 13 procedures to emergency procedures, all of those 14 technical procedures of how you do a specific test out [
15 in the plant. In a nuclear power plant you have .
16 licensed operators. Anything that can affect the 17 nuclear safety or plant reliability goes to the i t
18 centralized control room. You have licensed operators 19 that maintain that control room. They make sure that !
20 they have adequate equipment, status control. They l l
21 monitor the equipment to make sure that one event !
22 doesn't interfere with another event. But you have your j 23 centralized control room there as a barrier, i
24 You have your first-line supervisors and 25 oversight. They're out making sure that we're following i
THE REPORTING GROUP !
Mason Lockhart Hagopian & Ramsdell l i
~. . _ _ _ _ __ ._ _ _ _ _ ___ _ . . _
22 1 the procedures and making sure we have good work 2 practices, proper work environment. l
~
3 Your next barrier is your workers, you know; and
! 4 that's -- your next-year equipment is your next best l 5 barrier. And here are your workers properly. trained, i 6 motivated, usings good work practices? :Self-checking 11s 7 your -- you.know, your next best barrier.
8 And in some cases you have additional barriers if ,
t 9 it's an important evolution. You have a separate from ,
I 10 the normal chain of command that you normally have 11 independent reviews. This goes from independent 12 verification, QC, radiation protection, post maintenance 13 testing, anything that independently verifies that 14 whatever you did up here is working. i t
15 What you don't see here is management, and that
- 16 reason is management is over here. Their responsibility 17 is to ensure that you have adequate barriers in place 18 and working. That's their role. And they have several j 19 organizations that help them do that. They have their 20 engineers, their technical organizations that make sure 21 you have technical input into your barriers including 22 your equipment, administrative controls, your 23 procedures, your training. And you have an engineering 24 organization that helps management do that. You have 25 your nuclear safety or QA organization, licensing
(}
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
23
[
() Again, their job is independent eyes and i 1 organization.
2 ears out there to make sure these barriers are in place J
3 and working. You have your' training organization. Four
'4 of your seven barriers are-people.- So you have to +
5 ensure that your people barriers are properly trained, 6 qualified, and you have a training organization that' 7 helps management do that.
8 Then you have your miscellaneous management support 9 groups, all the way from HR, chemistry, other (
10 organizations, warehouse, purchesing, that help i 11 management ensure these barriers are in place and 12 working.
13 Senior management is over here; and their job, j
(}
- 14 primary responsibility is to make sure their management 15 organization is in place and working. And they rely on 16 independent oversight committees, NRC, INPO, anybody 17 independently giving them feedback to make sure these 18 barriers are in place and working. You also have your 19 regulations, your industry standards down here as
, 20 feedback under senior management.
21 The other thing I would like to point out are the 22 arrows. Arrows represent communication. Communications 23 -- you know, you could have a breakdown of any of these 24 barriers if you have a breakdown in communication. And
() 25 that's why that 70 percent of the events that happen, THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
24
[N 1 the underlying cause or a contributing cause is a b breakdown of communication. The operations barrier, for 2
4
. 3 example, will fail if they don't know what work is being 4 done out in the plant-due to a miscommunication. So 5 again, what we're trying to do-is look at. communications 6 to make sure!that is contributing or not contributing to i
7 a breakdown in the barriers.
8 So one of the things we're trying to do -- and 9 that's how we define nuclear culture. Everybody in the 10 site fits into one or more of these boxes all the way ;
11 from a clerical person who could mistype a procedure, 12 cause a failure of that barrier, to a janitor who sees i
13 oil on the floor and doesn't report it that contributes
) '
14 to a breakdown in the equipment barrier.
15 So what we're trying to do is what are the 16 attributes behind these barriers and then see which of 17 these attributes are failing or needs improvement. So J
18 anything that happens out there we can come back to our 19 nuclear culture and identify those areas that we need to 20 improve. ;
4 21 Where we stand and what we've done so far is we've ]
l 22 gone back and looked at the existing known problems up ;
l 23 here.. And so basically this is looking backwards, and ;
24 this is where we've preliminarily concluded we are ,
I
() 25 looking at that data. And the boxes here indicate the l
THE REPORTING GROUP l Mason Lockhart Hagopian & Ramsdell l
l e -- u
l 25 i
\
t I areas that we need to improve. And the red means, as 2 you can read here, significant weaknesses. Then we have '
, 3 identified in these barriers, yellow means an area that !
I 4 we need to improve, white mean.it's adequate and green j 5 means it's a strength.
6- And the areas'that we've: Identified so far are,the 7 ones indicated here. I can briefly give you a rundown 8- of our extent of conditions in those areas. ;
9 The first one up there under plant equipment is -- r 10 we've identified an issue that we're not always getting l 11- timely design changes implemented. We have several j i
12 operator work-arounds that require design changes, and {
13 that we consider a weakness that contributes to that l [us)! ,
barrier. Also, we have nine systems that are classified 14 i 15 as A-1 by the maintenance rule. And again, those two 16 things are the two main things that contribute to that 17 barrier being red right now.
i 18 The next barrier is administrative controls. We'll l 19 identified a real issue in a lot of our programs of a l 20 lack of ownership of the program. Thette isn't a single 21 point ownership of the program. A. lot of our programs f i
22 are fragmented; and mainly our technical programs are 1
23 fragmented between the Yankee organization, the 24 corporate engineering organization, the plant i 25 engineering organization, and the plant itself. ,
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
26
/^ 1 So one of the things we're going through now and C}/ we're doing a lot of working looking at over 200 2
3 programs to make sure we have ownership, make sure we 4 have adequate adequacy of those programs. The other 5 thing that we really contributes to this probably being 6 yellow not red is a lot of our programs are cumbersome 7 and complex. So in the long-term, you know, this isn't 8 something we're going to solve for rectart but something 9 we want to solve in the long-term; and we probably would 10 keep that window at least yellow until we simplify a lot 11 of our programs. And we're bringing in process 12 improvement techniques through Entergy who is going to
/N 13 be going over our programs in the next few years to U improve them.
14 15 Coming down to yellow down at the bottom, our logic 16 testing identified that we have a weakness there. But l
17 also we -- due to that weakness in logic testing, and 18 you'll see it in a minute when we go through the 19 appendice, we've done a major review of our testing 20 program. And so far it's looking pretty good.
I 21 Coming up to the top, we've identified a 22 significant weakness in our engineering barrier, our 23 technical barrier. We have a lack of system engineers.
24 We've never implemented system engineers in total here,
(~) 25 and we figure that is a significant weakness. Also,
(_/
1 THE REPORTING GROUP l Mason Lockhart Hagopian & Ramsdell l l
27 l
/~' agafn our technical programs adequacy, you know, the !
b) 1 2 cable separation program, our logic circuit testing, our j 1 3 UQ programs, a lot'of our appendices that we've 4 identified as significant issues go back to our 5 engineering programs.
6 Also as -identified in our 50.54 (f) , we have 7 weaknesses in our design bases and documentation. So ;
8 those are the issues that make that barrier red.
9 Nuclear safety, this is our QA licensing program. f 10 We've taken the first step there. We've combined them !
1 11 under a single officer and have a new officer. But 12 basically what's turned that barrier red is we have a
( 13 nonintrusive QA program, a QA program that hasn't been 14 able to identify some of the weaknesses before they're 15 identified by other people.
16 The other thing that has contributed to that in the 17 past is we have our corrective action programs. We have 18 several of them. I'll talk about that a little bit more 19 in our appendices, but our corrective action program 20 wasn't adequate to prevent similar issues from 21 happening.
22 Like I said, plant management, whenever you have a 23 breakdown of barrier, you know, management is usually 24 the root cause because their job is to ensure those
() 25 barriers are in place and working. What we've THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
?
28 l 3
s !
1 identified there is a lack of questioning attitude, a
(
2 lack of management accountability in the ownership of l 3 our programs and our systems, and also a lack of .
j
. 4 self-critical, self-assessments that contribute to that j 5 barrier being red. 1 l
,h 6 Training program, We've just come off probation: in ,
7 our technical programs; but we've also identified that 1
8 technical training.or engineering training is a weakness ;
9 and contributed to cable separation, logic testing, EQ.
10 So again, the only thing that's keeping that is 11 basically one of our, you know, several programs in 12 there; and that's our technical training program. We 13 have come off probation now with INPO, and that's why l
)
14 that's yellow.
15 Coming over to senior management, what's keeping 16 that red or has turned that red was economic pressure in 17 trying to focus on cost; and also a lack of resources is f 18 what has mainly contributed to that barrier being red.
19 Yellow, independent oversight. Again, our 20 independent oversight groups haven't been effective in 3
- 21 identifying the issues, and that's why that's yellow.
22 And regulations and standards, the main reason that's 23 yellow is we haven't kept up with the industry
, 24 standards. We haven't kept up with where the rest of
() 25 the industry is. We've become isolated, and that's why THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell :
h 29 ,
n l 1 that barrier is yellow.
)
i 2 Some of the other areas in some of the -- this kind ,
i 3 of gives a qualitative look at where we are or.wher. we 4 have been. Again, this is preliminary. Again, this is 5 basically looking backwards. I would say if you're 6- - going torbenchmark this to a time,,this is probablys 4
7 where we were January 1st, at the turn of the year, 8 January 1st of this year. That isn't necessarily where 9 we figure we are today. But this is how we're going 10 through and looking at our extent of condition and 11 trying to identify the areas that we need to improve, 12 not just the specific problems that come up.
13 Questions?
)
14 MR. RULAND: Yes, I have a question. In reading 15 .your restart-plan, based on what I understand of your j 16 plan, right now your restart steering committee is 17 only committed to review those items that are major
. 18 actions -- and I guess I'm not quite getting the 19 words -- A through H in your appendices. Are those 20 major issues that you basically required your restart ;
21 steering committee to approve prior to restart? And I'm 22 curious why these particular items which you identified 23 as significant weaknesses aren't included in that list i
24 of items that you have to have the restart committee l
/ 25 approve your actions.
V) ,
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
30 ,
i 1 MR. KEUTER: Well, the restart steering committee,
)
2 they've gone through, you know, the initial extent of l 3 condition. They're going -- that -- if that's what --
4- that wasn't what we intended. As a minimum, the restart 5 steering committee is going to be looking at the major 6 appendices. Like we said, these have been in >
7 development; but the restart steering comlaittee will be !
8 looking at each of these. The restart steering 9 committee and Mike himself will have to be involved in 10 the determination of these barriers. >
11 MR. MEISNER: Bill, said another way, the 12 appendices are a major focus of the restart steering 13 committee; but as important a focus is on looking at the 14 extent of the condition. And what Dan is describing ,
here is -- is how we define the extent of condition.
~
15 ,
16 And each of those individual items is going to be 17 important for the steering committee to review, buy 18 into, and determine that we have adequate corrective 19 action in place. So review of what you're seeing up i
20 there is a key element of the steering committee's job.
21 MR. KEUTER: This is a major way of how we measure 22 nuclear culture. This is a major _way of how we assess i
- 23 where we are and where we're going. And definitely, the l i
24 steering com.otitee is going to be involved in this.
25 MR. RULAND: So am I hearing that these are going l
(}
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
31 l
i
/N 1 to be reviewed by the restart steering committee or 2 aren't or --
3 MR. KEUTER: They are, yes, definitely.
4 MR. HEHL: -And what's the criteria? You know, do 5 these need to go from a red to a yellow to support 6 restart, or'have you tied any-correlation to these? '
7 MR. KEUTER: Basically what we've gone through, 8 we're going through and identifying the weaknesses that 9 I-just told you. So each of those we'll identify the 10 corrective action, and from that corrective action we'll 11 determine whether we have to do that corrective action 12 before restart or not; For example --
13 MR. HEHL: I know each piece that you mentioned is 14 broken down, and a lot of these things are reviewed by 15 the non-hardware group as part of their process.
16 MR. KEUTER: Correct.
17 MR. HEHL: And I guess it goes along with Bill's 18 question is who is going to make the determination. At 19 least it's not clear from the plan that -- that there is 20 going to be an overview determination that these are 21 adequate to support restart.
22 MR. KEUTER:- The non-hardware committee is going to 23 present this to the steering committee. The 24 non-hardware committee is doing basically the leg work, 25 and then it's going to be reviewed and approved by the THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
s 32 !
1 steering committee. And this is going to be an integral b("N part of our integral assessment. We have to assess this 2
3 as the management team, even above the steering 4 committee, up to Mike's. level before we reach that.
5 MR. RULAND: Just a follow-up question on this. of 6 course, the NRC is going to be critically involved _in reviewing these items, and it wasn't clear to me at what 7
8 point in your process you would declare these things 9 ready for inspection. Maybe I didn't -- I couldn't 10 glean it from the report; but it seems to me that the 11 burden, rightfully so, ought to be on you folks to 12 declare these things sound and ready for our
/'N 13 inspection. And that's primarily the way we're going to (ms) 14 judge whether you're ready for restart, is not only did 15 you do the work, that as we come in and inspect that 16 work, it's -- that work is appropriate and adequate and 17 it's ready for restart. And I think we will then infer 18 based on your performance in that area whether you in 19 tact are ready to restart. And we'll be able to judge 20 your management in that way.
21 And I guess I couldn't understand at what point 22 these different items, A through H, are going to be, you 23 know, ready for our review, and how you're going to add 24 items to your list and then how are you going to notify
(
V) 25 us that these items are ready for our review?
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
i 33 .
1
() 1 2
MR. MEISNER:
for that.
