ML20062B860

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Transcript of 900918 Public Meeting W/Util in King of Prussia,Pa to Discuss Assessment of Power Ascension Test Program.Pp 1-100
ML20062B860
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Site: Seabrook NextEra Energy icon.png
Issue date: 09/18/1990
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
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ML20062B856 List:
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CON-#490-10986 OL, NUDOCS 9010260168
Download: ML20062B860 (102)


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ORIG! M _

  1. UNITED STATES  !

NUCLEAR REGULATORY COMMISSION- l

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I In the Matter of: ) i'

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POWER ASCENSION TEST PROGRAM )  ;

FINAL PHASE II )

SELF-ASSESSMENT REPORT )

O Pages: 1 through 100 Place: King of Prussia, Pennsylvania Date: September 18, 1990

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9 HERITAGE REPORTING CORPORATION o p w t a ,.rv e 1220 L Street, N.W., Suke 600 Washington, D.C. 20005 l (202) 628 4888 l 9010260168 901016 PDR ADOCK 0">O00443 T PNV

1 UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter oft )

)

POWER ASCENSION TEST PROGRAM )

FINAL PHASE II . )

SELF-ASSESSMENT REPORT )

Tuesday, September 18, 1990 Building 475, 475.Allendale Road King of Prussia, Pennsylvania The Commission met, pursuant to notice, at 1100 p.m., in the main conference room, PRESENT:

Neal A. Pillsbury, ' Director: of Quality Programs.

Joe 14. Vargas, Manager of Engineering..

D.E. Moody, Station Manager.

G.J. Kline, Technical Support Manager.

Ted C. Feigenbaum, Senior Vice-President, NHY. '

Bruce L. Drawbridge, Execut'ive; Director of Nuclear Production, NHY.'

.i Edward Desmarais, Independent Review? Team- ~l Manager. -i y

James M. Peschel, Regulatory Compliance Manager.

Terry Harpster, Director, Licensing; Services.

W. Hehl, Director, Regional' Projects, Region.I. 1 Ronald-L. Nimitz, Senior. Radiation Specialist.- I Victor Nerses, Acting Director, Project Director :j of 1-3, NRR.

Noel Dudley,.. Senior Resident Inspector. '

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Present (Continued)-

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Ebe McCabe, DRP Projects Section Chief. ,

Jon Johnson, DRP Projects Branch Chief. .7 Tim Martin, Regional Administrator, ,

4 Jim Wiggins, Deputy Director, DRP.

Michael Case, Operations Engineer.

Karla-Smith, Regional Counsel.

William Oliveira,' Reactor Engineer,_ Operations Section,' DRS.

P.K. Eapon, Chief, SpecialLTest Program Section.

David Bessette, Chief, Operational Programs Section.

Peter Drysdale, Senior Reactor Engineer.

Lee Bettenhausen, Chief, Operations Branch.- ,

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1 PROCEEDINGS 2 MR. JOHNSON. Good afternoon. This is a meeting-l l 3 between Public Service Company of New Hampshire and the NRC.

4 It is an open public meeting. It is being transcribed ,

5 mainly for efficiency for us, .for us to be able to document 6 the summary of the meeting. ,

l 7 The purpose of the meeting is to. discuss the New 8 Hampshire Yankee' assessment of.the Power Ascension. Test i L What we will doLis go around the table:and 9 Program. {

l 10 introduce each other, and then what I will do is. turn the 4 11 meeting over to New Hampshire Yankee. I expect-it'to take 12 probably no more than two hours. And I would hope that' 13 anybody that has any questions during the' presentation,;make- 1

() 14' sure we give you feedback and answer the questions.

15 MR. WIGGINS: Jim Wiggins, I am' Deputy Director, 16 Division Director of Projects here in Region One, l 17 MR. JOHNSON: Regional Administrator Mr. Tim ,

18 Martin is here. He stepped out for a moment; he will be  ;

19 back shortly. ,a 20 I am Jon Johnson, DRP Projects. Branch' Chief.

j. 21 MR. MCCABE: Ebe McCabe, DRP. Projects Section 22 Chief, j 23 MR. DUDLEY: I am Noel Dudley,' Senior Resident 24 Inspector.

25 MR. NERSES: Vic Nerses, Acting Director of-Heritage Reporting Corporation.

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Project Director of 1-3, NRR.

MR. NIMITZ: Ron Nimitz, Senior Radiation 3 Specialist, Region One.

i 4 MR. HEHL: I am Bill Hehl, I am the Director for  !

5 the Regional Projects, Region One.

6 MR. HARPSTER: Terry Harpater, Director of 7 Licensing Services, New Hampshire Yankee.

8 MR. PILLSBURY: Neal Pillsbury, Director of 9 Quality Programs, New Hampshire Yankee. /

10 MR. VARGAS: Joe Vargas, Manager'of Engineering, 11 New Hampshire Yankee.

12 MR. MOODY: Don Moody, Station Manager, Seabrook, l

13 New Hampshire Yankee.

() 14 MR. KLINE: Gary Kline,. Technical Support Manager, i 15 New Hampshire-Yankee.

16 MR. FEIGENBAUM: Ted.Feigenbaum, Senior Vice- '

17 President and Chief Operating Officer, New Hampshire Yankee.

18 MR. DRAWBRIDGE: Bruce Drawbridge, Executive 19 Director of Nuclear Production,.New-Hampshire Yankee, sj 20 MR. DESMARAIS: Ed Desmarais, Independent Review.

21 Team Manager, New Hampshire Yankee. 1 22 MR. PESCHEL: Jim Peschel, Regulatory Compliance j 23 Manager, New Hampshire Yankee.. j 24 MR. EAPEN: P.K. Eapen, Chief, Special Test ,

-25 Program Section.

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5-1 ~ MR. OLIVEIRA: . Bill Oliveira, Operations Section, 2 DRS.

3 MS. SMITH: Karla Smithi Regional Counsel.  !

4 MR. CASE: Mike Case,JNRR. ,-

5 MR. MARTIN: Tim Martin,-Regional Administrator.-

6 MR. FEIGENBAUM: .Okay, good afternoon. My name is 7 Ted Feigenbaunt, and as I said, I am the Senior Vice 8 President and Chief Operating Office of New Hampshire 9 Yankee.

10 As most of you may.already know,.I will:be .

11 assuming the position of President and-Chief Executive 12 Officer upon Ed Brown's retirement'on October <1st.- 1 13 On behalf of New Hampshire Yankee and our joint

() 14 owners, we are pleased to provide.you with this. briefing' i

15 today. As you may know, Seabrook completed its-test program-16 on the 17th of August, and the plant is currently operating 17 at 100 percent power.

18 We have some presentations thatLahould.take, 19 I guess, formally about 45 minutes. AndLplease, if.you-have -

20 any questions, just stop us and we will'try to1 address them.

21 First of.all, Gary Kline is goingito report to;you 22 on the results of the Power; Ascension. Test-Program:since we 23 last-briefed you at the 50 percent power plateau back.on-24 June 19th. .He is also going to discuss some of~the-lessons- 'I 25 we have learned during the Power Ascension Program, and that' f

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we plan to carry forward into normal plant operations.

Bruce Drawbridge will discuss the areas where we 3 believe we can improve through increased mane.gement 4 attention. And he will brief you on some of the short- and 5 long-term initiatives we are taking to strengthen ourselves 6 as an operating company.

7 Ed Desmarais is going to talk about the 8 self-assessment program, emphasizing the maintenance 9 evaluation which we conducted as part of the overall 10 self-assessment team evaluation.

11 So that we can maximize the effectiveness of the 12 information exchange today, I have asked our speakers to i 13 concentrate on the things that we are doing to improve our

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14 organization, and not to dwell on the portions of the test 15 program that we feel went smoothly and really do not require 16 any further discussion. j i

17 From the beginning of the test program, we stated l 18 that we would manago it in a conservative manner, and not be 19 driven by schedule. And that is exactly how we carried the 20 program out. The Power Ascension Test Program lasted about 21 155 daya, a little bit longer than we expected. And that l 22 was essentially due -- the biggest delay was about a month  !

23 to detune the turbine generator equipment, which we.

l 24 discussed at length when we met last in June. So we will 25 not take the time to go into that this afternoon.

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7 1 We also had two unplanned reactor trips, which 2 Gary Kline will brief you on, apart from the turbine work.

3 Other than that, the tests went pretty much according to 4 schedule, and the results were as we expected. We believe 5 the test program demonstrated the readiness for full power 6 operations, not only of the equipment and the systems in the 7 plant, but also the operators and the entire support 8 organization.

9 I think the good results we had were a direct 10 result of our careful and deliberate preparation for the 11 test program. We reviewed and revised every test procedure 12 to incorporate lessons learned. The lessons learned from 13 our low power test program, from industry experience.

() 14 From the lessons learned from NUREG 1275, which was the 15 NRC's Operating Experience Feedback Report for New Plants, 16 which was very valuable to us.

17 We made sure that the operation and test crews 18 were thoroughly trained and briefed, and we had ample time 19 on the simulator to practice complex procedures, which was 20 very helpful as well.

21 We made sure the entire New Hampshire Yankee 22 organization was properly focused on supporting the test 23 program. But as a new plant entering commercial operation, 24 I know from my own experience at other units, and my 25 personal conversations with other senior managers in the Heritage Reporting Corporation O

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industry, and through meetings with them at NUMARK and INFO, that there are certain pitfalls following commercial j 3 operation that we need to be on the lookout for.

4 one is complacency, and the other is a loss of 5 trained personnel.

6 As senior management, we are keenly aware of these.

7 potential concerns, and we will be closely watching for any i

8 signs of them. I do not, however, anticipate a problem in 9 these areas.

10 Me have a great many programs underway and

. 11 initiatives in the planning stages or in progress at New 12 Hampshire Yankee, and there would be no opportunity for our 13 organization to let down. These initiatives include j

() 14 improvements we are going to be making to our maintenance 15 program, that Bruce and Ed will be discussing; the 16 completion of our INPO accreditation for our technical 17 training programs.

18 We are also in the middle of preparations for the l 19 upcoming emergency planning biennial graded exercise, which 20 will be held in December. And we are also deeply involved 21 in preparations for our first refueling outage that will 22 contain a fair amount of work and a whole lot.of planning.

l 23 Be ready for them.

24 As far as turnover of our staff, New-Hampshire 25 Yankee has generally had a low turnover rate, even durir.g- .I Heritage Reporting Corporation

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We provided

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opportunities for our licensed operators to advance their 3 careers by transferring outside of the. Operations 4 Department. And we have really only lost from the company 5 five licensed operators since 1984, despite the frustrations 6 and the delays in getting the unit licensed and on-line.

7 Now, this may have something to do with the 8 quality of life in New England, but I know there has been a 9 strong sense of purpose among the people who work at 10 Seabrook, a determination to license the plant and to show 11 the public and our regulators that we can make it one of the 12 safest and most efficient sources of easergy in the country.

13 Also, our emphasis on open communications between

() 14 our employees and the management of the company, and the 15 importance we place on each individual employee, has also 16 had an important factor in recruiting and retaining talented 1

17 people.

18 Now, to get to the heart of the briefing today, l 19 I would like to turn the presentation, at this point, over 20 to Gary Kline, who will brief you on the results of the 21 second half of the Power Ascension Test Program. And'after  ;

22 Gary, Bruce and Ed will speak. And then I will return for a- j 23 few closing remarks.

24 Gary?

25 MR. KLINE: Thank you, Ted. Again, I am Gary

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10 i 1 Kline. I am the Technical Support Manager. And during

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2 Power Ascension testing, I functioned as the Power Ascension

! 3 Test Program Manager.  ;

4 At our meeting on June 19th, we discussed the f 5 development of the program, including preparation, procedure  !

l 6 development, and training, and testing activities up to that 7 time. Today, I would like to concentrate on the testing 8 that we completed since our 50 percent power meeting.

9 Since that time, we have conducted all or portions 10 of 29 power ascension tests. And there are four in e 11 particular that I would like to discuss in greater detail 1

12 today, and those are on the bottom of the second slide, i 13 The first one that I will be discussing will be  !

() 14 the large load reduction, ST-35. That is third from the 15 bottom. That test was performed twice, once at 75 percent l 16 power, and once at 100 percent power. And that was run by 17 initiating a set-back condition in the turbine, which l

18 decreases the plant power at about two. percent per minute, ,

19 down 50 percent. J 20 During the test, the primary and secondary plant l 21 performed essentially in accordance with our projected 22 response. After the second load reduction at 100 percent 23 power, we delayed power ascension about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, in }

24 accordance with tech specs, for axial flux difference, to

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25 get our penalty minutes back in spec.