Yes, Bill, we agree the onus is on us So that for an individual item, say, cable f w 3 separation -- and Dan will show you later we've-got a i 4 report submittal schedule for that -- that item may be 5 ready for your review maybe well in advance of the whole 1
6' package. 'And as'those things become-ready, or at least ,
7 in our estimation ready, we'll notify you of that. But 8 the responsibility lies with us to come back to the NRC ;
9 and say we've wrapped up everything. We've got the I I
10 extent of condition defined. We've got our hands around ;
11 all of these major activities as well as the minor 12 activities; and now we're ready to please come in and --
T 13 and take a look at it overall.
I usl 14 And we'll be doing that on the docket with you 15 when -- the-main impediment to doing that, of course, is 16 defining these unknown conditions. And that's where a ,
i 17 great deal of our focus is now. When we're satisfied j t
18 that we've got that defined, then we'll be notifying the l
19 staff of that fact. But we will provide you earlier I l
than that some discrete packages or at least I 20 21 notification that those are ready for your review.
22 MR. HEHL: That's important because looking back on 23 -- on the cover of your. March 7th letter that 24 transmitted to us the plan, you indicate in there that a 25 restart plan closure report due approximately 30 to 60
[V T THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
34
['N 1 days prior to our estimated restart date. And the
(
2 reality is that all along the way we're going to be-3 having to inspect these things; but we're certainly not 4 going to be in a position to commit a substantial amount ,
5 .of resources to a thorough review of an area until 6r you're satisfied that that area is fixed and meets your 7 standards for performance.
8 MR. MEISNER: We understand that.
9 MR. HEHL: And you certainly can't wait until 30 to 10 60 days before you plan to restart to have this stuff 11 ready for our review because, quite frankly, we couldn't 12 support that.
13 MR. MEISNER: We understand that. As areas are 14 complete, we'll let you know that; and we'll also let 15 you know when we're ready to ask for that 30 to 60-day 16 --
17 MR. HEHL: And I would venture to say that it ought 18 to be well on the 60 side versus the 30 side because we 19 have a lot of work to do at the tail end that -- that, 20 you know, we're going to work through it. And, you 21 know, we're going to try to accommodate as best we can, 22 you know, your readiness schedule.
23 But -- but the reality is that just about the time 24 that you're outlining for readiness, we also have f)
%_/
25 readiness of Salem II and Millstone unit -- one of the THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
1 35 1
1 units. 'And so you're competing for a lot of resource 2 expenditures at that same time.
3- MR. MEISNER: Okay, sure. We understand that. And 4 as far as-60 days'rather;than 30, we can accommodate. :
5 .that. But by the same token, whether it's 30 days or 60 6i days, there will still.be-some planned activities-after 7 we notify you. That 60 day, that list of planned 8 activities to be completed, will be bigger than it would 9 have been at 30 days. !
i- 10 MR. KEUTER: And it will become a little bit more t 11 clear when we get into the schedule of the different .
12 appendices. I want to make it clear, a lot of the 13 appendices, the A through H issues, are what feed into ,
14 make these barriers red or yellow. And if we identify a
- 15 new issue,.another major issue, there might be an 16 Appendix I or J or K; and we'll let you know as soon as 17 we reach that point.
18 One of the things I'd like to point out is we have
- 19 identified several of our programs have a common thread 20 through that, and that's a lack of ownership and single l 21 point accountability. So as we get through our program 22 review, like I said, we're looking at over 200 -
23 programs. There may well be an I or J or K. Now, not 24 all of the actions that come out of them may not all be
(~N 25 restart, but some of them very likely could be.
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
36 1 For example, our fire penetration is an issue.
2 It's not one of the appendices because we've got .
3 compensatory actions-that we can do. So it's an ;
4 important-issue.--We'could have made it an appendice, 5 but it's not going to be done before restart. That's 6! 'why we didn't'make itian.appendice. But,there might;be ,
7 other issues out there.
8 MR. HEHL: But you will be in compliance with the 9 requirements --
10 MR. KEUTER: Absolutely. .
i 11 MR. HEHL: -- through compensatory measures? i 12 MR. KEUTER: Absolutely.
13 MR. DORMAN: Dan, when you were going through the 14 barriers and talking about the things that made them 15 red, it wasn't clear as you went through there that 16 there were clear ties to the appendices. Some of the 17 issues that you talked about, like system engineering, 18 technical program adequacies, nonintrusive QA, lack of 19 questioning attitude and so on are -- are harder issues 20 to get your hands around. And they're not -- they're i
21 not clear that they're specifically tied to either 22 action plans,or to specific restart items in the 23 Learning Bank or -- or the work orders. And one could 24 infer from that that some of these broader, softer
( 25 issues may still be unresolved; and these issues may THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell i i
_I
37 )
l 1 still come in for restart. Could you address that a
[
2 little bit?
3 MR. KEUTER: Absolutely. A lot of those underlying 4 causes are softer issues. You know -- I lost my colored 5 slide now. But a lot of these are softer issues. And 6' some of these - =you know, for example, systems 7 engineering, I'll use that as a good example of why 8 that's red. Before we start up we will have a system 9 engineer responsible for all of our safety systems. And 10 that's what we feel we have to have as a minimum for 11 restart. After restart we're going to have system 12 engineer development for our other systems.
13 So we kind of broke that into a group. We didn't 14 make it an appendice necessarily because it's not going 15 to be all -- it's not a -- you know, a regulatory -- it 16 doesn't meet our criteria. But it's something that we 17 definitely want to have in place. And not having system 18 engineers has probably contributed to some of the issues ;
19 in the appendices. Just like not having program 20 ownership of cable separation and not having program.
21 ownership or fragmented responsibility for EQ has 22 ccmtributed why that is a major issue. So not only do 23 we want to solve the EQ, we want to solve the underlying 24 cause.
/~ 25 And now the underlying causes, all of those cannot N.-]D THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell l
38 r
1 be restart issues. Some of them will. System engineers
(}
2 will be implemented for at least the safety systems.
3 MR. DORMAN: How are you tracking that? Is there ,
4 something in the learning bank that. flags a restart: item j
5- -for having a system engineer for each of those systems? 3 6' And also,'in terms of the~ committees, how will:that:. ,
7 review be -- you know, who is going to decide and at 8 what point with respect to this example, system 9 engineers, that you're ready to restart with respect to f 10 these items?
11 MR. KEUTER: The program itself, the fact that 12 we've laid out 21 systems to be reviewed by the system ,
() 13 14 engineers is what's going to track us on that specific issue. So most of them are going to be tracked either, t
15 you know, by an appendice, by the learning bank, or by
, 16 work order.
17 MR. MEISNER: Dan, if your question is will each 3
18 and every item have some tracking mechanism and that we -
19 can follow and ensure is closed out, the answer is yes.
20 Some will be major issues like an appendix item. Others 21 will be single-line items and the corrective action i
22 plan. l 23 MR. DORMAN: I guess what wasn't clear to me is on 24 a relatively soft issue like that that's not an l 25 appendix, clearly it's not a work order, is there a THE REPORTING GROUP !
Mason Lockhart Hagopian & Ramsdell !
1 39 i
1 learning bank item flagged for that? Those are the
[
2 three categories that you've given to me how you're ;
- 3 tracking these. or is there another tracking mechanism )
i 4 for these?
5 -
MR. MEISNER: No, that's it. It's either'in the 6 corrective-action program or,the Learning' Bank-which1 will hold most of the soft items, or it's largely a !
7 8 hardware issue in which case you've got a work order 9 attached to it. Those are the two mechanisms. I 10 MR. RULAND: Just to use this as an example, are 11 you saying this particular item, to establish system 12 engineers to a particular group of systems, you're 13 calling this a restart item?
)
For the safety systems. j 14 MR. KEUTER:
15 MR.=RULAND: So how would we as the NRC know that 16 you are completed and ready to go on this matter? .
l 17 MR. KEUTER: You come in and review. Our 21 safety 18 systems will all be all evaluated and have a system 19 engineer responsible for them.
I 20 MR. RULAND: I understand that, but what I'm j 1
21 suggesting is what is the document that we're going to 22 have that we know that this is on your list as a restart 23 item?
24 MR. MEISNER: I think that document will be what we
() 25 submit to you 30 to 60 days prior to our determination THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
40 1 that we're ready to restart.
2 MR. RULAND: And I would suggest to you that that's
- 3 not soon enough,~that we have resources to plan; and, 4 you know,:we've got to decide,ayou know, what are-we, ,
l Do we have the right staff to ;
. 5 -going to inspect?
68 inspect? -And frankly,-I. don't think-that's soon.enough.
7 MR. MEISNER: I think we'may be talking about two 8 different things here, Bill. )
9 MR. RULAND: Maybe we are, f i
10 -MR. MEISNER: If you're talking about where are the !
11 details going to be and where is it all going to be 12 wrapped up together, it's going to be in that -- in that
. 13 document we submit to you 30 to 60 days prior to 14 restart.
': 15 As far as continuing dialogue, additional 16 submittals as necessary and our notification to you that 17 we're ready in a particular area, those are going to be 18 separate and distinct documents that you'll have 19 available.
t 20 For instance, cable separation, like I mentioned !
21 early on, we'll be submitting a detailed -- a very i 22' detailed report on that issue that will cover --
, i 23 MR. HEHL: You-all have a well-defined hardware 24 issue. Here we're talking about something that's a 25 little bit broader. Establishing a viable system
)
THE REPORTING GROUP -,
Mason Lockhart Hagopian & Ramsdell l
41
/~} 1 engineering program for at least a certain 2 range of - .of, you know, systems is a little different
' 3 than -- than resolving, you know, the cable separation 4 issue where you have clear -- you know, clear criteria 5 that you either satisfied or you didn't. The point is 6 how are we going to --
7 MR. KEUTER: Your tracking mechanism is your CAL.
8 So that you have to identify the extent of conditions.
9 We have to identify the extent of conditions.
10 MR. HEHL: Maybe we're getting into too explicit a 11 level of detail at eht point in time because maybe we 12 can -- I guess in general what we can say is what we're 13 looking for -- for us to be able to -- to review and l (J')
14 know when you're ready for a particular area to be 15- reviewed, I would suggest that maybe you put together 16 some sort of a package or something that outlines the 17 issue and how you went about resolving it and -- and 18 perhaps your assessments of it. And then we'll take 19 that package of things and then go out and do an 20 independent review of that.
21 MR. MEISNER: We understand that. We'll make every 22 effort to give you as early notice as we can. We 23 understand everybody is resource stretched, and it's up 24 to us to give you enough advance notice. Don't 25 misunderstand, you know, what Dan is going through here f~)/
N_
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
42 1 is this is a work in progress. We're trying to give a 2 kind of a snapshot of where we sit now. But we're still ,
3 putting items into those bins, you know. We're still 4 going through the. extent of' condition... We don't have a 5 document now that will grab all of those. ;
6- MR.'HEHL: We understand that; but we're also in l 7 the process right now of trying to take your restart ,
I plan and decide how we're going to develop our own, you t
8' ,
4 9 know, assessment plan, you know. And it's -- moving I 10 targets are hard to hit.
11 MR. MEISNER: I agree, I- agree. And, of course,. ;
12 you know, part of this is -- and I think Mike said it at 13 the beginning -- is the approach we're taking we think 14 goes well beyond the 0350 restart criteria. And in that 15 context,--what we've put together here -- I mean, our' ,
16 understanding is you'll come back to us in a couple of I 17 weeks; and you'll issue to us a restart plan that will i 18 be or may be substantially different from ours. And 19 we'll focus on the regulatory criteria in 0350 for 20 restart. And, you know, you might have --
21 MR. HEHL: You have your own plan. This is your 22 plan for going forward and fixing the problems that l
- 23. exist both prior to restart and post restart. Okay?
24 Our plan'is different. Our plan is not -- is not 2
25 telling you or blessing what you've put down as far as a THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell j i
. . . + - - . . ., . , . . ~ . . , , . , - . . . - - - - - . - . . . ~ . - ,- - . ~ ,
43 i
1 plan. Our plan is a plan of how we're going to expend
)
I 2- our resources to evaluate your readiness for restart.
3 MR. MEISNER: Right. ..And that's what I was trying '
4 to say, that the scope of review,'the-scope of your-plan 3
5 may be -- may be much different than ours. a 4
6 MR. HEHL: -It Will be. JWe obviously expect you to l
, 7 dig into -- into detail in all of these areas and to 8 ferret.out the problems and ensure that you got lasting I
[ 9 corrective action. We're going to, consistent with our-3' i 10 plans, do some sort of sampling which will include some l 4
11 very thorough and deep assessments. But certainly we're 12 not going to be able to challenge every area that you've 13 looked at.
)
What I wanted to get to was I 14 MR. MEISNER: Right.
15 .we'll.give you as early notice as we can once we finish 16 an area. But by the same token, your plan is going to i 17 be different than ours. So for us to give you advance 18 notice on the things that you plan to inspect, we need 19 to know what those are. So it would be helpful, too, 20 for --
21 MR. HEHL: Well, it may be helpful for you to time 22 what we're going to-inspect. But I'll tell you what, 23 you probably are going to be very surprised at -- you 24- know, we're not going to lay out a detailed plan that is 25 going to highlight each and every thing that we're going THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell ,
44
()
\_/
1 to inspect. You know, our expectations are that you 2 will come to us, tell us when you're ready to be 3 inspected in a particular area; and then we'll 4 accommodate that as far as going out and inspecting-at 5 'that point in time as best we can within -- within 6 resource constraints.
7 But, you know, we're not going tell you, okay, in 8 order for you to restart, you know, we're going to look 9 at this specific issue, this specific issue and this 10 specific issue. No, no, no, no. We're going to be 11 looking at a broad range of things. We'll share our-12 plan with you; but that plan is going to be, you know, ;
(~'T 13 somewhat general in nature addressing the areas that.
b 14 we'll be looking at. Certainly I would not time your 15 completion to our plan. You need to move forward at ;
16 your own pace and accomplish what you -- l l
17 MR. MEISNER: No , you misunderstand. That's not at '
18 all what I'm trying to say. And we will provide that 19 information early to you.
20 MR. HEHL: You need those arrows, right, those 21 arrows that communicate. l l
22 MR. MEISNER: And to the extent that your plan may 23 differ from ours in a way we wouldn't anticipate, then 24 that is also useful information. And we need to know !
(~N 25 that so that we can give you advance notice in that area
\m- !
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
. . . - . . . . . . . .-. - . - . -. . - - - - - . - . - - . ~ . . - . . -
i .-
1
' 45 I
)
1 as well.
)
! 2 MR. HEHL: We will -- as I mentioned when we f I k- 3 started, we have just really begun to dig into your< plan j 4- 11n. detail'.. -And'asswetdo-that and". identify areas that we
- have concerns with or areas that we think -- we'll,give 5
1 6- '
you' comments - 'you know, we'll give'you" comments and l 7 things on it, in those -- you know, certainly you'll be i
.8 aware of them. ,
l 9 MR. MEISNER: Good, appreciate it. :l 10 MR. KEUTER: Okay. -I'd just like to point out .
4 11 again we're going to give you our evaluation of extent I
Also, as we. I i 12 of condition, as required by the CAL.
13 committed them to the restart plan, we will also give 14 you our short-term plan on the same time frame. 30 to 2
i 15 60 days before we'll give you what we're going to do 16 after restart so you can look at that, also. l i'
i 17 Identification and screening, again, I just want to i i
18 emphasize that we're going through the known issues as :
- i 19 described; and also we're screening all of our work .
l
! 20 orders, our learning bank issues as a minimum. Also, !
i 12 1 we're going out and looking for the unknown issues, j 22- whether it be plant equipment, programs or people. f I 23 These are.the significant restart issues;.and we'll ;
4 !
24 be going through those in detail, so I wasn't going to ;
l25 go through those right now.
)
THE REPORTING GROUP l Mason Lockhart Hagopian & Ramsdell {
46 1 I did want to talk a little bit about the
}
2 screening, the safety screening. What we're trying to j 3 accomplish here is look at anything that can affect ,
4 nuclear safety:andemakeithat a restart. Tha're looking 5 ~~at, you know, anything that has repetitively caused-6 equipment failures of our safety systems or components, 7 look at anything that can, you know, potentially or 8 realistically cause a plant transient, power reduction or shutdown, looking at our design basis, anything there i 9
10 that could cause one of our safety systems to be an 11 inoperable component. Also, looking at our non-teche d
12 spec but important to safety equipment, making sure 13 that's adequate, and also any potential injury or
[}
14 overexposure as our screening for safety. -
15 In addition to that, we're looking at regulatory 16 requirements, what would cause a noncompliance with the 17 regulations, whether it be EQ Appliance R, et cetera; 18 noncompliance with operating license, or failure to 19 satisfy our tech specs or effluent that would exceed our 20 regulatory limit.
21 Work completion, like I said, we're not trying to 22 invent something new. We're trying to beef up the -
23 existing processes that we use normally, whether it be a 24 work order, learning bank, design changes. And we're 25 just giving an extra level of review, an extra few
/}
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
47 l
l 1 barriers in there to make sure those processes are 2 working. We're tracking them, like Mike said, using two ,
'- 3 main mechanisms to track them. Hardware will be tracked
'4 by work-orders.and our software. issues by a. learning.
5 bank.
6 MR.-CONTE: .Can we hold right there?
7 MR. KEUTER: Okay.
8 MR. CONTE: Can you give us a sense, in terms of the work orders and the learning banl items, what level -!
9 10 -- if those items are labeled for restart, what level i I
11 of independent review will they receive, if any, fore ;
12 closure? ;
4 .
13 MR. KEUTER: On work orders, you know, like I said, 14 we'll be going through our normal work order closure.
15 And work order is -- probably the best way to look at 16 that is to look at the work order flow chart. This is a
17 Attachment 4 of how we're going through our work ,
i 18- orders. Basically we're talking -- all of our work 19 orders are taken through our operation integrated team.
l 20 They're evaluated and see if we need to do it for j 21 outage. If it is, it goes into a bucket. Anything that 4
l 22 doesn't, they're required for outage screen against our :
i 23 criteria. If it meets the criteria, it goes into a 24 bucket. Our hardware committee looks at that, and they 25 agree or disagree with that; and they can add things to
)
f THE REPORTING GROUP ;
Mason Lockhart Hagopian & Ramsdell t i
48
() 2 1 it at their discretion.
here.
So it's got two-level review i
i 3 Then it comes down to the work order owner. Again,
^
4 -
Rhe looks at:that^ schedule,-completes.the work;'and he 5 might see other things as he's out-there, And again, he 6 can bring-that back and say this.is a restart issue.or a 7 nonrestart issue, go back through OPIT, hardware ,
8 committee and add or subtract. So there is a review 9 within here.
10 Then it goes to the system owner. If it's a safety ;.
11 system, it goes to the system owner. He reviews it. ,
J !
12 This is a third level to make sure that whatevc- bas l [~h 13 been undone up here that that work is done and ms :s his b
14 standards. So he looks at that. ,
l The system owner then takes it, conducts his final 15 16 system assessment. The final system assessment goes l
17 through the restart steering committee. As you see i
18 here, there are several barriers along the way to make e
19 sure that a work order, one, is screened for the 20 restart, and two, even after the work is done and it's 21 got pretty well of a review besides its normal -- it has i
22 its normal review by the owner and his management team.
23 Then it goes through the system owner and the hardware 24 committee. So there are several barriers added in b J 25 there.
THE REPORTING GROUP ;
Mason Lockhart Hagopian & Ramsdell ,
49 1 MR. DORMAN: Does the restart steering committee 2 ever get that?
3 MR. KEUTER: Not in total. What we'll do is the ,
4 restart steering 1 committee come back.and.look at the 21 i
5 safety systems. ~They'll have a presentation, but i 6 they're not-going'to go'through every single item. They .
7 are going to look at it in general.
Also, what you see down here is a review of the I
8 9 stuff that didn't make it on the list. So they're not l 10 only reviewing the stuff or the things that were done.
11 They're looking at the stuff that wasn't done as part of 12 their assessment.
13 So the steering committee isn't going to review.
14 every work order. That's why we have the ;
l 15 subcommittees. l l
16 MR. CONTE: I notice on the block here, and maybe 17 it's a figmentation of being brief, does that mean that 18 the hardware committee is only looking at the system ]
19 assessment which may be a compendium of work orders; or 20 are they 200 king at individual work orders? !
l 21 MR. KEUTER: What they do is the system owner, he's 22 going to maintain a notebook. And we line up the 23 expectations in that notebook. And that notebook is 24 going to have the work that was done and the work that 25 wasn't done. And he's going to take that notebook and
[}
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
50 1 review it with the steering committee. And the steering 2 committee is going-to have that list, and they're going 3 to look through. And they'll have an opportunity to-
- ' 4 < question the owner.or anybody.else on the committee, you 5 - know, why isn't this done, what did you do about this? ;
6 So are they going to look and= physically take every 7 work order and look at the work order or the work order 8 package? No. What they're going to do is they're going
,i i
9 to have a listing that they'll go through. And it's all 10 going to be documented in the system notebook.
}
11 MR. DORMAN: But they are screening the ones that 12 are determined to be non-outage work.
/~N 13 MR. KEUTER: Yes. They're looking at the t
14 non-outage and that.
15 -MR. DORMAN: Halfway down the page the hardware
, 16 committee is looking at the non-outage?
, 17 MR. KEUTER: Correct. The rounded boxes is .
18 documentation, and the square boxes are the actions. So !
i 19 -- and there's similar -- in your attachments there's a j 20 similar review process for not only work orders but 21 learning bank, department assessment, system 22 assessment. They have multiple barriers in there to 23 make sure we have adequate review.
24 Any other questions?
25 Restart readiness assessments, once we get ready, THE REPORTING GROUP ^
Mason Lockhart Hagopian & Ramsdell
51 i
\ 1 we feel everything is ready to go, we'll bring back our (D 2 plant. system readiness assessments and go through the ,
3 applicable steering committee. For the plant system,
'4 we'll go through the-hardware committee, then to the 5 ' steering committee. If it's a program assessment, we'll 6 go to the hardware committee, then to the steering 7 committee. If it's a department assessment, we'll go to 8 the non-hardware committee and then the steering 9 committee. And then we'll have an integrated assessment 10 that is going to go and be managed by the steering 11 committee.
12 And they're going to be looking not only at the 13 things above. They're going to have a licensing 14 affirmation that we've done all the licensing required 15 things. They're going to have a quality affirmation, a 16 quality assurance program that our department feels are l
17 ready. They're also going to be doing a management 18 assessment to make sure the management is ready. So 19 there are several reviews at the end that we're going to 20 be going through.
21 In addition to that, we're going to be what is the 22 current performance? We're going to be -- have several 23 -- four milestones that we go through; and we're going l
24 to be looking at the performance of people, management,
/N 25 equipment. And we're going to be looking at that before U
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
52 1 we heat up. We're going to be looking at it again
(~}'
Li 2 before we start up or after startup. We're going to 3 have a hold at-30-percent. We're going to be looking at 4 systems, doing systems walkdowns,-make sure the a 5 equipment is operating and the people are up to 6 standards, maintenance, et cetera. And again when we 7 get to 90 percent we're going to stop and assess it 8 again.
9 This is very similar to the program that we went 10 through after our steam generator failure. So it's 11 something we've done before.
12 MR. YEROKUN: If you go back to slide -- I think
/'~T 13 it's 9, the one of the Restart Readiness Assessments, t 4 O
14 when you talk hbout plant system readiness assessments, 15 do you have to have the system engineering in place 16 before you do that?
17 MR. KEUTER: We may not have the permanent system 18 engineer. We will have a system engineer in place. We 19 are in the process of hiring system engineers. That's 20 why we call them system owners. But there will be l l
21 somebody responsible for that system. It may not be the f l
22 guy that we end up permanently. I know there is a lot 23 of very good startup engineers out there that know a lot l 24 about systems. But this is the system review process 25 that we go through. And when you look at both the
(~)>
\~- i THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
53 ;
i 1 system reviews, the department reviews and the program f~h s/ >
2 reviews is in two steps. The first part of it is to --
'~
3 to look at the system, identify existing problems,.come }
4 .- out'with' work-orders,' learning-bank, proposed _ mods,2 5 engineering actions, et cetera, and assessing, you know, !
6 what-is restart, nonrestart, then doing a detailed j 7 walkdown of the system, then coming back to the hardware t
8 committee saying this is what I feel my system is and 9 these are the things I need to do for restart. Then it 10 comes down to the task owner completing any restart l 11 ' actions. Again, there is a big loop if there are things 12 that fall out that we want to add in or subtract out.
I
() 13 14 The system owner then completes a more detailed-assessment, and this is where we're looking for the c t
15 unknown issues. Here are the existing issues. Now '
l 16 we're going out and trying to find what don't we know l 17 that maybe we should add in. And if we have a design 18 basis summary document, our procedures, testing l 19 requirements, vendor information, FSAR, he's going to be 20 looking at this information to make sure these all mesh 21 together.
22 So he is going to be doing that assessment. Then 23 he's going to be doing a final walkdown before we start 24 up. Again, he's going to bring it back to the hardware
'] 25 committee. And then, you know, he's going THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell k
54 1 to -- as we go up in power, he's going to be walking 2 down the system and monitoring the system.
3- Now, this is for the :21 safety systems. - We're not
-4 ' going to'be-doing this:for'all,.you know, systems at.
5 this point. We will be doing it eventually but not,at 6 this point.
7 MR. HEHL: What kind of criteria -- are you going 8 to use your Attachment 3, restart work criteria, for 9 , them to review the systems in? Is that the idea?
10 MR. KEUTER: Well, they'll be using -- for lL l ^ determining whether it's a restart or a non-restart,i 12 they'll be using that criteria. But we're going to have 13 a checklist for doing the-walkdowns. We have a f \
l 14 checklist of what they have to review and do for their !
15 systems. It goes into a lot more detail than just the !
16 criteria. The only thing the criteria does is determine We'll have checklists I
17 what is restart and not restart.
18 for walkdowns. We'll have checklists for doing the l
19 assessments. Again, they'll have a system notebook; and I
. 20 they'll be documenting their assessment in that I l
21 notebook. They'll be bringing that notebook to the 22 committees. l 23 MR. HEHL: Have those walkdowns started as yet?
24 MR. KEUTER: No , they haven't.
25 MR. HEHL: So you're still developing the criteria THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell !
+
, , - . . . , - - , , ., -. w ,-
6 55 l i
, 1 in the lists?
2 MR. KEUTER: Where we are right now is we're 3 gathering this information right here, we're putting l 4 them into the notebooks and we're staffing. And we're -
5 hoping to have -- or kick off the system walkdown i 6 starting about mia N <11.
7 Is that about right, Paul? l l
8 This is probably going to be one of our limiting !
9 factors just because we haven't -- we don't have system l 10 engineers in place. And we're going to supplement it 11 with, you know, some operations people to operate.