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The second test that was on the slide, the inner trip from 100 percent power, ST-38, was performed by the 3 plant transient response to a trip from 100 percent power, 4 met our standard design requirements. -Additionally, this 5 test verified that the actual HUT leg RTD temperature. l r

6 response time is conservative, with respect to the values l l 7 u sed in accident analysis.

8 ST-38 was initiated by tripping the generator,  ;

9 which in turn tripped the turbine, tripped the reactor.  ;

10 Once the trip took place, the shift operating personnel 11 utilized their appropriate normal and emergency operating ,

12 procedures to recover the plant to a stable IRJT stand-by 13 condition.

() 14 Selected plant parameters were monitored 15 throughout the test, and the subsequent analysis of the data 16 showed that the plant responded as expected.

17 Approximately one hour.after the reactor trip, wo 18 entered natural circulation,. ST-22. And that involved i 19 simultaneously tripping all four-reactor coolant pumps. .

20 The purpose of this test is to verify that the plant can 21 enter natural circulation conditions ~and acequately remove 22 decay heat.

23 In fact, it took about 11' minutes to actively 24 establish natural circulation conditions.

25 The last major test was the loss of off-site

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12 1 power, ST-39. This test was initiated by simulating a loss 2 of off-site power with the opening of the off-site power 3 feeds to the plant, and tripping the turbine. The reactor 4 was at approximately 20 percent power, and we were above our 4

5 P-9 subpoint.

6 The test verified that the emergency diesel 7 generators would start and reach their rated speed and 8 voltage within 10 seconds, and also' verify that the power 9 sequencer would perform its designed function of sequencing 10 our required loads on, 11 This test has also demonstrated that the plant can 12 be maintained at a stable condition, which we verified for a 13 30-minute time span after loading the diesels.

() 14 Our Power Ascension Test Program was essentially 15 completed following the completion of ST-40, which was more 16 commonly known as the warranty run. That was completed on 17 Friday, August 17th, 18 I would like to discuss our review and analysis of 19 the Power Ascension Test Program results. All'of our tests 20 that we performed have been reviewed by our Sort Committee 21 and Management oversight Committee. All test results and i'

22 test exceptions have been reviewed and approved.

23 Our initial start-up report had been submitted on 24 June 13th, and the first supplement was submitted last week 25 on September 13th. Some of.the results,are included in Heritage Reporting Corporation 10 (202) 628-4888

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these reports, and the final report, the final start-up test report, will be published prior to September 30th.

3 Mith regard to test exceptions, during the program  ;

l 4 we had a total of 62. The majority of them were very minor l

5 in nature, and would include administrative details like  ;

6 receiving the final report from GE on our turbine torsional I i

7 test results.

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8 .The three listed on the slide are three more -

9 significant ones. The first one had to do with power 10 distribution measurements, ST-29, which was conducted at 11 each plateau. Our planer peaking factor affects was l 12 slightly more than our limit at a given plateau, and per 13 technical specifications we have performed our analysis and

() 14 accepted the results, 15 During our LOP test, we concurrently ran ST-43, j 16 which in our computer test procedure. During the initiation 17 of the test, the primary host on our computer -- we have two 18 hosts -- was slowed down. The back-up host noted that the 19 computer slowed down, and we had a fail-over during the -

l 20 test, and we lost about two to five minutes' worth of data 21 during that. test. That one is still.under review.

22 ST-46, that basically is our ventilation system -

23 testing. During the test -- we did that in.the middle of 24 the summer -- we did have some high temperatures in the east 25 and west pipe chases, and we-had some temporary cooling in 7

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there to maintain our technical specification limits.

Therefore, we had an exception against the procedure at that I

t 3 point.

4 Overall, there are still, to date, there are only i

5 11 test exceptions left open. We all have them in our 6 tracking system, and are working towards a final plant f 7 close-out.  !

8 The last time we were here, I showed a different 9 version, an earlier version, of this slide that showed our 10 unplanned trip results, up to 50 percent power. This slide -i r

11 has been updated to show completion through 100 percent ,

12 testing. Our goal was zero plant trips. We did not meet 13 that goal. However, I am very pleased with the results we I i

() 14 did receive.

r 15 The first reactor trip that we did have, of the 16 two, occurred on June 20th, while the reactor was at  !

17 approximately 30 percent power and increasing. The trip was 18 caused by an unexpected actuation of a relay in our l 19 generator protective circuitry. The relay is designed to :i 1

protect the last 5 percent of generator windings from ground 20 21 fault. This protective function, which is not required by 22 the generator manufacturer, it is customer trip, initiated a 23 turbine generator trip, when the production circuitry was >

24 activated at about 30 percent level.

25 The turbine generator trip, in turn, initiated the f] Heritage Reporting Corporation s s- (202) 628-4888 i

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reactor trip, because the protective circuitry actuation is related to set point adjustments that are based on assumed 3 third harmonic voltages supplied by our vendor.

4 In actual operation, our third harmonic voltage, 5 which is a noise over 60 hertz frequency, turned out *:o be 6 lower than anticipated. Therefore, the set point was overly 7 conservative.

8 Since this protection is not required, we have l 9 reviewed the functioning of the relay with the relay

10 supplier and the vendor in detail, and we have initiated a '

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11 modification to convert it to monitoring circuitry, and it I l

12 is an alarm function only at this point.

13 The second reactor trip occurred on July 5th, j

() 14 while the reactor was at 75 percent power. This trip was 15 caused by main steam low EHC oil pressure signal, and it was 16 due to vibration. The switches were monitored on our main 17 steam stop valves. There was excessive vibration at a-18 particular point at 75 percent for those switches to be 19 monitored in that location, cousing contact closure. <

20 At that point, we relocated the switches to an 21 environment that did not exhibit vibrations, and the problem 22 went away.

23 In the determination of this root cause, we did 24 talk to other plants to determine if they had experienced 25 the same problem, and we also worked closely with the

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vendor.

In summary, the Power Ascension Test Program, 3 I feel, was very successful. Despite the problems with the 4 turbine, the actual performance of our tests were 5 essentially in accordance with our-test schedule and the 6 results were very much as expeched.

7 We, as a company, learned a great deal from power 8 ascension testing. Two major areas that I feel we excelled 9 at were in preparation and teamwork. The Power Ascension 10 Test Program was a complete New Hampshire Yankee team.

11 It was not just an operations and test personnel effort.

12 Training, Engineering and Maintenance Departments, to name 13 just three, worked very effectively with the operations and

() 14 test crews to solve problems and make this an effective test ,

15 program. And I think I am confident that you will see this 16 same teamwork in the future.

17 With regard to preparation, there are three 18 significant areas that we will be carrying over into  !

19 permanent plant operation. I think that the procedures we 20 developed for the test program were unique in nature, and '

21 very good. They have some features'in it that we are 22 already utilizing, and additicnal procedures, as we go  !

23 through operation. Basically, background and briefing 24 documents for complex evolutions are a key ingredient to l 25 have, I think. Training, the use of' testing the procedures Heritage Reporting Corporation O' (202) C26-48eo

17 1 on the simulator for complex evolution I think was key to E 2 debugging the procedures, and making sure that training for {

3 the test crews and the operations group was of high quality,  !

4 and provided thorough knowledge of the evoluticn to people  !

5 that are going to be doing these complex evolutions. l 6 And finally, and even prior to entering the test 7 program, we conducted pre-test briefings, pre-evolution 8 briefings, right outside the control room. And we found  ;

9 that those briefings can be extremely helpful, and we are l

10 continuing to use that technique. -

l 11 We have also identified some areas where we can 12 improve. And at this time, I would like to turn the 13 presentation over to Bruce Drawbridge, who will address 14 these areas and other issues.

15 HR. DRAWBRIDGE: Thank you, Gary. My name is  !

l 16 Bruce Drawbridge, and I am the Executive Director of Nuclear 17 Production at New Hampshire Yankee.

18 I will discuss some of the events that occurred  ;

19 during the test program, and I will also discuss the use of d i

20 the Power Ascension Test Program self-assessment results, 21 and in particular, some areas where we are devoting 1

22 additional attention. 4 23 I agree with Gary that the Power Ascension Test l 24 Program was very successful. Now, my conclusion is not 25 based solely on my own observations, or the technical l

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() 1 results. It is also based on the observations and reports  :

2 from various oversight functions, and from observations of ,

3 other senior managetent.

4 The results of the power ascension self-assessment 5 were submitted to you on Tuesday of last week. And before I 6 discuss how management will use the report and 7 recommendations, I would like to have Ed Desmarais, our ,

8 Self-Assessment Team Manager, provide an overview of the 9 assessment, and discuss the_ assessment of the maintenance 10 program. .f 11 So I will turn it over to you, Ed. .

12 MR. DESMARAIS: Thank you, Bruce. I am Ed l

13 Desmarais, the Independent Review Team Manager. And I will

() 14 discuss the self-assessment team efforts.

15 Before I do this, I would like to highlight the 16 role of self-assessment at New Hampshire Yankee.

17 First and foremost, self-assessments are-a 18 management tool, which they use to identify areas for 19 improvement. In a general sense, these self-assessments can  ;

t 20 range from weekly reports or compliance inspections, to 21 experience-based management evaluations.

22 New Hampshire Yankee has a number of diverse but 23 well-coordinated groups which do these self-assessments on l 24 different aspects of the company's business. For the Power 25 Ascension Test Program, New Hampshire Yankee set-up a Heritage Reporting Corporation

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19 1 special group called the Self-Assessment Team. This team 1

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2 was chartered with evaluating the conduct of the test  !

I 3 program, as well as the functions that would ensure its j 4 success.

.I 5 On June 19th, I described the scope of the j 6 self-assessment and the composition of the team, so I will 7 not repeat that today. Instead, I will briefly discuss 8 examples of the types of evaluations we have done, and how 9 they resulted in recommendations and conclusions. After i 10 that, I will talk about the team's efforts on the 11 maintenance evaluation.

12 Evaluating the conduct of the test program and 13 plant operations was a primary focus of the team and the

() 14 Hanagement Oversight Committee. Throughout the entire test 15 program, the team did this by attending the same initial and 16 requalification training as the test group and the  !

17 operators, by attending pre-shift briefings, by reading and 18 reviewing all test procedures and their revisions, observing 19 every test, independently reviewing all test results,  ;

20 observing the test result review and approval process, and 21 by presenting the results of these efforts to the Management 22 Oversight Committee.

23 Through these and other efforts, the team was able 24 to conclude that the test program was conducted in a 25 cautious and conservative manner, and the plant operates por i s

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the design basis.

The team also evaluated activities that supported -

3 the test program and plant operation. As would be expected

! 4 during a test program, a number of design and maintenance 5 challenges occurred. As an example, we closely followed the  :

6 engineering and technical support efforts to analyze and  ;

7 design fine-tuning adjustments to the feed water pump, the l

8 feed water regulator valves, the heater drain pump discharge  !

l 9 valves, and the moisture separator reheater, ,

, 10 The team reviewed each design package and d i

11 modification, and discussed the results with the Management 12 oversight Committee. The SAT, or the Self-Assessment Team, 13 has recommended that technical support and engineering l

() 14 document and analyze the chronological history of the design 15 revisions to the feed water and heater drain string for 16 lessons learned.

17 The team also reviewed events surrounding the l 18 turbine setback on July 2nd. The setback occurred during 19 the performance of a repetitive task involving the generator >

b 20 step-up transformer cooling fans. The potential for this ,

21 event had been identified about a month earlier, and a  !

22 revision to the repetitive task sheet was initiated. ,

23 This' event occurred before the revised repetitive task sheet 24 had been issued. -

25 The team recommended that station management ,

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further review this event for generic implications on revising issued work packages.

3 The last example for the power ascension 4 self-assessment involves performance indicators. During the j 5 first few months of the self-assessment, the team 6 recommended to the Management Overnight Committee that 7 New Hampshire Yankee adopt and develop INPO-style ,

8 performance indicators in anticipation of plant operation.

9 These indicators were initially issued in March of 1990, and 10 have evolved over the past few months. j 11 Our assessment indicates that management did use 12 the work request, request for engineering services, surface 13 contamination, and receipt inspection performance indicators

, () 14 to track and, where necessary, make mid-course corrections.

  • 15 our evaluation also resulted in a recommendation to complete 16 the outstanding performance. goal and analysis information 17 for some of the indicators.

18 These few examplec typify the activities and l

19 observations that provide the basis for the recommendations l

l 20 and conclusions in the June and September reports.

i i 21 Many of the areas for improvement that Bruce will I

22 discuss today began with recommendations that the team  !

23 identified and reviewed with the Management oversight 24 Committee.  !

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The team has looked at many different activititsa

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(' I during the past 10 months. Our maintenance evaluation is 2 one example of the key area of focus. The first part of the ,

3 evaluation looked at the ability of maintenance to support 4 the test program and full power operation. The June and 5 September self-assessment reports sumn.arized the team's 6 activities that led us to conclude that maintenance can 7 support safe and reliable plant Operation.

8 As we mentioned in our presentation on June 19th, 9 the Self-Assessment Team was also doing a special evaluation 10 using the proposed regulatory guidlines in DG-1001.- This -[

s 11 second part of the maintenance evaluation indicated that 12 overall, New Hampshire Yankee has developed, or is currently 13 addressing, the programmatic aspects contain*d in those  :

() 14 maintenance elements. ,

15 Using the rating scheme from the draft guidance, 16 we determined that most of the elements are satisfactory.

17 Some of the elements were evaluated to be good, while others l .18 need additional attention.

19 These ratings reflect criteria which is aimed.at f 20 fostering excellence in maintenance programs and practices.

21 The team's general conclusion is that, overall, 22 our maintenance program and practices are satisfactory.

23 We were able to determine chose ratings and 24 conclusions through a series of different types of l

25 evaluations. The first involved a comparison of our

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existing New Hampshire Yankee maintenance program with the proposed regulatory guidance.

3 To ensure an objective and independent review, we 4 asked an experienced maintenance individual from another 5 utility to make this comparison. His report, which is 6 appended to our maintenance report, concludes that in 7 general, the program documents have considered all the 8 elements stated in the NRC inspection guidance in some form 9 or location. The major weakness is in how the various 10 documents relate and they demonstrate a smooth flaw.

11 The second type of evaluation involved comparisons 12 of our maintenance program with maintenance programs at 13 other nuclear power plants. At various stages in the

() 14 evaluation, we either visited or contacted other nuclear 15 plants. The team also contacted INPO to obtain a list of 16 utilities noted for exceptional or superior performance in 17 selected areas of maintonar..e. We have provided this information to our Maintenance Department.

1 18 i

19 The third part of the evaluation was based on 20 direct observation of maintenance work. The team observed 21 each part of the work process, beginning with the 22 identification of a work activity, through retrieving 23 arc hive work packages from the records center.

24 The first example of direct observation involves 25 the installation of a design package on the heater drain

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pump. This modification replaced the existing gland packing with a mechanical seal.

3 We attended the pre-work briefing, reviewed the f

4 work for proper authorization and work documents. At the 5 work location, we verified tagging, foreign material 6 exclusion, and the assignment of qualified workers. ,

7 During the actual performance of work, the team i 8 noted that some administrative aspects of the work could be i 9 improved. We also observed that maintenance inspectors 10 inspected the work in progress several times, and that i 11 individual departments work well together.  ;

12 The post-modification test was performed as 13 specified. The data collected, reviewed, and approved. -

() 14 Another observation example invo3 *s the feed 15 water and steam flow calibration. We began by observing the l 16 pre-work briefing in the INC shop. The supervisor reviewed 17 the work package, and the steps to be taken by the two teams 18 involved in the calibration.

19 This work activity needed good coordination to 4 .
6 20 ensure consistent communications and expectations between i

21 '

the two teams involved in the calibration. The work-22 activity needed good coordination to ensure consistent 1

23 communications and expectations between the team in the RCA 24 and the team and the control room.

25 As part of observing this work activity, we

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reviewed the work package for authorizations, the radiation work permit, tagging, documentation, and general adequacy.  !

l 3 Throughout the calibration, procedures were explicitly ]

4 followed, and the communications crisp and professional.

5 This was particularly significant in light of. rotating f

6 technicians into and out of the RCA.

7 The work package was properly completed, reviewed, 8 and closed.

9 The third example of direct observation involves 10 the diesel generator 18-month surveillance that occurred 11 over several shifts. As in the previous examples, the team 12 reviewed the contents of the work package and the i

13 availability of spare parts.

() 14 In the field, we also verified that. assigned 15 workers were qualified, a detailed log was maintained as 16 work progressed, tagging was per the tagging order, and 17 procedures were followed. The surveillance test was l 18 performed, and the test results reviewed and approved.

19 The team also took different slices of the 20 maintenance process as-a cross-check on our direct i

21 observation of work. One of these slices included a review

, 22 of the procurement process for its impact on- maintenance. -

23 In the beginning of the test program parts 24 availability was impacting the_ performance of work in the 25- field. Manag'..nent established the Materials Task Force to

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( 1 analyze and correct this problem. Through the efforts of 2 this task force, and a planning and scheduling group, parts 3 ordering and expediting has been improved. Work requests i 4 are not released until all identified parts are cleared S through receipt inspection, and parts availability for work 6 scope changes is now at approximately 98 percent.

7 The team also reviewed a good-sized sample of the l

l 8 maintenance procedures for content, ease of use by the-9 workers, inclusion in the work packages, the preparation and i

10 revision process, and the biannual procedure review.

11 Our evaluation indicated that procedures are issued and i 12 controlled as specified by the programs.

13 We did find, in certain instances, that the

() 14 content of procedures could be improved to clarify vague 15 statements, such as "as required," or to provide more 16 specific direction.

17 The last example of direct observation involved l

18 the maintenance training and qualification program.

19 Our evaluation began with the Training Advisory Committee i 20 that establishes the content and scope of the training 21 program. The evaluation continued by attending different 22 training sessions,-reviewing the training schedule and i 23 attendance, reviewing the initial qualification of workers, .

I 24 and verifying that qualified workers were assigned to work l 25 activities.

Heritage Reporting Corporation-O (202) 628-4888 i

27 1 The team found that the Training and Qualification 2 Program is working as designed.

3 In the fourth type of evaluation, we reviewed new, 4 pro-active initiatives intended to improve maintenance.

5 These activities are in the initial stages of development or 6 scheduled for future action.

7 Our reliability-centered maintenance program is-8 one of these efforts. Engineering has developed the first 9 package using the diesel generator as a prototype. And this 10 package is currently being reviewed by our technical support 11 and maintenance groups.

12 Beginning in 1991, Engineering is-scheduled to 13 develop several reliability-centered maintenance packages

() 14 each year until they are complete.

15 The team also reviewed the implementation status 16 of the work-controlled data processing system. The current 17 information systems for maintenance are essentially 18 stand-alone systems that require multiple data entry and 19 access. New Hampshire Yankee is currently at the two-year i

20 point in a five-year schedule aimed at implementing a single 21 system for maintenance information.

22 Parts of this new system are now being used and.

23 approved on. When completed, the system will provide 24 information on planning and scheduling, procurement,.

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equipment, and configuration control.

The final example I will discuss involves the 3 performance monitoring program for plant systems. This 4 program was initially reviewed by the Self-Assessment Team 5 during the low power self-assessment program. At that time, 6 the team reviewed the program outline and performance 7 reports on the few systems it had operating history.

8 Since that first review, the only additional 9 opereting history has been due to the Power Ascension Test-10 P rog, ram . The monitoring program, when fully implemented, 11 will previde an analytical tool to improve maintenance by 12 pro-actively finding and correcting equipment systems and 13 problems.

() 14 From these four types of evaluations, the team j 15 identified areas of strength. These include the planning, 16 scheduling of work, work package preparation, the actual 17 performance of maintenance work, and the pro-active efforts l

18 which I just mentioned.

19 We also identified areas.for improvement, which 20 are cited as specific recommendations. Some of these 21 recommendations includes better coordination and integration 22 of maintenance support functions, establishing a dedicated

! 23 procedure-writers' group, improving work history 24 descriptions, and developing maintenance-specific l

25 performance indicators.

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These, and a number of other specific recommendations for improvement, were discussed, accepted,  ;

3 and endorsed by the Management Oversight Committee.

4 We have documented this maintenance evaluation in i 5 a separate internal report, which we have made available i 6 on-site to the senior resident inspector and other NRC l

[

7 inspectors to review. ,

8 I will conclude by reiterating that this l

I 9 maintenance evaluation is an example of our self-assessment i 10 efforts. We believe that the endorsement of our .

11 recommendations by the company's top management team  ;

j 12 indicates that the assessments have proven to be a valuable i i

13 tool for the company. >

i

(

() 14 I will now turn the presentation back over to i 15 Bruce, so he can discuss how New Hampshire Yankee is 16 addressing these recommendations, i 17 MR. DRAWBRIDGE: Thanks, Ed. I think that reports ,

18 such as the maintenance evaluation are very valuable 19 management tools. We will be utilizing results of.this and-20 other internal evaluations, along with a total power-21 ascension self-assessment report, as we implement j 22 initiatives for the enhancement of our operating 23 organization.

24 We recognize that we must continually work to i 25 improve all aspects of_our operation. That includes i

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1 maintenance, operations, engineering, or training.  !

2 We also recognize that it requires active 3 management involvement. I want to assure you that senior 4 management is involved as wa implement our initiatives.

5 Some of the initiatives that.we are currently 6 pursuing include enhancement and streamlining of our  !

7 programs and procedures, improvements in our facilities, and [

t 8 maintenance actions to improve reliability and

{

9 maintainability. f 10 We not only tested the plant, but have also tested 11 our personnel, in our administrative control programs, with 12 a great deal of emphasis on our work control and maintenance 13 programs. We have determined that the programs are O 14 satist ctorv, hue, ther oeu1d de stream 11ned and enhanced to 15 better support plant operations.

16 One of our initiatives is to consolidate and 17 streamline our work control program, and our maintenance i 18 programs, as well. I am working with key station managers 19 to implement recommendations from the self-assessment 20 maintenance evaluation, internal programmatic reviews, as l 21 well as comments received from NRC inspectors during the  ;

\ l l 22 Power Ascension Program.

23 Now, Ed Desmarais has already mentioned the l 24 ongoing work to develop the reliability-centered l 25 maintenance, that is RCM program. And we will be including i

O Heritage Reporting Corporation i V (202) 628-4888  !

t 31 1 RCM considerations in this implementation.

}

2 I am looking at the recommendations, and I am 3 going to establish a master schedule for their  !

4 implementation.

5 I have recently made some changes within the 6 maintenance organization to facilitate the control of work.

7 I made these changes to remove potential distractions so 8 that maintenance personnel can concentrate on the day-to-day 9 maintenance of the plant.

10 Changes that I made, to date, include the 4 11 reorganization of the Maintenance Department to create two 12 separate sub-organizations, Hechanical Maintenance and s 13 Electrical Maintenance. We feel this should facilitate the *

() 14 control of work. We have also reassigned a manager to a 15 staff position, where he has responsibility for planning and 16 coordinating long-term projects, also facility additions, as 17 well as major turbine overhauls.

18 And finally, the respunsibility for maintenance of 19 our off-site siren system, we transferred-from the 6 20 maintenance organization to- our- site services organization.

21 Root cause determination is on ongoing initiative, 22 and we will continue to work on it to improve'our overall 23 performance. At our last meeting, I mentioned an 24 enhancement that we are developing to our root cause 25 analysis process. Our new root cause determination

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procedure was issued the end of July, July 30th.

Now, we have not had enough experience to date ,

3 with a new proceaucs to really produce any evaluation of i

4 trends. However, this program will be continuing.

5 I would liht to discuss another ongoing initiative '

a 6 that we introduced at the June 19th meeting. And this is .

l 7 our trip avoidance program.

8 As Gary mentioned, our trip avoidance program was  :

9 very successful during the Power Ascension Test Program.

10 We experienced only two unplanned reactor trips. .

11 We did, however, experience an unplanned reactor 12 trip on August 22nd. This was after the conclusion of the l 13 Power Ascension Test Program. This trip occurred with the "

() 14 unit at 100 percent power, while conducting some minor 15 maintenance on the generator EHC circuitry.

16 We were aware that the industry had long 17 experienced problems with unexpected EHC sy .; response 10 during maintenance. We reviewed this work k ilty in 19 detail prior to the implementation, and took all the j 20 precautions'that we deemed to be prudent. Unfortunately, we 21 still experienced the trip. Ana we have not_ determined the .

22 exact cause.

23 Now, our discussions with our vendor, GE, has 24 indicated that other plants have experienced similar trips 25 with unknown causes involving EHC circuitry.