12 Wefll take the notebooks. We're going to get them on 13 shift. Operations are going to help feed into that 14 assessment. But we're not taking credit for it right d
- 15 now.
16 MR. HEHL: You mentioned you're going to discuss l 17 schedules a little bit later on, and I guess maybe we'll 18 get into that at this point in time.
19 MR. KEUTER: We're going to discuss schedules for 20 the appendices?
21 MR. HEHL: .Right. l 22 Any other requests on startup and power ascension?
23 oversight, the oversight is our line management; 24 and our restart organization is our primary oversight.
25 To back that up we have our plant operating review THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
- - _ - - - - . -- - -. . - - _ . . _ _ - - . - . . . ~ - _ . . . . -
l 56 i i i committee in place and reviewing what we're doing. We
-2 have our quality' programs department. They have {
i 3 individual representation on'the steering committee; on )
4 both subcommittees independently looking at-what'each of 5 those committees'are doing in addition to what their i J
6 normal assessments are doing. And then we have our '
1 7 Nuclear Safety Audit Review Committee that's looking at .
I i
8 what we're doing independent. l 9 MR. DORMAN: Dan, back in the barriers graph you j 10 talked about significant weaknesses in the lack of l 11- ownership accountability, questioning attitude and line i
12' management, nonintrusive QA program. As you're -- as !
you're changing the culture and correcting those issues, 13 14 could you speak to what value you're getting out of'this '
15 oversight?
l 16 MR. KEUTER: Can you say that again? I'm -- I
- 1 17 MR. DORMAN: Well, you're -- I assume you're in the l 18 process of trying to make changes to the culture and :
19 improve the ownership accountability, questioning !
20 attitude and the line management and improve the 21 intrusiveness in the QA programs. But in the meantime, 22 these are your -- some of your oversight barriers in
, 23 this -- in this process. How are you checking the 24 quality of the oversight that you're getting in this
() 25 process?
THE REPORTING GROUP l Mason Lockhart Hagopian & Ramsdell }
t
,, , e , .- ,.
57 1 MR. KEUTER: Like we say, you know, we -- for
)
2 example, quality programs has representatives on each of i
3 the committees in addition to what their normal routines 4 are. And'some of=the weaknesses that you identified --
5 you know, we identified some weaknesses. The colored :
6 ones are - -basically show the areas where we've, you 7 know, changed out. We have new people coming in from l l
8 the outside. And you know, we're not waiting on saying i i
9 we're -- you know, everything is perfect. Some of those l 10 weaknesses we're already addressing with those red 11 barriers. ,
i 12 MR. ZWOLINSKI: Let me try it a little different ,
13 way, Dan. I think it was in response to the ISAT t f
14 enforcement. I believe it was the February 28th memo.
15 You all had identified that your quality programs 16 department hadn't been functioning very well. And now 17 you're using some of the quality programs department l i
18 folks apparently in some oversight roles.
19 So I think that you told us at one time it was 20 not -- not functioning to your expectations. Have 21 things changed, and is that group now performing at a j 22 different level? In other words, have you made 23 changes?
24 I know that -- I do see what you've said, Dan, that
/\ 25 you've changed a manager; but to change all of the folks b
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell ,
r
58 I to work at a different level seems like it's going to (V~)
2 take more than just flipping the light switch on and 3 off.
4 MR. MEISNER: You're exactly right, and we can ask 5 George Zinke to address that if you'd like to. But.
6 the -- we've made -- it's difficult, as you're pointing 7 out, to change a culture and a mindset. So part of --
8 part of what we're doing is laying out the expectations 9 that we have of our quality assurance organization.
10 Now, if you recall the enforcement conference we 11 had a couple of weeks ago, we spent a fair bit of time 12 talking about these things like lack of a questioning
[\. 13 attitude, nonintrusive QA, and giving you some idea of GI We can go into that in some 14 the changes that we made.
15 detail now, but I guess I wanted to summarize by saying 16 that we're aware of those concerns; and that's why we've 17 started making those changes, so that in the oversight 18 functions for like the quality assurance organization, 19 that we're going to get a quality product out of it.
20 Similarly in the -- in the nuclear -- the NSARC 21 committee, the safety review committee, that group has l
22 boon largely reconstituted and I.think in the last year 23 or so has a new chairman and really has l l'
24 a -- has a very intrusive and questioning attitude
[) 25 compared to the way it was a year and a half ago.
LJ THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
59 l
1 MR. ZWOLINSKI:- Well, I think it helps, the 2 embellishment that you've given it, Mike. But yet there j 31 is'some-fluidity in many of those programs,-and I think j 4: .there'will-be> fluidity for-some years.
5 MR.-MEISNER: And11s'it where we want it to be?. }!
6 No, not by any means. But.are we making incrementalt f 7 progress?. Definitely. t 8 HR. ZWOLINSKI: And I guess who is checking the ,
9 checkers is kind of like the bottom line. And I think :
10 I'm hearing that it's senior management that's trying to :
11 take the~ pulse of this, whether it's management within ;
12 the QA group or yourselves or -- or departmental o 13 managers. That's where the buck is going to stop. .
)
14 MR. KEUTER: Well, I'm just going to -- you know, !
15 I'd like --
{ 16 MR. MEISNER: That's right. )
! 17 MR. KEUTER: -- I'd like to point out here that 18 one of the things that's different here is the working f i
19 level of the people are good. We have a -- the 20 foundation. What is changing is the expectation. And I J ,
21 guess to be blunt, maybe the expectation wasn't finding i
22 problems. And that's why you see more red up here.and l
23 not red down here. I think we've got basically good, !
)
24 very good people with good standards; and what we're 25 changing is the expectation. We've changed the
)
f THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell f i
r
60 i b
1 expectation now to go out and find problems, not to f
)
.2 cover them up or not to find them. What is changed is 3 the expectation. What is changing is this up here. ,
4 MR. HEHL: Let's get to a specific. You have the *
'S QPD programs that provide' independent oversight. Have 6 you gone out and reassessed the quality and' activity.of ,
7 QPD? ;
8 MR. KEUTER: Are we going out? Yes.
9 MR. HEHL: Have you? You changed organizations. j 10 You say you have confidence in the -- in the people 11 implemanting it. And I guess the question is have you 12 gone out and tested that to provide the level of 13 confidence?
/]
b 14 MR. KEUTER: As part of the department's .'
15 assessment, we have to do that. Have we done it now?
16 No. l l
17 MR. HEHL: The problem that we see is you're i 18 depending on that at this point in time to be one of )
I 19 those barriers that's sitting in on these other 20 committees who are also assessing things.
21 MR. KEUTLR: But the fact that we have the 22 committee is -- is -- you know, it's not one person.s 23 We've supplemented the program. Go ahead.
24 MR. HEHL: What we're doing is we're trying to poke 25 holes in this thing to see where the weaknesses are.
s THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
l 61 1 And so --
2 MR. ZINKE: I'm not sure I can answer all of your 3 questions. I'm George Zinke, manager of quality i
4 . programs..- And certainly 11t is a ' valid question that: we 5 have to answer because, you know, my function did not 6 find certain things. And'so we've done, you know, ailot 7 of root cause and some short-term corrective actions to 8 miske sure that the reasons for us not identifying would 9 not prevent us from providing good oversight during this 10 period.
11- We think we have done that. Completely? Not yet.
< 12 So there's still some -- some things that we're doing, 13 some checking adjustment. We have not done like what I
- 14 would say an independent assessment ~of how much we have 15 . improved. I mean, I have seen evidence that we are 16 providing a different kind of an oversight in the sense 17 that -- that the things that I looked at of what was 18 done like over the last year was not -- the reasons for 19 not finding things were not because the people, you 20 know, were not qualified or were not capable of finding 21 that. Some of it had to do with -- with selection of 22 what to look at. And that was -- that's something very 23 easy to fix, particularly during this -- the time period 24 for restart. It's not that hard to now pick things that
("'j 25 are important to look at. And it's easy to pick to what D
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
. . . . - . - - . . - . - ~ - . . . . . . - .. -- ~ _ . . - _ - . - - - - . -
i 62 l l
)(
)
1 level of depth you will look at things. So those are 2 easy fixes to do. i 3 We will be during this. process assessing the ,
f
~~
-4 quality of oversight..to make sure, well,-are we 5 ' deceiving ourselves again?- !
6 MR. HEHL: Is there a' feedback mechanism or 3 7 something that if you find difficulties in an area you ;
8 will then be able to go back and reassess the work that ,
9 was done on an individual basis or whatever feedback you 10 have? In other words, at some point in time, you're !
11 '
going to reassess the quality of activities in the QPD j 12 department.
13 MR. ZINKE: Yes. ;
14 '
MR. HEHL: I guess the question is is that-point )
15 the point that you're then going to go back and if you j 16 find difficulties re-reiew work done by that group?
17 MR. ZINKE: Well, let me give you a specific j 18 example. One of the activities we're doing right now j l
19 relative to restart is the cable separation project, and 20 so we have a level of oversight in that. And we're i 21 carefully monitoring, well, what kinds of things are we 22 finding? And.we are finding some things. And -- and 23 they -- some are of a nature that then we go back to the 24 work group and say now we're going to have to go rede
() 25- some of what we just did. So we are assessing that as THE REPORTING GROUP i Mason Lockhart Hagopian & Ramsdell .
i
?
. . _ _ -.._ . . . . - _ _ _ . _ - .. - -..-.--- _---- . _ _ _ ~ . .- ~ .
.. ..= .- . - - . . - - . - - . . . .
t
(
63 i I
() 1 2
we find an issue, to now what extent do we have to relook at things we've already looked at? l 2
3 And that -- and that's the same thing. Since -
1 4 quality. assurance and quality' inspection samples, o .
(
5 anytime I find a thing, knowing that I'm not looking.at ;
{
6 100 percent of everything, I have to assess and sayt ;
I 7 well, now what extra do I have to look at? What work i
8 may have to be redone in order to give myself assurance
. 9 again? So that's a natural part of the process. j 10 MR. HEHL: See, the interest we have is because 4
11- we're almost one level removed in that process, we #
12 depend very heavily on you being able to identify your
- ( }
13 problems because we also run a sampling of your 14 sampling. So that's --- that's certainly the reason for j 15 our interest.
d l 16 MR. LEITCH: Bill, there is one level that's not
) 17 really described here; and that is there is a Nuclear 18 Committee of the Board. Reporting to the Nuclear 19 Committee of the Board is the Nuclear Oversight 20 Committee. There's a group of nationally known industry
.; 21 experts. And they -- they are not in this chain of - I 22 command. They report directly to the Nuclear Committee And the Nuclear Committee of 1
23 of the Board of Directors.
24 the Board of Directors has specifically charged that
() 25 group, that is that Nuclear Oversight Committee, with i
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
i 64 I
i
()
\s /
1 assessing and reviewing this independent oversight '
2 function at all levels, that is QPD and the NSARC and --
l 3 and independent oversight as it exists at all levels.
4 MR. HEHL: Is that ongoing, or-is that scheduled 5 for some point-in time when they're going to do their i i
6 review? ,
7 MR. LEITCH: Yes. I think their next meeting is ,
d 8 later this month. They have meetings periodically and I
9 during this period of time at an increased frequency.
10 MR. YEROKUN: Just a question on that, Graham. Is
, 11- that Nuclear Oversight Committee attached in any waycto ,
12 the Restart Readiness Plan? Do they have any input to i 13 the restart readiness as far as milestones, or is this 14 just.the existing NOC that's-overseeing plant i
15 activities?
16 MR. LEITCH: Yes. We have discussed that issue 17 with the Nuclear Oversight Committee. They are ;
18 formulating at the moment how they and to what degree 19 they want to be involved with the -- with the restart 20 plan. As I say, they report directly to the -- to the ,
, 21 board of directors. I believe their involvement will be 22 fairly intense and perhaps somewhat similar to the NSARC l 23 committee. I also believe that they may have a 24 particular interest in some of the cultural aspects in I
() 25 addition to the technical aspects.
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
.~. ,
w 65 1 But at the moment their plan for reviewing the 2 restart has not been entirely formulated, but it is 3 under consideration by that group at the moment. ,
MR. KEUTER:- .But'we have removed the -- reviewed 4
5 the restart plan with-them; and originally we did have 6 them on here. We took them off because they're totally ;
- 7 separate from what we're doing. We didn't want to feel ;
8 like we were spelling out what they were going to do.
i 9 We wanted them totally separate.
10 MR. HEHL: Are you -- this is helpful because it 11 answers ~one of the big holes that I had a question in.
- 12 That is what is the role and responsibility because you've got about a sentence here in the plan for their 1
13 14 oversight. And I guess are-you going to plan to 15 supplement this plan then, you know, in letters to us or ,
16 something? Is that -- is that -- what are your plans 17 for keeping us abreast and modifying this document? i
! 18 MR. MEISNER: I think we'll be happy to expand in 19 any areas that aren't clear if you'd like us to, if I 20 understood right.
21 MR. HEHL: Well, we had talked earlier that as you 22 come across additional -- additional findings that.
23 require additional supplements that you communicate that 24 information to us.
() 25 MR. MEISNER: Yes.
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
66 MR. HEHL: And I guess I would ask that maybe as f}
V 1
2 you -- as you fill in the blanks or round out the role 3 of how or whether~they round out their role, since 4 they're an independent group, that-you would keep us 5 informed of that and maybe supplement this document.I 6 think might be the appropriate way to do it.