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1 In 'he future, we will continue to carefully 2 evaluate EHC maintenance activities, performed at power to 3 minimize challenges to plant systems.

4 We are currently evaluating our check valves as 5 part of an EPRI project. The research portion of the 6 project will determine the operating charactoristics of each 7 one of our check valves. Now, this data will subsequently 8 be incorporated into surveillance procedures for these check 9 valves to allow us to more accurately test the valves. Now, 10 we anticipate that the program will be developed by the end 11 of this year, and implementation will commence with our 12 first refueling outage. '

13 As you may be aware, we also have an extensive

() 14 program to ensure the operability of motor operated valves, 15 both during normal operation and also during transient i

16 situations. This program utilizes a unique technology, j 17 developed by NHY. And it involves the use of strain gauges, l 18 as well as personal computers to diagnose and assess the i

19 performance of each motor operated valve.

l 20 Now, the previous method, using Movat's equipment, 21 required actuator disassembling,- in some cases. That was 22 during the performance of calibration. That was primarily l

23 for butterfly-style valves, i

l 24 Our MOV strain gauge program will include all

25 motor operated butterfly valves and rising stem valves, i

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a 34 1 1 whenever possible. The program has two objectives. One is 2 to accurately measure the forces applied-to.the valve shafts 3 by the valve operator. And second, to utilize : train gauge 4 measurements to verify that the valve actuator. switch 5 settings insure valve operability under the design' basis 6 conditions, for the life.of the plant. l 7 We feel this is a creative approach to an NRC-8 concern.

9 An additional area where we aus devoting attention  !

10 is the fine-tuning of our secondary plant. In particular, 11- the' feed water and connosay system. We have experienced 12 some secondary plant oscillations at power during the Power 13 Ascension Test Program.

() 14 We have established a' team of individuals to 15 review the operational characteristics of:the: secondary i

16 plant, and develop additional design or procedural l

17 enhancements to ensure the-rel. ability and the ease of 18 operation of the secondary-site.

19 I would like to very briefly' discuss-two plant >'

20 facility enhancements. As you may know, we have a five year ,

21 major plan, an overall plant facilities plan. Plant'  !

i 22 facilities-are included within this plan,-so it goes over a 23 five-year period.

24 The first project we-are implementing is a direct 25 result of-our Pcwe; Ascension-Test Program experience.

l I Heritage Reporting Corporation

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35 1 In order to enhance our chemistry capabilities, we are

{

2 installing a half-million gallon demineralized-water storage  ;

3 tank. Work on the installation of the tank is' in progress -

4 now, we just started. And we project'that the tank will-be 5 in service by March of next year, the end of March of next -

6 year.

7 We are also completing design work on a building );

8 that.will' house our new. decontamination facility, and a hot.

l 9 INC shop. And we expect that this work will.be done by.the 10 last half of 1991.

11 I would like to address events,that occurred  !

12 during the test program. We-had a-series of.LERs that ,

i 13 occurred during the Power Ascension Test Program. As you

( ) 14 can see, we have classified the LERa'according to their root 15 cause. There was one LER attributed to a weakness'in our  :

16 configuration control program; three due to equipment  !

17 failures; and five classified-as caused by3 personal 4 error.1 18 Now, the three' equipinent problems were the type- 1 19 that would be expected during start-up of a new plant.- 91 20 m sever, the remaining LERs were not expected, ntn our i

21 review of these LERs has-provided additional input to our  !

22 overall management assessment'of operations to date. l 23 At the June 19th meeting, I' described an ongoing 1 24 evaluation of configuration control aspects of our work l 25 control program. We have. completed. evaluation, and have :l

" p. Heritage Reporting Corporation a v (202) 628-4888 I

l 36 1 reached the-following conclusions.

2 Existing station programs and procedures;are 3 satisfactory to maintain configuration control-of installed 4 plant systems and components. However,-the-administrative 5 controls for a configuration control are fragmented l 6 throughout our station manuals and procedures.

7 The task team that performed the configuration 'I 8 review recommended that the existing' configuration control 9 documents and procedures be consolidated and simplified to 10 provide a consistent, uniform configuration control program 11 for all departments, l 12 This recommendation is being implemented as part >

13 of the integrated program consolidation that I discussed  !

( ) 14 earlier.

15 In regard to the personal error LERs, as far as I 16 am concerned, one personal error is one-too many. Last 17 year, we implemented a human performance evaluation system, 18 HPES. As part of the implementation ofothis program, we i

19 review events caused by-personal errors to determine if' q 20 there is a fundamental underlying cause. We have-not 21 identified a unique cause for these events,.but we have  ;

22 identified several factors contributing to personal errors.  ;

23 Attention to detail:is always a concern with 24 personal errors. We have identified two areas we will be 25 1

addressing in order to increase attentien to detail.

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"\ l These are self-verification, or self-checking if you will,.

(O 2 and increased management supervisory presence and i

3 involvement in the field. l 4 It should be noted that there is a lot of-5 activities being performed during power ascension.

6 And whenever there is a. lot of activities, there.is always l >

7 the potential for personal errors. That notwithstanding, we-l 8 are concerned about personal errors, and we will continue to 9 work on eliminating them.

10 The two LERs involving unlocked high rad areas.

11 were unique in their ultimate cause, but could.have.been-1 12 prevented by self-verification. These two LERs in f 13 particular I found very disappointing. In both cases, the

() 14 doors appeared to be locked,'but physical manipulation of 15 the door would have revealed the problem.

16 Meetings have been held with'the technicians 17 involved to review'the physical configuration of locks andi 18 doors, and to reinforce the need to physically check doors ,

19 to verify their security..

20 I made it clear to station managers and-21 supervisors-that I would not tolerate these: types'of errors.

22 It should be noted, I said it irt a few decibels higher <than 23 I am talking to you today.. ,

24 Finally, I would like to assure you that we will 25 not forget the lessons learned during the' low power and Heritage Reporting Corporation

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'T 1 Power Ascension Testing Programs. We'are using the (V '

2 experience gained to enhance the operation of both the 3 station and the company. ,

4 Now I would like to turn the. presentation-back 5 over to Ted. Ted? l; 6 MR. FEIGENBAUM ' Thanks, Bruce. Well, the t

7 presentations today have~ emphasized some of the ways that are 8 are striving to establish and maintain a pro-active 9 philosophy at New Hampshire Yankee. A key. element of that 10 philosophy is finding weaknesses before they manifest into 11 operational problems.

12 Although the power ascension self-assessment has L

13 formally concluded the process of internal self-evaluation

() 14 and critique remains very active at the company. Through a 15 combination of line management self-evaluations, 16 comprehensive root cause and event evaluations, formal  :

17 quality program performance-based reviews, and most of'all 18 close tracking and follow-up of the corrective actions that 19 come out of all these self-assessments and reviews, we. .

t 20 believe that New Hampshire Yankee will remain ahead of.the- ,

21 curve-in identifying and addressing weaknesses in our >

22 programs and procedures and people.

23 I think Seabrook is off to a good start. Our 24 testing prooram demonstrated the readiness of the staff of 25 the plant systems and equipment for plant operations.

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1 And as we enter the early years of commercial operation,- ]

}

2 I can assure you that safety will be utmost in our minds of  ;

3 management during all our decision-making processes. And we 4 will continue to work towards ways to improve.

Now, interestingly, industry experience has'also f 5

6 shown that the plants with good safety records, the ones 7 with a few unplanned trips, few violationo or challenges to-8 safety systems, and with good maintenance practices, are 9 also the reliable and the highly productiveJplants, as well.

~

10 And it is our corporate. mission, and the mission-11 of all'of us here at the table, to achieve'all of these. -1 12 goals and join the ranks of some of the more successful l 13 power plants in this nation.

() 14 That, essentially, Jon and Tim, concludes our 15 formal remarks here this afternoon. If you have any 16 questions that you would like to discuss on the.  ;

~

17 self-assessment-or the Power Ascension Test. Program, we 18 would like to respond.

19 MR. JOHNSON: Sure. .I think we have quite a few.

20 questions. I will start off by asking, first of all, 21 I guess, in the maintenance area and.the technical support 22 areas, you talked about annual reviews of maintenance .

23 requests, or backlog of maintenance requests, and an annual 24 review of RESs, engineering service requests.

25 How do you envis' ion that annual review to take i

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I l 40 1 place? And wnat do you expect to get out of it? On the

(~

2 surface, Jc looked to me like it was not frequent enough to 3 get some benefit out of it. But maybe I misinterpreted the j 4 purpose of it.

5 MR. KLINE: Well, _ actually, we have monthly j 6 reviews.

7 MR. DRAWBRIDGE: Why-do I not jump in here?

8 We review within my organization, within production, we 9 review. We have a weekly report that comes out as to where 10 we stand on backlogo, et cetera, as far as work requests are o i

11 concerned. -That has a wide distribution. I look at it on a 12 weekly basis. Most of the other management within the J 13 company look at it on a weekly basis,1too, as'well. '

( ) 14 It is also updated for particular'iteme on a daily i 15 basis, on our plan of the day. And there is a plan of the 16 day report that also comes out, along with hot ~ sheets, et 17 cetera, for work requests.

18 We also have a committee called-the Smerk 19 Committee that looks a little longer term as.to items that 20 we want to have Engineering looh at, such as RESs, 21 reprioritize those on an ongoing basis. In fact, we have a-22 member-of our engineering staff that sits in on Don Moody's 23 morning meetings every morning. Every morning we have a' 24 meeting in Don Moody's office at 8 o' clock, where many of  !

25 the plant managers and supervisors sit in on.

Heritage Reporting Corporation (202) 628-4888 1

41 1 We have a member from Engineering who sits in on 2 that meeting, too, as well. And if problems come up that 3 were noted the previous day, or that evening,.that we want-4 Engineering to look at, we tell that Engineering 5 representative. At that point, he goes back,_and that 6 becomes the top RES, if you will, right for that day.

7 So there is a continual feedback for ongoing-type things.

8 And then on a periodic basis, we also look as to-l 9 where we stand with che RESs.

i 10 The annual review, that is more of a sanity check, 11 if you will, as to where we stand, where we want'to go, . et . j 12 cetera. '

13 MR. KLINE: That is really to adjust our goals,

() 14 most of it. I 15 MR. DRAWBRIDGE: Right, right, i

16 MR. KLINE: To see whether you set the right' goals 17 for backlogs.

18 MR. DRAWBRIDGE: How we have done it in previous 19 years, how we are looking this year or-this past. year, where 20 we want to go, you know, in future years.

21 MR. JOHNSON: Have you had one of those yet?

22 . MR . DRAWBRIDGE: For this year?

23 MR. JOHNSON: For any year. Have-you had this 24 annual review meeting or. goal meeting?  !

25 MR. KLINE: Yes.

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t 42 1 MR. DESMARAIS: It basically came off as part of.

2 start-up reviewing, everything we had out.there, to make ,

3 sure that nothing had fallen through the cracks.

4 MR. JOHNSON: ~What do you see as the big picture?

5 Do you see yourselves able to manage the backlog?

6 MR. DRAWBRIDGE: Oh, yes, we have been managing.

7 the backlog right-along. You mean as far as RESs and --

8 MR. JORNSON: Let'sLjust take engineering 9 requests.

10 MR. DRAWBRIDGE: Oh, yes. C41, yes. They have _

11 'come down substantially. I'do not have the numbers in front' 12 of me, but.from previous years, they have gone down quite a 13 bit. I do not know, can you --

() 14 MR. VARGAS: The program started in 1986..

15 Basically, the RES program is a' vehicle'for all-the-16 departments to communicate with Engineering, not'just the 17 station. Since 1986, we have received about.4,000 RESs.

18 To date, there are about 750 that1are open.-

l 19 Now, the annual review =that you were alluding to -

20 is the annual review of the five-year plan; .We.take every 21 RES that is scheduled, and put-it into a five year plan.

22 We started this about a year-and-a-half, two years-ago.

23 And every year we update the five year plan, such that the

~

24 initiator of the RES now knows whether we are going to 25 respond to his concern, j'] ' Heritage Reporting. Corporation

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/ 1 Now, there are a lot of forums,-as-Bruce has 2 indicated, whereby the priority of a particular RES can be  ;

3 raised. Specifically, that is the daily Don Moody meeting,  !

4 or the daily DOE meeting, or the weekly Smerk meeting, Smerk l 5 meaning, as Bruce indicated, is a Seabrook Modification 6 Resource Committee, of which engineering participates, the 7 station participates, Operations and Maintenance 8 participates.

9 , So there are at lecst three forums, in addition to l

l 10 the annual review of the five year plan, whereby-priorities q 11 of the RESs can be raised.

12 To date, we have no priority one RESs open.

13 Priority one RESs are very high priority items, which we

() 14 respond to within two or three days. Those are priorities.

15 Most of the RESs that we have are priority three and' fours, 16 which are long-term enhancements. Those are factored into -

17 the five year plan. And every year at this time, we get-18 together and revise the five year plan.

19 MR. JOHNSON: Okay. * *

.i 20 MR. FEIGENBAUM: A' lot ofLthe priority three and j 21 four RESs have to do with efficiency enhancements, ways to

  • l 22 make a job easier for the plant and more efficient, less 23 time, less personnel. And we schedule those as we can get 24 to them, and evaluate them on a routine basis. -

25 The ones needed to support the plant, again

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through-the daily involvement of Engineering,_at the. station managers' meeting and a constant Smerk re-review of the-3 priorities, the station is' supported. So we will always 4 have some backlog of good ideas that people have that we 1

5 will be evaluating at one time, and putting into the. i 6 schedule as we can handle them.-

7 MR. JOHNSON: Okay.

8 MR. DRAWBRIDGE: And those RESs,'I think as was -

9 noted earlier, are not only just-station requests, they :1; t

10 support the entire site, as well.

11 MR. WIGGINS: In your assessment report, the 12 maintenance area,.a couple of items of places where I guess 13 you referred to as needing improvement,. kind of intrigued

( ) 14 me. Maybe you can give me a little bit more background as 15 to what they are, and what their significance is.

16 I guess it looks like=you think you need to do 17 more work in rework, and root cause analysis, and 18 maintenance history collection analysis and application.-

19 Tell me'a bit about what you meant by that, or how bad the- :l 1

20 problem is.

21 MR. DRAWBRIDGE: Well, in the area-of. rework, 22 right now, we are.looking at a definitive-way of defining i 23 what rework constitutes. Right now, we do not have an-  !

24 indicator where we can follow the amount of rework that 25 occurs. '

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-45 1 Right now, I have a maintenance manager looking at 2 the INPO definition of rework. We are going to come up with  ;

3 a definition, and use that for the last quarter of this 4 year. And what we want to do is, beginning of next' year, we 5 want to set a goal for -- a limit as to how much rework we 6 want to shoot for. We want to first define, you know, what<

7 rework is, so we can put it into our data base so that when 8 we have a work request that has rework associated'with-it, 9 we can capture that information.

10 MR. WIGGINS: Is it your sense that there is a- j s

11 rework problem now? That you do not have the. answer now,; or 12 just you want to make sure that --

13 MR. DRAWBRIDGE: My gut feel.is we do not have a

( ) 14 problem. But if you do not really look-at'it carefully, and 15 .really define what rework is, how can you -- I mean, ituis-  ;

16 just a gut feel. You have to really define what you-17 consider rework, and then see what'you have. And then.go 18 from there.

19 There is nothing'that-jumps out at me as=having a s 20 problem, no. But I want to be able to define it,'and be-  !

21 able to see where we really stand.- Then we can start-22 comparing ourselves-with other plants 1that use the same-23 definition. Hopefully other plants will be using the same-24 INPO definition. And reallyLsee where we stand, and where 25 we want to be. That'is the'important thing; where we want T Heritage Reporting Corporation (d

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MR. WIGGINS: How about.for the root cause i 1

3 assessment in the maintenance azea?

4 :MR. DRAWBRIDGE: Yes, I mentioned it very briefly.

We developed a procedure that just got out on the street the 5

l 6 end of July.. To define root.cause, and how to use root I 7 cause methodology. This is more for' things that are of-a 8 more minor nature, where you would'not do a. formal 9 full-blown. root cause, but you still want to capture that 10 information so that you could put'it bsck into your data-11 base, along with the rest of your'maintsnance activities.

12 So if you have a problem with a piece of 13 equipment, you can really define what thattroot cause is, 5

() 14 and'make sure you are really, really correcting it. That is 15 why we wrapped it in with the rework, because if you do not; 16 define-the rework and if you do not really find ~the root =

17 cause, obviously you"could, in the future, cause more  :

18 rework.

19 MR. WIGGINS: The improvements =in maintenance 20 history, data collection that you are shooting.for,: does 21 that portend a problem with your documentation that exists 22 so far?

23 MR. DRAWBRIDGE: That alludes to the data base, 24 I believe. The unified data base.-

25 MR. DESMARAIS: There are really two aspects to ,

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47 1 that.

2 MR. DRAWBRIDGE: Yes, sure, go ahead. Go ahead.

3 MR. DESMARAIS: When we reviewed a good-sized- 1 4 sample of the work requests, we identified the fact that-5 some of the documentation of the work history at the 1

6 conclusion of the work efforts was lacking. It was thure, I 7 but it was not sufficiently definitive to-provide for later-  ;.

8 application and analysis and application of the history, so 9 that you would be able to use it in a predictive sense.

10 So that area that we are identifying is to improve 11 the existing practices for documenting work history,'so that 12 they can actually be applied in a more predictive manner. .

13 MR. WIGGINS: So basically;you have records that

( ) 14 an activity took place,-you are trying to improve 1the i 15 description of what the activity was.- Your trying to1 guess 16 what information you would need to have in-there,~say, if- T

-17 you are looking at it five years.from now.

18 MR. DESMARAIS: That is-right, that-is right.

19 MR. WIGGINS: Okay. I had:a couple of other 20 questions that go outside of maintenance.  !

21 In your report you talk about your verification' 22 team looking at EOPs, and you. identify a series of'EOP 23 discrepancies. Give me a feeling for the-severity-of those i 24 discrepancies? I 25 MR. DRAWBRIDGE: Do you want me.to hit-that, or do-l Heritage'Reportingz Corporation-(202)'628-4888

48 1 you want me to do it?

2 MR. DESMARAIS: Why do you not do it?. ,

3 MR. DRAWBRIDGE: The EOP-type things were 4 relatively minor type of. problems that occurred. We didta -

5 complete re-review of our EOPs in' preparation for actually a' 6 review that-is occurring.

7 Whenever I am in this building, I am always 6 worried about the roof coming off. ,

9 (Laughter.)

l 10 MR. DRAWBRIDGE: I am sorry, I lost my train of.

11 thought.

12 (Laughter.)

13 MR. DRAWBRIDGE: I can address that a little. bit  !

()-14 in technical support.. As.part of the independent process, j 15 we loan some of our more senior peopleito Operations for

]!

16 their effort for validation. verification. And the' majority -'

17 of the-effort has been to make sure there has been  !

18 consistency throughout the preceduros,.to maka:sure the f

19 procedures are consistent in approach, in going from one-20 generation to another or in. referral back and forth between-i 21 procedures. And it has been pretty much minor clean-up.  !

22 EOPs have.been used on the simulator now for a 23 number of years. And they have been-in pretty good shape, ,

24 overall. '

25 MR. PILLSBURY: In the SAT report,z it talks:about '

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49 1 one technical discrepancy. -And then a number of additional l 2 discrepancies, but those were administrative discrepancies 3 of a minor nature, as opposed -- I believe that it is in the 4 . operations section of your report. ,

5 MR. WIGGINS: Okay, so basically your sense is I 6 these are minor discrepancies. ,

7 MR. PILLSBURY: Yes.

8 MR. WIGGINS: You indicated in the discussion on, 9 I guess one of your events or trips, that the problem was a #

10 repetitive task procedure, was marked for change,.but the 11 change had not been made before that repetitive task was --

l 12 MR. DRAWBRIDGE: Yes. In that case --

13 MR. WIGGINS: .I guess in reading the report, I got

( ) 14 a different view. -I guess maybe I am just captured by'the 15 words that indicated a note was made on the<one, and then a 16 month later, the procedure goc issued in a note that 17 followed along. And-as a result, it repeats the same thing.

t .

18 That was the generator fan.

j 19 MR. DRAWBRIDGE: Okay, I was. going to takeLit. .

1 20 That involved the package already being ready to go.

21 MR. WIGGINS: I guess the question I really had,.

22 and I guess you addressed it, I wanted to knowowhat the l

23 outcome is. When you used your SAT, in my understanding of.

24 what you said, asked,'is there a more generic problem in-

, 25 terms of how procedures are changed, revised?. And'I guess  !

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l 50 1 that is what'I was wondering, what you find when you looked 2 at that.

3 MR. DRAWBRIDGE: In this-case, they reviewed the l l

4 repetitive task sheet, found the problem, corrected the 5 problem. However, we did not4 take it one'more step.

6 The repetitive task sheet, a lot of times we will.

7 pre-stage certain packages, ready to go into the field for:  ;

8 use. We did not take that extra effort to verify the RTS 9 when it was updated, that there was not already a package.

10 already formulated ready to go out in the field. In that  !

11 case, chat-is what happened; there was a package ready to-12 go.

i 13 So since we did not take that extra effort to make

( ) -14 sure that there was:not an old RTS ready to initiate, that-15 package did go into the field,. and'we had=a problem ~.

16 MR. WIGGINS: And what.have you taken'to address 17 that problem?

18 MR. DRAWBRIDGE: Now what we willdo, as a further

~

19 step, when an RTS is. updated, we will check to see if: there 20 is any packages there that are'already pre-staged, ready to.

21 go out in the field.

22 111. WIGGINS: Okay. .It seems you-would be ,

i 4

23 susceptible to having that,Jif-you pre-stage maintenance 24 work, and have procedures in there---

25 MR. DRAWBRIDGE: That-is right, that is right.

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51 1- Same is true of RTSs or procedures, as well.-

2 MR. WIGGINS: You could get a vendor document that 3 comes in, that says, "Now, do not.do it this way, you have 4 got a pre-staged work package that references the.old 5 vendor's way of doing it."

i 6 MR. DRAWBRIDGE: Exactly.

7 MR. WIGGINS: That could tr&p you.

8 MR. DRAWBRIDGE: So what we do now is,. if we are 9 changing a procedure, or if we are changing an RTS, we would 1 10 check'and verify. l 11 MR. FEIGENBAUM: Prepared work packages.  ;

12 MR. DRAWBRIDGE: For a_ prepared work package, to 13 make sure if there is a prepared work package out there,

( ) 14 that we would pull that package, make a change to the.RTS or 15 the procedure.

16 MR. WIGGINS: That is'more-effective than the 17 other way around? Verifying any procedure in the package as 18 the up-to-date revision?

19 MR. DRAWBRIDGE: No, no, no,.no. They are up.to ..a 20 date. They are up to date at the time the package is 21 developed. You have to understand'that we will -- in the 22 case, we used what we call a system week concept, where in a-23 given time, you already have scheduled out certain systems 24 that-we are going to do preventative maintenance on. .

25 And that is scheduled out well, well, well.in advance. '

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1 52 1 -About six weeks'before that syster week comes~up, 2 we will prepare the packages for that syr,cem week. And what-

]

l 3 I mean prepare the packages, it is not only putting in thel l

4 procedures, et-cetera, et cetera, it is also verifying that- ,

5 we have spare parts available, depending upon what.the-RTS l f .

6 or the procedure says. So that the package is whole. We-1 l 7 know when the individual takes that package snd goes out on L I l 8 the street, he will have the spare parts,fhe will have the -

9 equipment, and he will have the procedure. He will have a 10 everything'needed in order to doLthat process.

11 Unfortunately, you have,this gap where you:will f 12 have a package ready.to go, but'it might be a month or a 13 month-and-a-half before the package'is-actually implemented.

( ) -14 So it is for that time frame where.a new procedure or.a new

-15 RTS~ revision comes through that we have to guard to make sure that, when we make that change, we go back'and pull'the

~

16 4

17 package.

18 MR. WIGGINS: The problem you'are attacking, that-

19 you just discussed, would it be different?then from let'st 20 say a surveillance test that is pulled out and is found to I 21 have a problem in it?- And then a changesrequest is
made to 22 the surveillance? And'the methods that you have at Seabrook 23 to make sure that next time you go through the surveillance, t

24 you will at least note that-there-is a change outstanding.to 25 it?

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Most people that I-have seen'do it=the other way 2 around. Whenever they.get their hands on a procedure, one 3 of the things that the procedure user has to do is make sure 4 he has in his-hand the up-to-date' revision, whatever kind of 5 change paper is out against it..

6 WE, DRAW 5 RIDGE: We had this squared away for 7 procedures. We have always had for procedures that you go 8 back and check the package. We did not have it1for RTSs. .