7 MR. MEISNER: Yes. We can do that.
8 MR. HEHL: Okay.
9 MR. HEHL: Go ahead. [
10 MR. KEUTER: Okay?
11 MR. RULAND: Thank you.
12 MR. KEUTER: Well, we covered the first half-hour.
MR. HEHL: We're getting a lot of our answers done
("')
LJ 13 14 as we go along.
15 MR. KEUTER: The attachments really have a lot of 16 the detail. It goes through the flow charts for how we i
17 do the work orders, the learning bank, the plant system 18 review, the program review, the checklist we're using 19 for licensing affirmation, our QA affirmation. A lot of 20 the details is in the different attachments, and I 21 wasn't planning on going into that kind of detail today. l l
22 But what I did want to go into is what our 23 different appendices are and talk about those a little 24 bit because this is really where the meat of the issues 25 are. These are the things -- the specific issues coming
(')N THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
67 i 1 out of the confirmatory action letter and other areas 2' that we've expanded into.
3 The'first one is logic circuit testing. The 4 problem here is several of the logic circuits were not 5 adequately tested per Generic Letter 96-01. And we've 6 gone through that; and the root cause of this, as.we've j 7 determined, is the design basis function of component's j
-8 were not clearly defined. And we're going through and 9 beefing that up. Test procedures required were not 10 clearly defined. Correct resources were not used to !
11 develop test procedures; poor program ownership, l 12 management policy was to limit testing and ineffective 13 self-assessments. Now, these last four causes are going :
14 to be addressed in our developing our test improvement 15 program.
16 So what we're doing about this in the schedule for 17 this, the initial evaluation has been completed. We've 18 identified 102 discrepancies. We issued the LER. We've 19 conducted independent review of our evaluation. We'll 20 have a final report that we're going to submit or have 21 ready on mid April. We're developing temporary 22 procedures to make sure we test the 102 circuits. We've 23 developed disposition identified issues, evaluated root 24 cause recommendations and performed independent review
- 25. and performed the testing, j 4
THE REPORTING GROUP
' Mason Lockhart Hagopian & Ramsdell
68 )
1 I
() 1 2-So far the testing of the 102, we've completed 70.
We have 18 that are ready to-go, just waiting for-plant 3 status to complete them. And 14 we're writing the 1 4 procedures for. -So that will be done.before startup, 5 'and'we're well'on the way on that.
6 Then after startup -- we're using mostly temporary 7 procedures right now. But after startup we're going to ,
8 incorporate those into permanent procedures, also going 9 to develop a test improvement program by the end of the 10 year, and then complete any post restart actions as 11 scheduled in our root cause analysis.
12 So this kind of gives you a summary level of where f
13 we are. We're well on the way, and a lot of this
(}
14 testing has already been completed.
15 MR. HEHL: I guess, let me just to clear -- get 16 clear in my own mind, because this kind of forms a 17 pattern of what you're doing in a lot of areas, I 18 think. And that is you're -- you're fixing the problem 19 that exists but recognizing that you've got some 20 -infrastructure issues there that have to also be 21 addressed. And~you're not -- you're going to fix what 22 you can of those to support the adequate testing in this 23 : case, adequate accomplishment of the activity. But the 24 infrastructure fixes won't occur until like Phase 2 and
() 25 Phase 3, which -- in a lot of areas, right? Is that THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
69 1 going to be --
2 MR. KEUTER: Some of them are going to be.. fixed --
i 3 -some of them are going to be before restart. A-lot of Maybe some.of.them
- 4 sthem are goingnto.be in Phase 2.
. 5 'will be in Phase 3. And you can.tell, for example,.
6 develop a - 'this'one here is development of test- ,
! 7 improvement progrtm. That's not just for circuit 8 testing. That's for all testing. So we looked at the 9 extent of condition, said we need to improve our testing 10 program beyond just logic circuit testing; and that's 11 going into Phase 2. But we're intending by-these j 12 actions here to go beyond just circuit testing. .>
13 And as you can see,-when we get into'-- I think in J
14 Appendly G,' based on logic circuit testing, we've looked 15 at a bigger picture and developed another whole 16 appendice where we're looking at tech spec testing, 17 we're looking at IST and post maintenance testing. And 18 that's a good example of where we expand beyond just ,
19 this issue. So, yes, we are looking beyond just this 20 issue.
21 MR. CONTE: Excuse me, Dan. To. follow up on our 22 . previous questioning in terms of the work orders, the 23 L1carning process and what's a restart-issue, how would 24 .the inspectors identify in this Appendix A package what 25 .are the specific items that are going to get done-for
)
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell J
70 i
1 restart?
2 MR.-KEUTER: +Anything before July 15th. j 3 MR. CONTE: And what would be a good time for the t
'4 inspectors --*when,would you'-considersthis package a :
5 final' package:for-review with some exceptions to do's 6 and left to do's from the NRC -- what<would be a good 7 time for the NRC to come in and look at this appendix, 8 for example?
9 MR. KEUTER: Correct me if I'm wrong, but when we 10 get our final evaluation report, at that point I think 11' would be a good time to come in.
12 I've got my brains over here so -- but that would 13 be a good time. 'I would-say between -- right around the 14 1st of May we should be ready.
15 MR.-CONTE: Thank you.
16 MR. RULAND: You know, the --
17 MR. HEHL: Recognize that some of this stuff we've 18 already looked at as we go along. We have inspection.
19 MR. RULAND: The problem with that I think is 20 you're basically suggesting we come in before you've 21 dispositioned the identified issues.
22 MR. KEUTER: Like I'm saying --
23 MR. RULAND: And it causes -- 14 understand what 24 you're saying. I'm just saying that it causes us to 25 have to dedicate scme resources before you are really THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
71 1 completely done.
2 MR. KEUTER: -Well, for example, there's 18'that 3 we're waiting for plant conditions.: I mean, some of 4- this testing willibe;done-as>we're going up. , s 5 MR. RULAND: I understand.
6 MR. KEUTER: But I think'we've'got, you know,'70 7 percent of them done now. That's going to give you a 8 pretty good indication of how we're handling it.
9 MR. HEHL: You know, the reason we're pushing hard :
10 on this is not -- you know, there's really two things.
11 One, we're -- we're committing resources -- you know, we 12 have been committing resources to -- to look at ongoing 13 activities. We've'had certainly resident inspectors.
14 They've been augmented by regional inspectors. We've i 15 had those augmented by contract folks and things. A lot 16 of resources have gone into it so far; and -- and that's l
1 17 going to continue. i 18 But certainly it -- in our mind, it's a -- it's a 19 measure of your performance as a management team to come l
20 forward with a package that is complete; you've reviewed 21 it; it's gone through your process. And at that point, 22 you know, then we will -- in addition to the work in i 23 progress looks that we'll see, you-know, we're gcing to 24 want to take an indepth look into a lot of these 25 things.
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell !
J
72
(j
\~
T 1 And I guess the point being is we don't 2 want -- we don't want -- you don't want for us to 3 identify things that you haven't identified because 4 it -- you know, it certainly raises questions with 5 regard to the robustness of your process. So we would 6 just caution you to be ready when you bring.these things 7 in, not only from the resource expenditure as far as us 8 reviewing something that's not ready for closure. There 9 is also a reflection on the process that has to be 10 considered. So I guess that's part of the thrust.
11 MR. MEISNER: Okay. We understand.
12 MR. KEUTER: The next issue is cable separations.
13 Discrepancies were found in the cable separation (G) A program was initiated to identify and 14 configurations.
15 evaluate and resolve discrepancies for cables important 16 to safety. Our root cause here was inadequate labeling, 17 drawing errors, unclear cable separation criteria, and 18 inadequate training of the technical staff on cable 19 separation.
20 Our corrective action summary is we've completed 21 our -- rearticulated our cable separation requirements 22 on both licensing bases, design bases and implementing 23 criteria. We're in the process of our verification-24 inspections and assessments. We're about 90 percent 25 complete through that.
(;J
(.-
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
I l
73 l 4
1 The first phase which is the sleeves, ducts and (v~'}
2 conduits, we're complete with.that-assessment. , ;
3 Phase 2, which was originally cable trays, we are 4' 98 percent through that. We've -expanded that into 5 ' Appendix R, alternate-shutdown-and separation. 'We have ,
6' just' started on that. Again, Lit's an, area ~that we've 7 expanded into,.so we just started that. So that total 8 is -- we have 33 packages out of over 500 that we have 9 left to do of Phase 2. Our main control boards, we're '
10 about 50 percent through that and hope it will be done 11 by the end of May.
12 The evaluation of the inspections, we're about 70 13 percent through that. We're planning on submitting a
{
14 report to the NRC around June 1st. And after that point 15 we'll be ready for you to come in and look at it.
l 16 Resolution of all the discrepancies is in 17 progress. We're going to correct or accept as is. l 18 Other work efforts, and this goes into, you know, j 19 beyond just the specific issues, is, you know, fixing 20 the labeling, hazards evaluation, closecut of field work 21 except for design changesj engineering training, work 22 control process improvement. And then.again after "
23 startup, we'll have some things that we want to clean up 24 after startup; and they will be scheduled in our plan.
() 25 MR. CONTE: Let me pursue the angle here of the THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
74 1 need for an immediate culture change, if you will, f"J}
For example, the 4 2 versus a long-term culture change.
3 root cause in this area was-inadequate training. And I I
4 couldn't help noticing, and>maybe_it's an oversight,s but 5- 'in your-appendix there'is a strong commitment to- *
'6' proceduralize the~ Phases 1, 2, and:3 of the actual work 7 and assessment of conditions on the cable separation.
8 There is no mention of training of people using those 9 procedures. Was that done or was that just an oversight
' 10 in the plan?
11 MR. NICHOLS: Yes, it was. It wasn't mentioned in 12 the plan, but indeed it was.
13 MR. CONTE: Could you come to the mike and identify 14 yourself, please?
15 MR. KEUTER: The question as I read it is did we 16 train people before we sent them out on the new 17 criteria. And that's basically on step 1, you know, did 18 we train the people on that new -- up here?
19 MR. NICHOLS: Yes. First my name is Steve 20 Nichols. I'm the manager of configuration management.
I 21 For the purposes of cable separation, I'm also heading 22 up the engineering activities on that project.
23 '
Yes, it was not mentioned in the appendix that went 24 in with the restart plan; but'indeed, as we created.
() 25 inspection procedures, inspection guidance, we then THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
75 1 stepped into the classroom and had all hands training 2 Esession on exactly-what it meant. That also extended !
3 'through lessons learned through the inspection. process.
4 As we learned.that our procedures weren't as good as ,
5 'they ought to be, confusion arose. We had to modify i
6-them before we executed the procedure changes, and we 7 stepped back into training the craft and the 8 inspectors. ,
9 MR. CONTE: Was the quantity inspection department !
10 or quantity performance department involved in that f 11 training?
i 12 MR. NICHOLS: Yes, they were. In fact, through the 13 carly stages of inspection,.first phase we actually
)
14 created two teams. One was an engineering based team to 15 do inspections. That was Phase 1. And a separate ;
16 independent team was made up of quality programs 17 individuals. We gave them identical packages to go out 18 and inspect, and that's how we obtained a second 19 verification of the information gathered from the field -
20 as we compared the two packages. We modified that ,
21 slightly for the.second phase, but quality programs was 22 indeed included in inspection in Phase 2.
23 MR. CONTE: Thank you.
24 MR. KEUTER: Thank you, Steve.
25 The next issue, Appendix C, we discovered a THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
_ . . _ __ _.. _ _ _ __, -. -_. . ~ . _ . . . .
)
76 l
1 situation when our offsite power supplied from 115 KV 2 Section 69, the voltage will not recover quickly enough 3 after a plant trip when it's the only supply to offsite 4 power after a plant trip and. safety inspection prevent )
5 load shed diesel to generate auto start. The low 6 voltage condition was. caused by the auto start of'a l 7 motor driven main feed pump.
8 The cause here was we didn't have -- at the time ;
I 9 that this calculation went through, we did not have an !
10 interdisciplinary review of calculations for the voltage l
11 study. And we found -- in this situation what we found l 12 is that the assumed condition, which was a -- a transfer !
13 of two running pumps, wasn't the limiting case. The 14 actual start of the motor driven main feed pump was the i 15 limiting case, was more limiting; and that's what we 16 discovered here. ,
r 17 The corrective action, we've implemented an j i
18 electrical calculation design review committee. l 19 Actually, this has been done several years ago due to a !
20 previous problem. We submitted a tech spec change.
21 That's bee.n completed. We're-modifying the auto block j i
to block the auto-start or and/or trip the motor driven I 22 23 feed pumps. To prevent this condition, we've ;
24 implemented the tech spec when we receive it, and we'll 25 revise.the voltage study before restart. Long-term, THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
77 1- we'll evaluate the need for additional long-term actions 2 to improve offsite power availability. >
3 Any questions?
4 'D, which wasn't really.part.of the confirmatory 5' action-letter, we've gone through an extensive steamt 6 generator' inspection ontboth-the primary and secondary 7 side.not only to meet regulatory requirements but to 8 verify the condition of our steam generato.rs. We 9 really -- we didn't do a root cause. It wa:'.n't an 10 issue. If it was a major issue, we'd have it on our 11 plate'for restart. So we made an appendice out of it.
12 This is kind of a summary of the inspection we're 13 doing. We're doing 100 percent bobbin. Items 2 through 14 8 are basically we're doing a plus point. We started 15 that inspection today. We started pushing probes this 16 morning. It will take about two months to get through 17 this process, and we'll keep you informed of where we 18 are. There's not much more we can say about it right 19 now.