9 And that is where we fell.down.

10 MR. WIGGINS: So this was the outlier. '

11 MR. DRAWBRIDGE: .This was~the outlier, yes. I 12 MR. WIGGINS: And then my.last one.

13 MR. MOODY: I just want to echo, procedure-wise,'

() 14- that cannot happen, as far as a delay in the-RTS. You.first 15 mentioned procedures issued for a periodlof hours.- Anything 16 that'is out there is retrievable through the system, where 1

17 the.t procedure exists in.a pre-stat'ed-document. And it is 18 changed at the time the. procedure comes out.

19 So procedure-wise,Dit'is,uas I just mentioned 20 before, when a procedure comes out-with.new change,.alli work.

l 21 associated with that change or planned to be associated with 22 that change is changed at that time. The repetitive" task <

23 sheet is a data sheet, if you will, and that is the open i ,

! 24 mark that Bruce mentioned.

25 MR. WIGGINS: :And theclast' item is jumping to a

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1 =new area. I guess this is kind of an: observation. I was 2 reading through your performance indicators, and I was 3 intrigued or taken aback at.the licensee event reviewers.

4 Mainly, I have no problem with a goal-of reducing those LERs ,

5 caused by personal error.- But I was kind of intrigued by  :

6 how you got to it. The statement says, "To maintainLthe 7 total number of LERs as low as possible, the~ corporate goal 8 is LERs caused by personal error to'be less than or equal to 9 five."

10 Now, it is the first'part of the. sentence.that I

11 intrigues me, because if not properly communicated to your. i 12 staff, they could get the view that you are trying to 13 suppress LERs, or you are trying to hold down the-number of

() 14 them, which I do not think is what you-really want to do.

15 MR. DRAWBRIDGE: No.

16 MR. WIGGINS: I think you really want to report 1

17 everything that needs to be reported,.and you would like-to 18 solve the underlying causes that precipitate _the events that-19 are being reported, so you lower them-thatJway. I guess, I' 20 assume that is your view.

21 - MR. ' DRAWBRIDGE : That is right, that is correct.

22 MR. WIGGINS: And>your people understand that?

23 MR. DRAWBRIDGE: Oh, yes,: yes. They understand 24 that.

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25 MR. MOODY: That-has been discussed with al1 of 1

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55 I 1 the organization, from the-new mechanic or operator coming 2- in to the top levels of. management.  !

l 3 MR. JOHNSON: One of the events you had was a j l

l 4 problem with valve line-up by instrument rack, a pressure-f l

5 transmitter. We found some extra valves that were not on,^ q 6 I guess, any, kind of control system.

7 Your assessment of that prob'lem describes going; 8 out and looking at the valves in the plant to see if you 9 have any more problems like that. And it goes in and it 10 talks'about updating some instrument loop diagrams.

11 Could you give me a=little bit more detail as to 12 how confident you ' feel in your P and- ids,:- and your valve 13 line-ups? But not just your valve-line-ups. :How about.

O 14 circ =1t-bre x r e <= > 1, ie tai v 1ve, 15 but you know, how confident you are about the' systems your 16 operators and technicians have to operate the plant.by.

17 MR. VARGAS: The PIDs have undergone.various 18 stages of revision. All the P and ids have been redrawn 19 from the old CP and ids to the -- P,and ids. j

~

They have-all 20

~

been field verified, field walked out.: And we feel very 21 confident that-they reflect the actual' condition of the 22 plant.

23 The condition of.the valve through the PT-506,-

24 that would appear on the'CWD ILD portion of the electrical 25 schematics that we are generating right now..

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-The engineering documents that-depict that valve 2 right now are on the old UEC drawings. Since that issue has 3 surfaced, we hr.ve now undertaken the:CWD ILD version of-4 engineering schematics. It is, in essence, a three~ or 5 four-year plan to show.all instrumentation-valves-on 6 engineering schematics. We decided this on a system-basis.

7 We decided this on the CBS system. As we finish the system 8 by system, we are going to walk these. systems down such 9 that, by the time we are through, by the time we are 10 finished, all of the instrument valves will show-on the .!

11 electrical drawings.  :

12 MR. FEIGENBAUM: And.in theLinterim period, Joe, j 13 until that effort is --

() 14- MR. JOHNSON: Yes, howLdo you' control it now?

15 MR. VARGAS: The way we control it right now, the 16 valves are shown on engineering documents, okay?

17 The problem that we have had was that-they were not 18 consolidated-on drawings right now. 'They show on two 19 fragmented drawings. 3 20 In this. particular case, irt looking at the 21 procedure, the procedure did reference the correct 22 engineering documents. The drawings that the procedure had r

23 referenced were correct, and they were shown on'those 24 engineering documents.

25 MR. FEIGENBAUM: Gary or Don, maybe: you could talk

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57 1 about the walk-down that was done.

2 MR. MOODY: We looked at the walk-down, these type 3 of instrument racks that had a bulkhead valve, identified 4 any other existing ones, had those bulkhead valves and.

5 identified them in procedures as such.

6 There is two mechanisms that control those 7 instrument = panels. One is what we call 4.5. They go up, 8 and the valve out there in the instrument system that is not 9 in the proceedures that make up the 4.5. Which shows that 10 they are operating that valve, and it also shows that they 11 restored the valve to the original condition, following.the 12 evolution that it is going to go through.

13 And the 4.5-form is used for those valves that are.

( ) 14 not specifically identified in -- the 4.5 is.normally a 15 valve with a policy; change position, be it a lifted - ~4.5 16 may -- and in fact, the need'has been terminated.

l 17 MR. JOHNSON: How'do'they know whether they can 18 open this valve if it is not in the procedure?

19 MR. MOODY:. Because it is aar instrument. valve, it '

t 20 is identified as an instrument valve, then the instrument -

i y 21 people can open it. If it is an operation valve, you follow I

L 22 the operational --

23 MR. DRAWBRIDGE: Those valves, however,~they were 24 going to be -- the rack-mounted valves were going to be, or

s 25 have been captured, as I recall, in the RTSs. And we - are:

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58 1 1 going to lock-wire them1either open or closed,-depending-2 upon what the situation was. Because it was not only what 3 we call bulkhead valves, but it was als'o when.we went l 4 through our walk-through, it was also drain valves. We '

l 5 wanted to make sure that were in the proper configuration.

6 MR. WIGGINS: On the racks?

7 MR. DRAWBRIDGE: On the racks.- And we also did--a t

8 walk-down of non-rack-mounted.

9 MR. WIGGINS: What is your boundary for 10 responsibility,. say on-an instrument line? You got the. '

j 11 process, then you got a root valve. And then all of a l

12 sudden, it gets in the. instrument line, and you wind up with:

13 a bunch of instrument-valves-in the --

() 14 MR. MOODY: The operation is a general statement.

15 Operation is taken to the root valve. IC has a valve 16 downstream.of that, manifold drain valves --

17 MR. DRAWBRIDGE: In this case, that particular-18 valve was in the rack. It was in a different area; it was 19 up higher than the rest of the, the manifold valves, if you-20 will. But it was clear it was an INC. valve'.

21 HR. WIGGINS: Okay, so.it was not'a jurisdictional 22 problem.

23 MR. DRAWBRIDGE: No.

24 MR. WIGGINS: It was just a valve on the rack that 25 maybe had been missed.

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J 59 1 MR. DRAWBRIDGE: Right.-

2 MR. FEIGENBAUM: And now it is in the RTS. 1 3 MR. WIGGINS: Now-ittia in there, all right. That 4 has happened before. ;l 5 MR. DRAWBRIDGE: .Oh, yes, yes. There was, in'this s

6 case there was a root valve further up right near the. l 7 turbine. In this case, it was clear that'it was an IHC -

8 valve.

9 MR. JOHNSON: Okay, I. guess'I am a little-10 confused. I thought this was'a new. set of valves that was-11 not on, and valve line-up sheets, it was not on procedures, 12 and it was --

t 13 MR. VARGAS: As I'said before --

() 14 MR. JOHNSON: .In'other words,-a missing-set of '

15 valves.

~

, 16 MR.- VARGAS:' The engineering documents;are l'

L 17 correct. They have.been correct.

18 MR. JOHNSON: Okay.. Okay,~now, I guess the L 19 question is,: in this assessment : report, 'what :do you feel 20 about your system for taking the engineering documents, and-21 implementing them as an operational tool?

22 MR. VARGAS: 'The engineering documents that are' ,

23 existing today are accurate, and they-reflect the condition 24 of the plants. The ILD and CWD effort that we are 25 undertaking is-to enhance the maintenance capabilities of, j i

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60 1 the system. It is purely a maintenance tool for them to 2 interpret our documents, but.the documents that we have on  ;

3 the street today are correct. "

4 MR. JOHNSON: Well, let's say you start up from-5 your next refueling outage. What will'you use to line up 6 your systems?

7 MR. DRAWBRIDGE: We will use the revised RTSs for 8 that particular equipment that -- let's say the INC person 9 would be involved with. The RTS would include all the 10 associated valves;when he goes to' align that particular  !

11 circuit. l i

12 MR. JOHNSON: And does this RTS, if it has all the  !

13 valves in it so it does not need to refer to these- ~

l

( ) 14 engineering documents.

15 MR. DRAWBRIDGE: That is.right,-that is;right. l 16 Obviously, the-individual can look at the particular 17 drawing, too, as well, if he so desired.: But*the<RTS would 18 capture those valves.

19 4 MR.-MOODY: Calibration procedures -- whether-that -j 20 is true -- verifications of the,--

21 MR. WIGGINS: That is an intriguing question. As i

22 I said, I do not think this is the first plant that.has had 23 this problem. That there have been particularly 24 instrumentation valves that exist, and they were not rcally-

25. captured on either operators or the INC text procedures or i -

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1 line-ups. At least it seems to me I have heard of that 2 before.

3 If that is true, if I am right that I have heard L 4 of that before, does something in your processes fail you )

5 that you were not keyed to go look out at Seabrook to see if 6 you had exposure to that kind of a problem? Was industry 7 experience telling you that? Or did you ask yourself that?. -

8 MR. FEIGENBAUM- Well, Jim, the way I understand 9 your question is that.a valve that is not shown anywhere.

10 These were shown.

11 MR. WIGGINS: No, no, no. See, well, maybe'I am 12 wrong. What I think the man said is - -

13 MR. DRAWBRIDGE: They just-were not on the RTS. -

() 14 MR. WIGGINS: These arecnot spurious valves, 15 They are on engineering drawings. The plant is constructed i 16 the way the drawings say the plant'should'be constructed. -i i

17 MR. DRAWBRIDGE: That-is correct. 4 18 MR. WIGGINS: Well, that is fine. But usually  ;

19 people out that are task operating: facility, INC operators,- .i 20 whatever, they do not carry a-whole spectrum of engineering 21 drawings with them. They have some drawings.that.they find y 22 particularly useful, and'are' controlled-that way. And.they i 23 have procedures. And they go out with one of the'two to.do 24 what they do what they want to do. 4 25 And it has been, I-think I heard-before,1where you ]

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t 62 j 1 navs, if you put the operating procedures about a line up

{

2 here, and you put the instrumentation and control toch  !

3 procedure here; you put the two together, and sometimes 4 valves like these fall through the cracks. They are not on .

t 5 either. Okay, I have heard of that before; I have seen it 6 at other facilities. Have you? And if not, why didn't your 7 office assessment organization not alert you to that type of 8 thing, before you got to this point? -

9 Granted, it was an easy lesson to learn here.

10 It was not exactly the most earth-shattering thing of- f 11 importance. It is the best way to learn these kind of a 12 low-impact thing. But was there something that you missed?-

13 Or you have not look at yet, maybe? That ycu might be able l

l ( ) 14 to get something out of assessing?  !

15 MR. DRAWBRIDGE: No, we certainly looked at it 4

16 now, because we did the walk-downs of all those rack-mounted 17 instrumentations. Basically, the RTS primarily looked at -

18 the configuration of the actual manifold itself. It did not 19 include, not only these valves up here, what I call bulkhead  ;

20 isolation valve, it also did not include the drain valver, ,

21 too, as well.

22 MR. WIGGINS: That was not the scope -

23 MR. KLINE: Jurisdiction was addressed on that, t 24 whether or not bperations or INC had primary responsibility ,

25 for position.

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1 MR. WIGGINS: What I am getting to is, if you have 2 an office assessment and you have people plugged into the i 3 industry, you know, should they have told you or warned you l 4 that there might be a problem? So you should have found 5 this? You know, as you were getting operating proceedures.  ;

6 MR. DRAWBRIDGE: I see. I misinterpreted your --

l 7 MR. WIGGINS: Yes, I do not have a problem with  !

8 what you did after you found it. That sounds fine, you 9 know. Did something fail you? The elements of your  :

10 organization that are trying to keep wired into what the- l 11 '

other utilities developed, did that fail you?

12 MR. DESMARAIS: Jim, when we did the~ assessment,-

13 we did not uncover <anything that would have led, through the

( ) 14 office auparience review program, would have led us to look 15 at that problem.

16 MR. JOHNSON: I guess my final question, what 17 about breakers, fuses? Have you taken this experience, and 18 gone to the --

19 MR. MOODY - Hand slide lengths.

l <

! 20 MR. JOHNSON: Slide lengths. You have got things 21 that electricians operate, and things that INC technicians 22 operate. And what about the things that are in the middle, .

23 that nobody is -- that somebody is missing right now?

24 MR. DRAWBRIDGE: I think we are in pretty good 25 shape. I think I alluded to it when I spoke on the

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64 1 configuration management control, that we.think we have 2 captured everything. The problem from my perspective is, 3 the problem is that some of the departments are using a 4 slightly different method from department to department.

5 And we want to make sure we use the same standardized 6 method, and that the configuration control for Seabrook 7 station is streamlined, everybody understands what everybody 8 else is doing. That way, there is no question in the i

9 future, if a new system goes in, for example -- skid-mounted  ;

10 system, or something like that.

11 If you have skid-mounted system with vendor 12 supplied valves, for example, it will be clear whose j 13 jurisdiction those valves come under, and which procedures

() 14 that they follow up on.

15 So what we want to do is, we think our l 1

16 configuration control program is decent. We want to improve i i I 17 upon it. We want to standardize it, and we want to make 10 sure everybody understands what is what, across the ,

i i 19 organization. We do not feel we have a problem department l

20 to department; we want to make sure that everybody,-the 3 21 right and the left hand are talking to each other.

22 Did I answer your question?

23 MR. JOHNSON: I think so. I heard that you have 24 looked at that. I just wanted to see if you t?'k this 25 problem with valve line-ups and went outside of that and

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4 2 MR. MOODY: What about the other thing of -- we i 3 also set up a task force to work within, that involves other 4 departments, be it INC, be it electrical, be it maintenance, l 5 be it operations, be it physical chemistry. On what they 6 had in place, as far as configuration control, and how that 7 narrows the base betwean the other organizations in the-i 8 station.

9 We had each department identify how they i 10 interfaced back and forth across that line. In fact, there I 11 is some consistency -- the same way.

12 MR. DRAWBRIDGE: See,.Jon, it is not only i

13 breakers, fuses, slide lengths, et cetera. It is also what

() 14 the configuration of a particular piece of equipment is at 15 any given time.

16 For example, you are probably well aware, at one L 17 point in time when we were at the beginning of power 18 ascension, we were going to do some trouble-shooting in the  ;

19 turbine. And we had an open work request ist order to do l 20 trouble-shooting on the turbine, as we were spinning the 21 turbine. And we ran into a problem with the slide length 22 not being in the proper configuration. That was because the l

23 work package itself was open.

24 We went back and looked at our configuration i 25 control process to assure that the work in progress for 0

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1 outstanding work requests, where you might be doing )

O- 2 trouble-shooting, that that package is properly reviewed to 1

3 assure ourselves that we do not have something in a  !

4 different configuration than what we want. l 1

5 So it is not only just fccusing on a particular  ;

6 piece of equipment. It is focusing on the timing on when j 7 that piece of equipment is being used, what you might be i

8 working on, and what that final condition of the equipment

  • 9 is.

10 Because the point I am trying to make is, we -l 11 should not only just focus on what type of equipment, but in 12 what situations you might be trouble-shooting or using that 13 equipment. So it is a many-faceted issue.

I MR. JOHN 90N: I understand that. I was just

( ) 14 15 concerned with the basic procedure, valve line-ups, and P 16 and ids, and circuit breaker line-ups. Whether you had all 17 the equipment captured in a system to be' used. I was not L 18 going to take it the next step in terms of during 19 maintenance. I just want to make sure there is a system  ;

20 there, whether it be a line-up procedure or a P and ID, that 21 is accurate and covers all the equipment.

22 Because for this cabinet or instrument rack, 23 I thought there were some procedures or drawings being used 24 that did not show them.

25 MR. DRAWBRIDGE: Which cabinet was that?

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i 67 1 MR. JOHNSON: That is the turbine impulse 2 pressure.

i 3 MR. DRAWBRIDGE: Oh, I see, yes.

i 4 MR. JOHNSON: The tools the people were using did t 5 not show, the RTS did --

4 i

6 MR. FEIGENBAUM: The RTS did not show that. That 7 is correct. That is correct.

8 MR. DUDLEY: Also, the loop diagrams.

9 MR. DRAWBRIDGE: I have to go back and look, now; 10 it has been a while, now. I am not sure. I do not think [

11 the loop diagrams showed it. However, the original document 12 did show it.

I 13 MR. DUDLEY: You had to go all the way back to the

() 14 engineering drawings.

15 MR. DRAWBRIDGE: Right. But correct me if I am 16 wrong now, Noel, was there not a valve number that was A or 17 B?

18 MR. DUDLEY: Yes. B-4.

19 MR. DRAWBRIDGE: Yes, there was like an A/B, yes. .t

. 20 MR. DUDLEY: It was a generic drawing for all 21 racks. ,

22 MR. DRAWBRIDGE: Right, right.

23 MR. MOODY: A typical.

24 MR. DRAWBRIDGE: A typical of the --

25 MR. DUDLEY: A typical mercury rack valve V Heritage Reporting Corporation I

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i 68 1 arrangement.

2 MR. DRAWBRIDGE: Right.

3 MR. JOMMSON: Thank you.

4 MR. MCCABE On the repetitive task sheet issue i 5 and the problem with the shifting of the fans on the  ;

6 step-up transformer. I see that the first time that type of l 7 problem came up was when you could not increase power above 8 a certain level because the interlock had not been cleared ,

9 from a previous fan shifting. l 10 Then the problem occurred, and then a very similar l 11 problem occurred because the isophase duct cooling fan 12 shifting brought about the same problem.

13 Are you satisfied that, one, the initial indicator ,

() 14 was properly listened to? And that the corrective actions 15 are going to cover not only the fans, but the isophase duct 16 cooling? And have you reviewed other places in the plant 17 where this problem may occur?

18 MR. DRAWBRIDGE: Yes, we have. You want to hit i

19 it, or else you can get the isophase question?  :

20 MR. KLINE: I will take it. At that first one,

! 21 where we had difficulty increasing, it was, in fact, a place 22 where we identified that there was a problem with our F

23 setback circuitry. That is where we identified that we did i

24 need to revise the RTS. l 1

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l 69 ,

I where we did not retrieve the field package. Therefore, we 2 ended up with a setback.

3 We did, in fact, review in detail all of our 4 setback and runback circuitry, however. And the isophase i

5 duct cooling was the result of an individual reading of  !

6 procedure, with a change already in it, and misreadin7 the 7 change.

8 There is a delay circuitry in that fan such that 9 dampers open before the fan starts. So when he started that- ,

10 fan and shut off the other one, there was a 30-second time  ;

11 delay in that damper opening before the fan actually 12 started, the other fan, the second fan, now being off.

13 But there was a dead band, and that came down.

() 14 So in fact, the review was complete.

15 The readability, I guess, of the change in the isophase duct-16 cooling fan situation was in question. But, in fact, the 17 change was made. And we do have, in fact, some temporary ,

18 medifications going in -- some permanent modifications going i 19 in, I should say -- to eliminate that as a problem  ;

20 altogether with the time delays in the circuitry.-

21 MR. MCCABEt You are modifying it on both sets of 22 fans?

23 MR. KLINE: Yes. Time delay is going in in 24 isophase, and static cooling?

25 MR. VARGAS Yes, static cooling. ,

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1 MR. KLINE: Static cooling. So all of it was t 2 reviewed. Unfortunately, an individual doing maintenance on j 3 the last event read the note incorrectly. i 4 MR. MCCABE On your maintenance personnel  ;

5 training, when do you envision completion of the training 6 modifications coordination that you have identified in this  :

7 report? And full accreditation of your maintenance training.

8 program. ,

9 MR. DRAWBRIDGE: Full accreditation, right now wo 10 plan to go for accreditation, I believe it is November of l 11 this year. We go before a board, the Accreditation Board.  ;

12 We have already had the internal -- they do not call it an 13 audit, but I call it an audit -- where members of the

() 14 academy, INPO, come in and assess not only maintenance,.but 15 it is also tech staff training, chemistry HP. There is a 16 whole bunch of them. We hope to get accreditation by the 17 end of the year.

18 But that is not the end of the process. That is 19 just part of the process. ' Accreditation is an ongoing 1 l

20 process, where you continually improve, and use feedback ,

l 21 from what is actually being done in the field to improve-l l 22 your training programs. And then we have the accreditation

23 that occurs every two years thereafter.

24 So we do plan to get accredited by the end of this (!

25 year. But from then on, we will be constantly doing an i

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i 71 1 interin. process in our training programs, not only for 2 maintenance but all of those.

3 MR. VARGAS We have gone through the maintenance [

4 qualification, to check off_or not check off, whichever ,

5 would be the case, which individuals qualify for what tasks, 6 in conjunction with preparation for going through the 7 accreditation.

l 8 MR. DRAWBRIDGE: We also use training l

9 coordinators. For example, in the case of maintenance and 10 some other departments. We find that to be very useful.

11 They act as a liaison. They are in the department, and they

^

12 act as a liaison between the department and- the training -

13 department. That way when they see problems, or a

() 14 department head sees an area where they feel there is a 15- weakness that can be addressed by training, that is sent 16 back to the training department.

3.7 MR. MCCABEt About the area of radiation 18 protection, when you are shifting from no source term to a 19 bigger source term whose operation is continuous, what are i 20 your plans in regard to radiation protection, staffing, and.

21 in regard to the rad waste disposal issue? What are your 22 plans for going ahead with those areas?

h 23 MR. FEIGENBAUMt Don, you want to take that?

24 MR. MOODY: At the present time, where the rad 25 waste storage area, store rad waste, we have got-them at the

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a 72 j 1 station. We are sorting, segregating, compacting rad waste 2 we generated to date. And we are getting on the order of 94  !

3 to one reduction.

4 But, as you mentioned, we have only had a' source 5 term for a short term. We have probably got, to date, 6 accumulated around 100 cubic feet of low-level waste, which j 7 we keep on site.- We have got enough storage area on site at 8 least for the first cycle, and probably up to at least two ,

9 cycles to store it in the buildings we have got there on  ;

10 site. Then we will either have to use another building on [

11 site, or build a facility to store low-level waste.

12 That is the status we have got right now. ,

i 13 MR. FEIGENBAUM: Do you want to discuss the

( ) 14 staffing, Don?

15 MR. DRAWBRIDGE: Do you want to hit that, or do 16 you want me to hit that?

l 17 MR. MOODY: Go ahead.

18 MR. DRAWBRIDGE: Okay. Well, the reason why I 19 thought I would discuss it is I had a talk with Ron Nimitz 20 last week on this very issue.

21 Staffing in the HP area we are going to watch 22 carefully. Right-now, we think we are adequately ataffed. ,

23 We are certainly not overstaffed in the area. There are a 24 couple of areas that we are keeping close watch on. Records-l 25 keeping area is one. And also the amount of overtime that-l Heritage-Reporting Corporation (202) 628-4888 -

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73 1 we use.

2 We are going through the budget process right now.

3 Next year we are also looking very carefully as to what kind 4 of augmentation we are going to need for our first refueling 5 outage. This is an area we are going to watch very closely.

6 We are just beginning to-see a source term, of course, and 7 as I alluded to earlier, in the HP area, we are being 8 challenged for the first time. And I think we have to keep 9 a real close watch as to where we are, and where we are 10 going.

11 This is something that Don and myself, and other 12 senior management is going to keep a real close eye on.

13 MR. FEIGENBAUM: We-feel comfortable right now-( ) 14 with the staffing, the way we are.

I 15' MR.-JOHNSON: Is the control of overtime adequate? l 16 MR. DRAWBRIDGE : Control of overtime? 'I get 17 overtime reports for all areas, not just HP, but for all 18 areas. And we watch them. And we do have some overtime 19 that occurs in the HP area right now, doing surveillances, 20 et cetera. And we.have to watch that. We have to make sure i 8 21 that it does not get excessive in any way, shape, or form.