20 Fuel failures, I guess this is a good example of
-21 what I consider a,new culture. Even though it wasn't 22 required, we went in-and inspected our -- our fuel. We 23 had fuel leakers. We found nine assemblies that were 24 leaking. That included 76 leaking rods in those nine 25 assemblies. We also inspected the nonleaking rods. We THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
78 !
I found significant wear in those rods, and based on that
'2 we made a decision even~though it>wasn't required to-3- - replace all 68 Westinghouse fuel assemblies.
4 The root-cause"here was' rod, fretting. That was'due ,
5 to inadequate Westinghouse design. And contributing to 6 that is we' implemented this unproven Westinghouse design f 7 without a -- you know, a pilot assembly or a proven I
8 design someplace else.
9 Our corrective actions, basically there we're {
10 replacing all the assemblies. We have imolemented the 11 requirement to complete the lead assembly requirement ,
i 12 before we implement a new design change -- new fuel 13 design. We're basically going to proceed with reracking 14 the fuel pool. We're going to offload the-fuel by 15 February 7th. We're going to have fabricating fuel,t 16 should be delivered around mid-June. And then we'll 17 reload the -- the fuel. So that's in your handout.
18 MR. CONTE: Excuse me, Dan. I just happened to -
19 notice that the corrective action slide is a little r
20 further ahead. We'll reorder it when we put this on the 1
21 docket.
22 MR. KEUTER: Okay.
23 Appendix F, corrective action program. Our l 24 corrective action program -- we've identified several 25 problems with our corrective action program. There are THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdel;
79
(} 1 several issues here that we've identified. Back in mid
%_J 2 '95 we kicked off a reengineering team to look at our 3 corrective action program. We had several programs.
4 They came back with the corrective actions.to address 5 all the weaknesses. The cross-functional team has been 6 completed. We~actually started implementing our new*
7 learning process the 1st of January. These are the 8 things that it actually goes through to solve a lot of 9 our corrective action program issues. It's up in place 10 and working. We have several -- as a -- in any process, 11 we have several glitches that we have to get through, 12 some of those that we're going to complete in the
(\
N ,/
s 3
13 future. ;
l 14 So we've implemented a new program at the first of 15 the year. Things that we've done after the first of the j I
16 year, we weren't fully staffed when we started. So l 17 we've gone through and staffed up. We've had a third 18 party review of our design, our corrective action 19 design. We've had several things that we wanted to 20 implement in our corrective action program to support 21 restart. One of the things is to put in a field so that 22 we can identify restart issues which is being -- is 23 completed; and we're testing it this week. We also want 24 to sort by department so we can get -- feed this 25 learning bank into our department assessments. Also, we
[]
v THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell m
80 went through our engineering reorganization.
i 1 So we have
}
2- to reassign'all of-the. people into -- so we.can do it '
3 sort of by department. ,
i 4 'There are severalithingsethat.. carry on in theyo
- ' 5 future past-'this. We're going to-have-a monitoring, plan ,
6 -to see how we're-doing.' We're-going'to. respond-to the 7 reviews. Actually we have a lot of old corrective ,
8 action program issues that are going to feed into the ,
9 learning bank. We want to make sure that we've reviewed l f
10 all of those previous corrective action programs against 11' ' our criteria <and incorporate those into the new learning 12 bank process, and we're in the process of doing that.
( 13 -Complete our restart review, and we're well along in 14 that. And then after restart, do an independent l 15 evaluation upgrading software issues at that point and 16 incorporate HR project data collection into the j i
1 17 process, 18 So this is a major, major undertaking. It's 1
19 bearing fruit. We've lowered the threshold. We have a jL 20 lot of things coming in that.we're in the process. t 21 Quite honestly right now though, our backlog and- -
i 22 learning process is. growing; and we've got to get our 23 hands around it. But definitely all of the issues we're 24 going to screen for restart.
25 MR. HEHL: Including the old ones?
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
81
[)
v 1 MR. KEUTER: lacluding the old ones.
2 MR. HEHL: Because the dates here, it looks like 3 you have the old ones. Are you going to start the 4 reviews on the 30th?
5 MR. KEUTER: No. This will be done by the 30th.
6 Actually, a lot of our reviews have already been done.
7 MR. HEHL: Are all of the old items coming from the 8 other various corrective action systems, all will be 9 part of the restart screening criteria?
10 MR. KEUTER: Correct, and we even have a slide for 11 that.
12 MR. CONTE: What's a little surprising is the 13 independent implementation review after restart, 930.
['
14 Is there some element of that independent implementation 15 before restart to assure effectiveness?
16 MR. KEUTER: The question is we're doing the 17 independent implementation review after restart, and 18 what's the purpose behind that? Are we doing anything 19 to --
20 MR. CONTE: Please identify yourself.
21 MR. SHEAN: The name is Arthur Shean. I'm the 22 learning processes manager. Interestingly enough, very 23 shortly after we went live, we had actually four 1
24 different assessments being made of the design in the 25 early implementation of the learning process. Those are
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THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
- --- - - = . . _ . . -. - _ _ _ . . - -. - . - - .
1 i
82
() 1 2
the ones we talked about in No.
evaluation.
3, third party design We'had a noted-individual with national < rep 3 come in and take a look at the design, Bill cochoran. l L
4 We also had an-organization <that does a lot of root . !
5 'cause activity >come~in. They're.doing a root causer 6 evaluation. And'they took a look at ourtsystemuto see 7 if it would have been -- had the capability of solving P
8 the problem or identifying the problem of an earlier ;
9- event, if it was in place.
10 We've also had the NRC come in and do a 4500 audit, [
-11 andzwe're going to get some feedback from that. And our t 12 quality programs department has done an extensive i 13 -evaluation of our process.
14 The one you see there is one that you take -- all l l
15 of those came up with basically the determination that 16 they thought the design was good and looked like it was 17 going to be productive. But they didn't have a long 18 enough track record to determine whether or not we were I
19 going to be able to fully implement as designed. And 20 that's what this later on evaluation is for is to look 21 at whether or not the design is being. implemented as it 22 was laid out. So that's the purpcse of it. And we'll 23 be doing that as~well as monitoring performance 24 indicators along the way that will give us indicators as
() 25 to whether we're tracking along that direction.
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
83 As indicated, one of the things we're picking up
(~'
i 1
2 from our monitoring is the fact that some of our 3 intermediate processes need to be looked at closer "4 because we're not getting everything through fast enough 5 .because of the large bulk of things.that.were dumped on 6 us all at once. Right now, for. example, since January 6 7 we now have in the learning bank 1,838 items. I went to 8 a meeting earlier. I went in at 1,808, came out of the 9 meeting with 1,838. So it's going quite quickly. The l 10 items are being identified and put in.
11 'MR. HEHL: I guess along those lines -- I guess 12 along those lines, because you are getting substantial 4
13 input into this system, which is -- is good; but on the 14 other hand, it certainly puts the -- the burden of 15 adequate evaluation of a large number of items. And I 16 guess the question is, you know, what are you doing to 17 stay ahead of the tidal wave?
18 MR. MEISNER: Well, I'm not sure we're ahead of the 19 tidal wave. What we're doing is trying to catch up to 20 the tidal wave right now. And in fact, we just met 21 earlier today to identify the traditional resources we 22 need to start closing out items as quickly as we're 23 generating them. We're doing a good job, that chart Dan 24 put up on identifying new issues and driving the 25 threshold down. It is a resource issue for us to close THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
84 ,
1 those items in the same way. And that's something that 2 we're going to have to get our hands around in the very 3 short future.
4 MR.-HEHL: Are you doing any challenging, I guess, 5- of the system to make sure:that -- that because you do i 6 'have a large-number andsyou're-not being able to,close ,
7 them out as quickly as you would like, that that doesn't 8 send a negative message to your folks as far as your l f
9 intent to complete items?
10 MR. MEISNER: That's a real good question. We 11 continue to have dialogue with people. And when you l 12 lower a threshold in the system like this, you create 13 the expectations on the part of people when they put 14 something in that it's going to get addressed. And 15 that's a continuing point of dialogue that we need to 16 get across to people that -- that if its of quite low 17 significance, and there are a number of items in the i 18 system like that, then we are going to have to deal with 19 it on a priority basis; and it won't be -- it won't be 20 addressed tomorrow, but it will be addressed 21 eventually.
l 1
22 But you're right. We need-to continue that 23 dialogue and make sure people understand that, else the 24 system then becomes self-limiting down the road; and 25 people won't use it. But we haven't seen any indication
)
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
r l 85 1 of that.
)
2 MR. KEUTER: Okay. And I'd like to point out here 3 that the prioritization -- make sure we, you know, 4 review and' correct the important-things. And we're..
5 identifying a lot of things here. .But, you know,'the 6 levels l's'and 2's are as shown'at the top; and we-want 7 to make sure we address those in a timely manner. But 8 that is a major --
9 MR. MEISNER: And let me just add to Art's 10 answer -- maybe he said it but I didn't hear it -- like 11 any program, the learning process has to go through a 12 restart review on its own merits. And we need to have a 13 determination, both for the process and for the 14 department that handles it, that those things are in 15 shape to restart. So that in-addition to the 16 assessments he has talked about, that assessment will 17 occur as well.
18 MR. ZWOLINSKI: Mike, you've kind of touched on an 19 issue on which I've been taking a few notes. I guess I 20 have one question in maybe eight parts or so.
21 MR. MEISNER: I'll start writing them down.
22 MR. ZWOLINSKI: Fundamentally,- people are expected 23 to be putting stuff into the learning process. But.then 24 there is an expectation that it comes out but with the 25 correct prioritization I think with the ones before, the THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
r 86 1 higher tier essentially leading to root cause analysis.
2 And I go back to I think it's Page 10 in the book, the ,
3 chart where you show root cause at the center.of the 4 -universe of a lot of activity. And it strikes me that 5 that root cause box is awfully important, that that, f 4
6 quality root-cause be -- be performed. Where do you all 7 feel you're at? Do you think that you're getting your 8 arms around quality root cause evaluations today? ;
9 I mean, I see on that one chart as you go through .
10 January, February, March, the numbers that are in the !
11 one category are fairly high. And if that's an 12 important contributor to the Phase 1 of the restart i
13 plan, it strikes me that what you've done today plus 14 what you plan to do tomorrow is pretty important to the 15 success.
. 16 MR. MEISNER: You're exactly right, John. We've 17 been focusing a lot of attention on that. The first key 18 to quality root cause evaluations is some quality 19 training and quality people.
20 Art, maybe you can jump in with the numbers; but as 21 I recall, you know, back at the end of last year we had 22 only a handful of people that were qualified by our
< 23 processes to do root cause evaluations. Today I think 24 we're pushing maybe 70 people?
25 MR. SHEAN: Closer to 80. There are actually 39
[)
i THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
i l
1 87 I
~' senior evaluators that have been qualified at the senior
/ 1 b) 2 level, and there are 40 that have'been qualified at the 3 evaluative level. Prior to us going live, there was 4 really no specific qualification-requirement to be an 5 evaluator. 'That was part of the-requirements when1we 6' went liveis to have a> specific qualification before a 7 person could do an evaluation.
8 MR. ZWOLINSKI: It just strikes that if an issue 9 goes into this learning process, you need to ultimately 10 get to the root. And in so doing, you may step on 11 somebody's toes because you're talking about people i 12 here, I think, as a softer side issue and to get people l
13 to buy in. And that's kind of the -- the next area I
()T E
14 was going to flow to. This -- this to me is difficult 15 times to assure that people can accept constructively 16 that whatever problem occurred, you've identified it; ,
l I
- 1) and you can take appropriate corrective action.
18 And thus, I see this as a struggle within the 19 context of your recovery activity that -- that you want 20 to enhance or modify the culture; but yet you want to do 21 it in a positive way. You don't want to do it in a 22 negative way. And I think, at least my view of root 23 cause evaluation has a potential to have a lot of 24 negative overtones to it if it's not handled correctly.
25 MR. MEISNER: It sure does. We have a resource i
[ }
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
88
(% 1 problem today, and I'll talk about that in a minute.
t G'/ 2 But I think one of the ways you don't get buy-in on root 3 cause evaluations is when you have sort of outsiders 4 'come in and do the root cause-evaluation for you. Maybe 5 you have a small cadre of people, and that's all they 6 do. So they're always outsiders to whoever they're-7 evaluating.
8 And one of the solutions to that is to broadly 9 distribute the knowledge and capability of doing root 10 cause evaluations and essentially demand that if I have 11 a problem in maintenance that's a level 1 or 2, then I 12 identify an owner for that problem in maintenance; and I 13 require that that owner come up with the evaluators, the
(}/
\m- l trained qualified evaluators that are knowledgeable in 14 15 that area from that department do the evaluation.
16 And when you do it that way, you tend to find much i 17 more buy-in to the results. People know that the person i
18 is intimately knowledgeable in the area they're 19 evaluating as well as being a qualified root cause l 20 evaluator. And -- and you tend to have better -- better 21 buy-in overall. So that's one of the benefits of trying 22 to get a lot of people trained and certified in being j
23 able to do this. l 24 But on the other hand, I need to tell you that even
(}
C/
25 though we've got people trained, there are so many other I THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
89 ;
1 demands on their time right now that we're having 2 difficulty, like I said earlier, closing out these items 3 >
as quickly as we open them. And we do have a backlog of 4 -root cause evaluations that we're trying to identify 5 -different ways to. provide appropriate resources to get
'6 those' things started-and completed because unless you 7 get the root cause evaluation done, you're kind of dead 8 in the water for the rest of the process. t 9 MR. ZWOLINSKI: And Mike, what I hear you saying 10 sounds very good. But the translation is the 11 implementation; and that is -- maybe a level 1 is ---is 12 a little too obvious because we all think that needs a 13 good root cause.
14 But as evaluators look at these issues -- and 15 they're either 1, 2, 3 or 4 -- gee, it's -- let's make 16 it a 3, and all I have to do is wave my hand at it, 17 whereas a 2 might require a little bit more rigorous 18 analysis. And in the mode of having a large number and 19 continuing to grow, will the evaluators grow a little 20 bit more less rigorous and tend to default to a lower 21 number priority as far as the type of root cause, which 22 could -- could settle in? And then are -- are your 23 people buying this? Are they actually stepping up and 24 accepting the ownership of the individual issue whether l l
25 it's a priority 1 or a 2, 3 or 4?
l
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THE REPORTING GROUP '
Mason Lockhart Hagopian & Ramsdell
90
-1 And I know there's been some examples of about 4500 2 inspection,'but-there's certain isolated cases at least 3- in which maybe ownership hasn't been totally 4 forthright. And to me that's some of just the adoption ;
5 of a new program.
6 MR. MEISNER: 'Right. Well,- before you get too many 7 questions, John, let me answer the first two.
8 MR. ZWOLINSKI: Okay.
9 MR. MEISNER: There is a problem that if the l l
10 evaluators feel overloaded that they may come up with a 11 lower level priority to avoid doing an evaluation. And 12 if we allowed evaluators La make that determination of 13 significance,-then that could occur. But what we have 14 is a separate and distinct group of screeners whose 15- sole responsibility is to identify the significance 16 level of a particular item. They have no responsibility 17 for the -- the root cause evaluations; and they're I
18 independent of any of the other organizations in the 19 plant. So they're the ones that set the -- the risk
' :2 0 level, the screening, level. And the evaluators can't 21 change that once that's been set.
22 Your second question is -- I guess -- I'd say it's 23 are people accepting ownership of'these issues once I
24 they're identified? Sometimes yes and sometimes no.
25 And we -- we have some ways to go along that path THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
1 91 J
1 because I think the system design allowed people to not
- 2. accept responsibility.
)
3 o Let me see if I can explain that. Once an item is 4 ldentified in the-learningnbank/ then11t's up.toia.
5 suggested group-to -accept. that item. - '
j J 6 MR. ZWOLINSKI: Okay.
i 7 MR. MEISNER: It's not assigned to that group.
8 It's up to them to accept it. And they can let that ,
9 acceptance take a fair bit of time, or they can ignore ,
10 it entirely. And the system is not real responsive in 11 driving that acceptance. In fact, that's one of the-1 i
j 12 things we were talking about this morning that we're 2 :
, 13 going to be changing very shortly, is when the screeners i
14 identify the significance level of something, they're l 15 .also going to assign an owner. It's not going to be; )
. i 16 that they're going to ask for an owner. They're going ;
- 17 to assign an owner and ensure that right from the ,
I 18 beginning an issue has an owner and has some 19 accountability and responsibility.
i 20 But in a situation where resources are tight today,
, 21 and we all know that, you know, we're trying to fill 22 some 100 positions here, it's note too surprising that l 23 unless you assign things rather,than ask for people-to i
- 24 take on more work, that -- that an issue might be pushed 25 off to the side. So I think the situation will be I
THE REPORTING GROUP ;
Mason Lockhart Hagopian & Ramsdell .
i
92 l
1 different once we free up the resource problems a bit, 2' but right now we're taking the step to make sure-that we i 3 have assigned owners.
4 MR. ZWOLINSKI:' I. guess-I'm making a point out of 5 it because I-think it has very much a direct nexus into l 6- your corrective action program,'and corrective action is 7 a very important program. And I guess we're just going ;
8 to have to observe it, maybe sit in on some of those 9 meetings to get a firsthand observation of how the 10 decision making actually goes, and ultimately get -- get 11 some results coming out the other end. You suggested 12 you're going to maybe retain a contractor to help .
13 disposition some of these' items? Did I hear you 14 correctly?
15 MR. MEISNER: We're considering a range of options; ]
16 and one is to provide some contractor assistance in 17 closing out items and doing the leg work and writing the 18 memos and setting up the training or setting up the -- l 19 the whatever. That isn't to provide ownership to the 20 contractors but to provide' assistance to our owners'that 21 need to close those items.
22 MR. ZWOLINSKI: Well, I guess I'll just close 23 that -- that that area just strikes-me as -- as you have l 24 a lot on your plate already that's very well defined; 25 but you don't want to make any more mistakes for 3
THE REPORTING GROUP '
Mason Lockhart Hagopian & Ramsdell
93 i
1 tomorrow or for the future. And thus, being tough on 2 yourselves in that area is probably pretty important.
3 And -- and the emphasis you're providing it tends to 4 reinforce much of what I-think is.in this plan that-5 seems to be a root to the success of the plan, at least 6 my interpretation.
7 MR. MEISNER: Thanks. We agree.
8 MR. ZWOLINSKI: But the ability to drive this to 9 all your staff -- and I guess I would even go to your 10 contractor staff, maybe Maine Yankee employees, everyone 11 seemingly has to be able to get into that area with some i
12 vigor so -- )
13 MR. MEISNER: We agree, iO 14 MR. CONTE: Just one last question for Art. You 15 mentioned this third-party design evaluation, action 3, 16 which is complete. They indicated that there just 17 wasn't a long lead time to judge the effectiveness of 18 implementation. And to give you -- does that include 19 that they couldn't evaluate root causes or closed out 20 passages?
21 MR. SHEAN: Yes, that's correct because again it's 22 almost like starting everything like a -- like a horse 23 race at ene time;Jand everything is kind of going 24 through a certain sequence of activities.
25 MR. CONTE: Let's move on.
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
94 1 MR. KEUTER: Well, I appreciate those questions. ,
, 2 It gave me a break.
3 This is a flow chart. This is Attachment 5. I 4 just want to point out that we are taking not only the 5 new learning bank issues. We're taking the old items 6 :that haven't" been incorporated into the learning bank 7 and taking it through the process plus the existing 8 stuff in the learning bank that has been put in since 9 January 6 and taking it through the whole process that 10 ends up, again, we're taking the nonrestart issues plus ,
t 11 the completion of the restart issues and ran it through 12 our department assessments all the way up through the i
13 steering committee.
14 Appendix G, this is basically a fallout of our 15 96-01 where we looked at extent of conditions and asked 16 the hard questions about if we had this problem with 17 circuit testing, logic circuit testing, do we have 18 similar issues with tech spec, in-service testing and 19 post maintenance testing.
20 So we have pulled the string on this. This is part 21 of our extent of conditions in action. We've developed 22 a separate appendice. And the root cause, well, in 23 actuality, we're finding that our tech spec 24 surveillances, they haven't found significant problems.
25 And that's the good news. We've looked at this very THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
95
/~'i - 1 hard. But we found some indications of causes or things U 2 that we need to correct, insufficient code 3 clarification, our IST program, non-participation in 4 industry events, ineffective review process and unclear 5 management expectations.on=the~ program development. And 6 this is mainly having to do with IST program. So we --
7 we're still asking the hard questions.
8 So this is basically in three parts, and I'm going 9 to cover the first part which is the tech spec testing.
10 We've gone through that. We've had ABBCE come in and do 11 initial review and assessment, and they've identified 12 basically 300 questions in going through. And they took
( 13 each of.the tech specs and verified that we had the 14 surveillance -- the written surveillance that implements 15 each of those surveillance requirements. 95 percent of 16 these questions have to do with procedural enhancement, 17 the wording of the procedure, can we better word it, 18 those types of issues. The 5 percent that isn't in that 19 category, for example, a swing pump, where we test the 20 swing pump but we don't necessarily test the swing pump 21 when it's lined up to frame A and frame B, those types 22 of issues. But we haven't found anything that makes 23 anything inoperable or nontested.
24 We're doing an independent review by a different 25 contractor which is they come in and do an independent
}
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
l 96 1 review and assessment, and they come up with any action 2 that comes out of that. Our resolution of issues by the l l
3 first of June and complete any additional testing by the j A first of July. Again, 5 is theisame as you saw on.the 5 circuit testing where.we're developing a surveillance 1
6 improvement program,- you know, going beyond ..just : this '
r 7 one issue and saying, hey, we need to improve how we do 8 testing.
9 As far as in-service testing, we've completed l 10 the -- complete the initial review by March 31st. Is 11 that done?
12 So that's been completed. Assess completeness l
13 and scoping by -- by July 1st, IST component basis 14 document completion by the end of the year and then )
15 implement-our -- our new code testing by next June. So :
1 I
16 this goes beyond just a restart issue. We don't have 17 that many restart issues coming out of this, i
18 Post maintenance testing, we added that to the ;
19 list. We're going to do assessments of post maintenance 20 testing. .We did.have - .looking back at our corrective 21 action program, we-did have a couple of hits on that in 22 the last couple of years. So we're going to assess that l
)
23 and verify the completeness of that. And that will be 24 done -- that assessment will be done before restart.
- Q 25 So I guess I just want to emphasize again, this is
%J THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
l 97 1 a good example where we've asked the hard questions, 2 expanded beyond just the obvious issues of circuit 3 testing, and assessing where we're going on all 4 testing.
5- , Environmental qualification, some EQ components in
'6 the reactor building.arecbelow-maximum flood level and 7 not qualified for submergence. Root cause is no EQ 8 coordinator on site, failure to maintain and upgrade EQ 9 program, station sensitivity to EQ compliance, !
10 inadequate design change process to control EQ 11 attributes, and lack of EQ training.
12 And these are some of the similar root causes you 13 saw in cable separation and logic circuit testing. The 14 reason I said we were yellow in training was because of 15 technical training, and this is one of the feeders into 16 that.
17 As far as our actions, perform the root cause is 18 complete. Perform EQ program assessment is complete.
19 Fill EQ program manager is complete. Relocate post 20 accident monitoring equipment, reviar .nd disposition EQ i
21 assessment concerns,: qualify and relocate equipment by 22 the first of July, complete turbine building high-energy I
23 line break analysis by the first of July, evaluate 14 turbine building equipment for safe shutdown before
/~' 25 startup.
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
t 98 t
( 1 And then we get into our post startup which is ;
i E 2 review design change process, develop and complete EQ 1 I 3 training, EQ master list verification and evaluate and ;
4 incorporate EQ-program enhancements. ,
S MR. RULAND: Could.you give.me some insight as-,to 6 why uyou .think your! EQ master dist -verification is an 7 issue post restart?
8 MR. KEUTNR: Matt, can you help me out?
9 MR. MARSTON: Sure. I'm Matt Marston. I'm the f 10 engineering programs department manager.
11 I guess the reason that we feel that that's a
} 12 long-term issue is because we feel that we haven't ;
13 identified up to this point any instances where a 14 component that was required to be environmentally ,
I 15 qualified-was not in the program. The issues that have 16 been identified is -- is -- have to do with EQ 17 submergence of components that are within the program 18 scope already. So we haven't identified scoping of EQ 19 as a problem area. And we felt that there were
- 20 enhancements that could be made in.the IX) master list as 21 far as the amount of.information that was available in 1
22 the master list as well as better documentation,Lthe 23 basis for the master list. But-without specific 24 instances of a failure to qualify components or include 25 components in the qualification program, we didn't feel Tl!E REPORTING GROUP Mason Lockhart Hagopian & Ramsdell-
t 99 l l
1 that was a startup issue.
O. 2 MR. RULAND: Thank you.
i 3 MR. YEROKUN: ,Just a quick question on this Item ;
4 No. 8. On your list there it says evaluation turbine !
'S < building: equipment for.. safe : shutdown. .Is that an
'6 evaluation process 1or.do ;you e plan .to qualify- or -- . at 7 least for startup I would think that's not just a matter !
8 of evaluation. It's ensuring that the equipment is EQ 9 qualified.
10 MR. KEUTER: Yes. We have to ensure that before 11 startup. So basically we do the analysis in 7, evaluate ;
12 the analysis and make sure our equipment is qualified.
13 If it isn't, we don't start up.
14 MR. RULAND: So am I correct in assuming that all 15 the equipment that needs to'be qualified will be 16 qualified, and not just qualifiable but qualified prior I
17 startup?
18 MR. KEUTER: Yes. ;
l 19 Go ahead, Bruce. !
20 MR. HINKLEY: Bruce Hinkley. I'm the vice ,
l 21 president of engineering. l f
22 The -- specifically the turbine building,,we are ;
23 continuing in the mass and energy release and taking a 24 hard look at the environment generated by the 25 high-energy line break. I guess the short answer of it THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
i 100 1 will all be qualified startup may not be completely i 2 accurate in that what we may=do is take actions that !
3'
- change the environment versus qualify the equipment;as !
4 in exhaust panels-in the turbine; building and/or-spray ;
- " 5 " ' deflectors or ' shields - around potential- break zlocations. !
\
'So until'we finish'the massuand energysrelease'andaget !
6 l 7 the verification of the individual components, I can't 1
commit to qualify what I might not have to qualify
- 8 i
9 but -- -;
10 MR. YEROKUN: I understand what you're saying, but :
?
i '11 it'still means it will be qualified for the 12 environment. If you're going to change the ,
~13 environmental, you're going to change the equipment is
)
} 14 what it boils down to. <
i
- 15 MR. HINKLEY
- That is true. And right now we don't
, 16 have, you know, enough completed information to give you 17 a specific list and the actions. So that's in ;
18 evaluation right now, i
)
i 19 MR. KEUTER: That's what I meant to say. ]
20 If there's no other questions,.I<still have six f
)
- 21 slides, but that concludes my presentation.
22 MR. SELLMAN: 'Okay. Are there=any general -
- l 23 questions?
24 MR. CONTE: What's the status of the December loth
'25 response to the ISAT? How does this fit into the
)
THE REPORTING GROUP Mason Lockhart-Hagopian & Ramsdell
J l
101 1 readiness report or the readiness -- your readiness 2 plan? [
l 3' MR. KEUTER: We've taken the ISAT, and we're going a
4- 'through that-and-screeningmit, determining those items ,
s 5
- ~
that-are required for'restartfagainst the criteria-and 6 ' making'sure'thosecare donesaDoes-that-. answer youri #
7 question?
8 MR. CONTE: So is it my understanding that all of 9 the commitments in that document are being transcribed 10 into the learning process and work order system? And we 11 will-find them -- if the commitment was, say, March 12 31st, I assume it's going to get done by March 31st.
13 Therefore, it's being done before restart.
14 MR. KEUTER: There might be some issues that we 15- committed to date in the restart plan assuming that we 16 would be in outage in the fall. And some of those won't 17 necessarily meet the restart criteria, although I don't 18 know of any offhand, that we can't meet that date 19 because we won't have the parts or something like that.
20 But>if we' change any of<the: commitments in that letter, 21 we will let_you know and the reason for it.
'22 MR. HEHL: Yes. I think that's part of the' thrust l l
23 of the question is that in this -- in the middle of this 24 plan, it did not address whether or not this scoped the
/T 25 -- the other response. And that may be something you V
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell i L
102 1 might want to -- it wasn't clear to us whether this 2- superseded the response or -- or the other response was 3 still out there. And I guess until we -- until we 4 clearly understand,that,-I guess we're looking for you 5 to live with both until you tell us which one is ---is 6 the right one.
7 MR. MEISNER: Yes, yes. The ISAT report is 8 clearly an input in a feeder up there and a key feeder 9 into the -- the restart process. And as Dan said --
10 MR. HEHL: Well, what's not clear is whether or not 11 this -- this new set of -- of criteria and actions 12 supersede what you indicated in that ISAT response.
13 MR. MEISNER: And we'll make that clear, Bill. I
(~]
\_-
14 think there may be a few minor changes, but I'm not 15 aware of anything real major. And a lot of it has to do 16 with, like Dan said, with timing. When we wrote the 17 ISAT report, we had a scheduled outage in September.
18 Things have changed.
19 MR. ZWOLINSKI: One of your early graphs, Dan, has 20 the three circles, Phase 1,-Phase 2, Phase 3, the 21 business plans, show those interconnected. I mean, I've 22 been reading this Phase 1 book principally or what you 23 provided. I guess I hadn't thought about looking into 24 the business plan or spending much time on Phase 2.
25 Should the agency have -- should we be aware, or is this
(}
\-
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
_ _ ___ _ ~
103 1 something that we don't need to be aware of as far as 2 the products that are being developed?
3 MR. KEUTER: Well, we have made a commitment in our 4 '
-submittal to<in the short-teramplan submit that, you-5- know, within the same--time: frame we, submit.our ready:for 6 startup-letter. And we'll'give you-a copy of'that-7 short-term plan to let you know the things we're going 8 to do in the short-term after restart.
9 We were not planning on docketing anything in the -
10 business plan, but you're welcome to review that. We've 11 rolled that out to all of our employees as part of our 12 employee communications already.
13 MR. ZWOLINSKI: If you go'to Tab 2, which i
\ !
14 are -- is the NRC 0350 cross-reference, you'll see that l 15 there is a lot of items in here that are kind of more in 16 Phase 2 than they are maybe in Phase 1.
17 MR. KEUTER: That's correct.
I 18 MR. ZWOLINSKI: And maybe intentionally so. But 19 some issues such as address QA and -- and things of that 20 nature, I think you'd make a lot of headway right now.
21 MR. KEUTER: Now, I want to make sure you realize 22 the short term doesn't mean it starts after restart. It 23 means those actions -- a lot of-these actions are going l
24 in parallel with Phase 1. So a lot of those things are l l
25 already happening.
O THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
- - _ - . - ~ . _ . _ _ _ _ _ . . . _ . ..
104 1 MR. ZWOLINSKI: In other words, many of the items 2 that are in this cross-reference may have already been 3 initiated or will be initiated in the near term?
4 MR.'KEUTER:. . Correct. For example, if -
5- 'you look at effectiveness of quality assurance program 6 --
7 MR. ZWOLINSKI: Exactly.
8 MR. KEUTER: -- there's a lot of things we're 9 already doing.
10 MR. ZWOLINSKI: Under corrective actions?
11 MR. KEUTER: Correct.
12 MR. ZWOLINSKI: Yes. And this is -- as far as this 13 day in history, this is where we're at with what's the
(~N 14 population of Phase 2 issues? And you're estimating 15 it's about six months to complete this group of 16 activities after restart of the plant?
17 MR. KEUTER: Well, if you look at Attachment 13, 18 it's kind of a listing of what we preliminarily feel is 19 going to be in the short-term plan. And if you look at 20 that, you'll see a lot of the soft issues -- you know, 21 lots of soft issues. They're not as black and white, 22 and they're going to take longer to fix.
23 MR. ZWOLINSKI:. But some of those are going to 24 require constant maintenance in which you could probably 25 argue, well, we've got it up and running but you have to THE REPORTING GROUP Mason'Lockhart Hagopian & Ramsdell
r l
l 105 t
1 pulse it periodically --
.2 MR. KEUTER: Absolutely. l 3 MR. ZWOL'INSKI: -- in order to declare victory on l
4 that. l 5 There were a couple of things that maybe'I didn't i
6 catch in here,: issues that have been at least~ identified 7 in inspection reports or in previous correspondence.
8 I'm thinking of 50.59's. I'm thinking of radiation 9 protection. I'm thinking of some of the things that f 10 came out of the ISAT enicreement, stuff like that. Will y
11 some'of those continue to be evaluated to -- to 12 understand should the:y have their own tab; or they'll be 13 corrected as time goes on as just a part of the -- your 14 learning process and corrective action program?
15 MR. MEISNER: Yes. I can give you an example, 16 John, like a 50.59 you mentioned. We have some i 17 short-term improvements that we're going to put in place ;
i 18 for the 50.59 program before restart. And they're 19 primarily going to be focused on some focus training for i
20 many people in-the plant on how to research the license 21 basis to determine whether or not 50.59 applies. That's 22 where a lot of things in that program tend to fall 23 through the cracks. And we also have some -- some very 24 long-term plans that we still need to firm up that will 25 really restructure the whole 50.59 process internally.
J THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
I 106 1 MR. ZWOLINSKI: Do you envision any type of a 2 backward look to 50.59's of the past several years or an 3 analysis?
4 MR. MEISNER: 'Yes. In1 fact,-we've done a j I
i ~
5- ' * ' substantial > amount'ofathat.--For instance, we had a,--
6 we had a_ team of:six<or seven people'in here a-few weeks 7 ago that did nothing but look at the -- the license ,
8 basis processes that are important to maintaining your 9 license basis. And the major focus was on 50.59 and -!
10 looking backwards at the quality of the safety i 11 evaluation, at the quality of the process of trying to 12 identify holes. And Maine has done some earlier looks 13 back about a year ago to try to identify the same 14 thing.
15 LMR.-ZWOLINSKI: In your extent of condition efforts 16 and initiatives, are you all folding into that taking a i 17 look at your FSAR, your design basis documents, your 18 50.59 processes? Are those the things that are being 19 wrapped into that overall product that you'll provide
, 20 the agency, some-assessments of all of those a
21 activities?
22 MR. MEISNER: Yes.- In fact, there's virtually' 23 nothing that doesn't feed into that hopper somehow. And 24 of course, a major element is what we have discussed l) 25 with you in response to the 50.54(f) letter in response
\/
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
P 107 1 to the licensing issues. All of those things are fair 2 game, and they're all going directly into our evaluation 3 process.
4 MR.' CONTE: Can I ask a related-question to the 5 extent.of conditions? Is there a reason why - ' I think 6 the end is.the-appendices - why a title of the appendix 7 on extent of conditions, at least from the hardware, why 8 that appendix was not -- was opted not to be used? I'm 9 thinking in terms of the CAL. Supplement N9 1, Part 2, 10 indicates that the issue about or the commitment to look
~11 at extent-of conditions. Or do you feel it's adequately 12 covered by the attachments in the rest of the plan?
MR. MEISNER: You know what? Maybe we made a
("'}
k/
13 1 l
14 mistake. We wanted to make extent of condition more l l
15 important than the appendices. So we made it a chapter 16 right in the plan itself. That was why it was not an 17 appendix. We thought it was more important. Apparently l
18 it didn't come across that way, but that was the ]
19 intent.
- 20 MR. CONTE: Maybe just to me. I don't know.
21 That's why I'm asking the question.
22 I think we're wrapping up here. l l
23 MR. KEUTER: I'd like to point out one other 24 thing. You kind of hit on it, you know, is -- you know, 25 this isn't an all-inclusive plan. It's something that THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
108
(~% 1 we want to do for restart, but one of the questions was 2 why isn't all of the ISA items in there? Well, ISA 3 items are in the business plan, but this isn't an 4 all-inclusive plan. These are the things that we want 5 to focus on for-restart,-and we don't-feel'that'this-6 supersedes any of our previous submittals or anything 7 like that. This is stuff beyond that. A part of it 8 does include the stuff in the business plan, and a large 9 share of it goes beyond that.
10 MR. ZWOLINSKI: Dan, I think the issue might have 11 been in the December 10th response you all committed to 12 having a variety of things done at the end of the next 1
(~T 13 outage. And with the outage being accelerated so many l l
\ l i N_/
14 months, some of that may not be possible to complete. )
15 And I think, Mike, your, comment was you intend to 16 inform us if there's any changes in commitments from 17 that December 10th letter --
18 MR. MEISNER: That's right.
19 MR. ZWOLINSKI: -- if I understand you correctly.
20 MR. MEISNER: That's right.
21 MR. ZWOLINSKI: So I think that's kind of the nexus 22 of where the questions are.
23 MR. KEUTER: Okay. I'm done.
24 MR. SELLMAN: Okay. Are there any other issues
} 25 you'd like to discuss with respect to the Restart J
THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
109
/~~'s 1 Readiness Plan?
( )
x_/
2 We thank you for your time and attention.
3 MR. HEHL: Okay. I guess -- I guess real quickly, 4 just as I mentioned when we started this, that we're 5 really just getting into the review of this document.
6 And certainly it has helped, I-think, to clarify a-7 number of points in this discussion. At least I think 8 it's been very beneficial for us. And we will, if we 9 have questions, go beyond what we've discussed here.
10 And if we feel they're important, we'll get these back 11 to you. We'll make them part of the -- part of the 12 docket; and we'll send you a letter with those questions 13 in it.
{
x_- ;
14 But certainly, the -- as we also said early on, you 15 know, we -- we do put a lot of emphasis on l 16 the -- the performance that comes out. Certainly any 17 plan is only as good as how well you execute it. So we l
18 will be looking closely at those activities as you 19 will.
20 And as we mentioned before, we'll -- we'll be 21 developing a restart plan of our own to address those 22 areas that -- that we'll be focusing on. But as I 23 mentioned, you know, certainly don't key your activities 24 on our restart plan because they may or may not 25 correlate to the areas that you need to focus on.
()I
'%, l THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
i i
I 110
(~) 1 If that -- I think we're done. I appreciate
\) l 2 certainly the presentations that were given; and I ,
)
3 appreciate those folks that came out to observe this 4 meeting.
5 We do have the meeting at -7 o' clock tonight which !
6 will be focused-really on'-- on getting input from the 7 public on this -- on this plan. And we'll certainly be 8 meeting again in the near future to talk through a 9 number of issues as -- as you've highlighted and we've 10 discussed as part of our continuing process, part of the 11 restart. So this certainly won't be the end of the 12 meetings that we'll have up here to discuss this. Okay, 13 thank you. j
(}
U 14 [5:04 P.M.]
15 16 17 18 ,
l 19 l l
20 1
21 22 23 24 r~ 25 THE REPORTING GROUP Mason Lockhart Hagopian & Ramsdell
K. AMw J a.ma ,Ja_. 4 e & .1,- d .~ r J._hsm + 4 ,w .Mi.ps :a. ~Je-3 _ c. - - - -e,i. *-
t 111 i
1 CERTIFICATE 2 I, Maureen Lockhart-Wagner, a Notary Public in !
l 3 and for the State of Maine, hereby certify that.thet l l
4 ' foregoing proceeding.was. stenographically reported by me '
- 'S '
and later: reduced to. print through Computer-Aided 6 Transcription,and the=. foregoing is a full and true 7 record of the proceeding. ,
8 I further certify that I am a disinterested ,
9 person in the event or outcome of the above-named cause 10 of action.
, 11 IN WITNESS WHEREOF I subscribe my hand !
i 12 this /d day of . ber/ , 1997.
13 Dated at Falmouth, Maine.
14 I l
i 15
, 16 / (facturA. be$ u/ / ca[ /
Notary Public My Commission Expires 18 April 24, 2001.
i 19 20 21 l
22 23 24 25 i
THE REPORTING GROUP ,
Mason Lockhart Hagopian & Ramsdell f
RESTART READINES PLAN Condensclt!" '95 - appendix MAINE YANKEE ATOMIC POWER CO.
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