22 But right now we want to take a.look at that area, 23 along with other areas, too, and see where we check out.

24 MR. DUDLEY: Yes, one area I wanted to touch on 25 was your quality assurance program. I know that you have Heritage Reporting Corporation (202) 628-4880 l i 1

74 1 outstanding some recommendations in the quality assurance-2 area, where you decide responsibility and due dates for 3 those recommendations.

4 That information does not appear in the 5 self-assessment team report. Could you go into some 6 background on where you feel your quality assurance program 7 is? And where you would'like to see it move in the future.

8 MR. FEIGENBAUM: Neal, do you want to talk about 9 the open items? We did a study -- before you go into this, 10 we did, as you know, a self-evaluation similar to what'we <;

11 did for the maintenance evaluation,' for the quality programs 12 area some time ago. And there were a number of short-term l 13 and long-term recommendations.  !

() 14 We have accomplished the short-term 15 recommendations, the things that we absolutely felt we l

16 needed to do to get our programs up to snuff. There were a 17 number of long-term enhancements, good things to do, and 18 there are still a few outstanding items left over from that, 19 including job rotation and a few others. ,

20 But I will let Neal Pillsbury, who has recently 21 had a reassessment done on our performance-based quality 22 program, and where we are moving in that direction. I will i 23 let him summarize where we stand on that.

24 MR. PILLSBURY: Yes, Neal Pillsbury, Director of 25 Quality Programs. As Ted has said, when we did the

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75 1 assessment in April of 1989, we identified a number of areas 2 that we felt we needed to take immediate action on. And in 3 essence, those immediate action areas and the identified 4 initiatives that were already underway are essentially 5 complete, or fully implemented, and continuing in ongoing 6 programs.

7 The other good idea suggestions continue to be b evaluated. Those are tracked on a matrix. We assess that 9 at least on a quarterly basis, and they are periodically 10 assessed in nuclear quality group or in production interface 11 meetings, which we tend to have them on -- or try to have 12 them on a monthly basis. I think we had-about 10 meetings 13 in 1990. So we keep track of it.

14 I think all of those, everything that has come out 15 of that self-assessment evaluation in the quality programs. l 16 area has been very beneficial to the organization. We are 17 proud of the advancements and success that we have 18 accomplished over the time between April of 1989 and today.

19 I think that the relationships between the quality l 20 organization and production organization, and-engineering 21 organizations, are significantly better. The communications 22 are better. And things such as the finding review board are 23 working well; the nuclear quality group production periodic 24 meetings are working well.

25 My relationships with the Station Manager, and Heritage Reporting Corporation (202) Gf!8-4888 i

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1 with Bruce, and our ability to resolve things without having 2 to go to Ted -- and there has only been one that I can think j 3 of, ever since Bruce has been on board, that we have 4 discussed it with Tod. But all of that relationship is much 5 better.  !

6 We would like-to be more pro-active. We certainly 7 have additional enhancements. And everybody here recognizes-8 that we have had a difficult time with allegations this 9 year, which have consumed much of the energies within the 10 quality organization that we would have more liked to have 11 put on pro-active r4nd enhancement-type initiatives.within 12 the organization.

13 But those initiatives are there. We know exactly

() 14 what we want to do. And hopefully, we will make botter 15 progress. It has been a challenge this year simply to carry 16 out the promised initiatives associated with the Power 17 Ascension Test Program. Not at all-to dilute'any of our 18 routine activities, and not let up at all on what we wanted-19 to accomplish, in terms of Power Ascension-Test Program (

20 self-assessment and nuclear quality group inspections and 21 surveillances and audits directly associated with the Power 22 Ascension Test Program. We did not let any of that slip. -

23 But we did have to put overtime in just to handle the

24 allegations load.

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i' 1 talking about that are still open? Approximately?  !

l 2 MR. PILLSBURY: It is down to a dozen or 15, 3 I think, on that order.

4 MR. WIGGINS: Out of how many? How many long-term 5 were there?

6 MR. PILLSBURY: There were -- I do not. l 7 MR. FEIGENBAUM: Fifty or 60?

8 MR. PILLSBURY: Yes, on the order of 60. There 9 were about 44 that were good ideas; 11 that were identified 10 initiatives that we asked the organization to support, and 11 all those have-been; and six immediate term.

12 So the six immediate, six or seven immediate, and 13 the 11 ongoing initiatives, are essentially done and being 14

() continued in ongoing programs today. And-then another 44 15 that have all been worked on, with the exception of a dozen-16 or 15.

17 MR. FEIGENBAUM: A couple other things, just to 18 give you an idea.. As I mentioned, job rotation out of the 19 quality program into other areas was_one of the 20 recommendations that was made. But with everything going 21 on, with power ascension and allegations from Congressional 22 staffers, it just was not possible to handle that well.

23 We could have moved people around, but it would not have i

24 been the kinds of assignments that we really wanted them to 25 experience.

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l 1 The other thing is facilities, it was a good iden 2 to look into putting all the quality people in one physical  ;

3 location. And we were not able to accomplish that this  ;

4 year. And it is something that we are continually ,

5 re-evaluating, as to whether that is the way we want to go. l 6 Is it better -- there is two trains of thought here. One l i 7 train is, put everybody that is quality together, so you get l

8 a critical mass, if you will, of thinking. And the other

  • 9 train of thought is, keep the people in quality together 10 with the groups that they are observing and overseeing.  !

11 So we are still discussing that. And we will be 12 looking at it again in the future. And we keep quarterly, 13 as Neal said, re-looking at a few of these open items that >

() 14 are left.

15 They were items to look at. They were not all 16 committed as absolutely we were going to do every one of  ;

17 these things. And we look at them, and we evaluate them..

18 If we think there is good ideas, we follow through on it.

19 MR. WIGGINS: For those that you agree are good 20 ideas, have they been scheduled out? Resource loaded? ,

21 Or any idea of how much it would take the organization to 22 implement?

23 MR. FEIGENBAUM: That is the majority of them.

24 The ones that are left are the ones that were really lower 25 priority, and still some difference of opinion as to whether O Heritage Reporting Corporation (202) 628-4888

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i 79 1 we want to go and do that. So we are still evaluating many 2 of those.

i 3 MR. MARTIN: Ted, what did you mean by keeping the 1 4 quality assurance people with the people they are observing? .

5 What did you mean by that?  ;

6 MR. FEIGENBAUM: Well, for instance, right now we 7 have quality control people located inside the protected 8 area with the plant personnel, in close proximity to the t 9 work that is going on, as opposed to the quality, 10 procurement quality people that are located in a different .

11 area, that go out to vendors and do audits. I 12 Quality assurance people, right now, are located l 13 with the engineering groups, in the toch support group, in

( ) 14 our operational support building. If we were going to take 15 the quality control people, and the quality assurance, and 16 the procurement quality people, and put them in one 17 facility, they would not be with any one particular, or

  • 18 close to, physically, any one particular group of people 19 that they work with day to day, closely. They would not be 20 with the purchasing people, they would not be with the 21 engineers, and they would not necessarily be with the 22 maintenance plant personnel.

2*o So I am from the school of thought, I actually 1

24 like the way it is, even though they are split up and it is 25 a little tough for the quality management people to keep Heritage' Reporting Corporation

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80 1 their fingers on various groups in different locations.

2 I like having the quality control people inside the plant,  ;

3 inside the protected area, near the work. I like having the 4 QA folks near the engineers. And that is what we are 5 kicking around right now, really, whether that is a good l 6 recommendation or not, t 7 MR. MARTIN: Okay, but there is an Achilles' heel -

8 with that, and I would kind of like to hear how you are  ;

9 dealing with it, objectivity and independence. How do you i

10 maintain that objectivity and independence if you keep them i 11 close? r 12 MR. FEIGENBAUM: Well,-when I said "close," I mean 13 they are in the same general area. They are not O 14 iae-ar- iao- ruer re c1o e to tae veerie eh e they have 15 to communicate with. They are independent in terms of their ,

16 reporting lines. Heal Pillsbury has all the quality i 17 programs people reporting through a quality assurance 18 manager to him.- The independent review team reports to him

  • 19 our employee concerns-anid allegations.

20 He reports directly to me. Those people that work I 21 for him do not work for Don Moody, and they do not work for i 22 Bruce Drawbridge. There is a lot of interface there, at all 23 levels, not only the working level, but at Bruce's level and 24 the middle management-level. But there is that 25 independence; but yet, I think physically it is good for Q

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I them to have their handJ on the pulse of what.is going on in 2 the plant, the activities that they are responsible for 3 checking and verifying.

4 If they were physically in a facility outside the 5 plant, I think that the value of-the quality control group 6 would diminish.

7 MR. MARTIN: We rotate our inspectors. Do you' i 8 rotate your quality assurance people?

I  :

9 MR. FEIGENBAUM: Yes, we do rotate them, 10 We rotate them between groups. The recommendation was made 11 to take the quality assurance people and put them in 12 engineering, take the qual!4y assurance people and put them 13 in maintenance. Actually, many of them came from

() 14 maintenance; they do not really want to go back.

15 And we are looking at that, and I think that is a 16 good idea. You have to. guard against the independence l 17 problem when you do that. But it.just.was not in the cards 18 for this year, with all the responses to the independent i 19 regulatory review team that we were working on, and the t 20 Power Ascension Program, and round-the-clock coverage.

21 We just could not coordinate a good job rotation program at 22 this point. But we will look at it again.

23 MR. PILLSBURYt Tim, we do do some extensive 24 rotation within the quality programs area, which achieves 25 some of the subjectivity, or objectivity, I think, that you -i Heritage Reporting Corporation- '

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1 are looking for. I can do that. That is within my 2 organization. i 3 We have not been able to formalize and set up the 4 rotation program between production and the nuclear quality 5 group. But that is one of those good ideas that we are l 6 working on, and attempting to figure out a way to do it, i

l 7 But within quality programs, for instance, we are 8 taking people from the nuclear quality group and applying l 9 them to the IRT self-assessment team assessment effort, and 10 vice-versa. From the ISEG group back and forth within the j 11 groups. And that helps to build the objectivity, and the 12 cross-discipline involvement. and so forth..

13 I had one additional thought, Noel,.in answer'to  !

() 14 your question about other pro-active things that we are 15 doing. We tend to measure ourselves a couple of different 16 ways. We use as barometers an individual from the Bartech ,

17 organization that I think you people are familiar with, to 18 come in and look at our programs, in-depth, in detail, 19 several times a year. As a matter of' fact, he was back here .

20 just recently. He helped us with our initial formulation of 21 thought and philosophy and concept on performance-based 22 assessment, and did some of.our initial training. And then 23 has come back and looked at that, as well as all of the 24 other facets of our operational quality assurance program in I 25 a disciplined, formal way.

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83 1 1 We also look at self-reports from all over the 2 nation, to soak up the good ideas, and evaluate ourselves 1 l

3 against those, as well as from our Joint Utility Management 4 Audit Association. We are a participant in the Juma 5 organization. We send various numbers of people from our l 1

6 organization to other organizations to do their annual l 7 management audits. And in turn, enjoy their participation l 8 at Seabrook, and their ideas, and so forth.

9 In fact, we have just had a Juma audit here within 10 the last month. f 11 MR. DRAWBRIDGE: I would like to just say a couple 12 words, that Neal alluded-to.- And I would also like to  !

13 mention, from my perspective, the interface meetingo that'we

() 14 have with the quality organization I found to be very  ;

15 beneficial. It is usually a free exchange of ideas, to say 16 the least. Some of'the meetings are' tough. QA, QC, they 17 call a spade a spade. We call a spade a spade on occasion, 18 too, as well. But I think the meetings are always '

i 19 refreshing. Because at the end of the meetings, we i 20 understand where people are coming from. And there is'a 21 mutual respect that is developed as a result of these 4 22 meetings. ,

23 There is also a mutual respect that is developed 24 when you have a QC organization in the plant, stationed in 25 the plant on a regular basis. It was not mentioned, but

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Neal could have mentioned that we have a QC supervisor that sits in on Don Moody's morning meetings. _And he hears the 1 3 same thing that we do; he sees some of the decisions that j 4 may be decided at those meetings, and the thought processes  !

i 5 as well. So there is a mutual respect, a team effort that .

6 occurs here, that does not compromise their independence, ,

l  ;

7 but it is a, I think it is a very healthy interface between 8 the two organizations that occurs on a daily basis. And 9 then when we havo our monthly meetings, I think that is 10 going through the organization, and I think that they are  ;

i 11 very beneficial, very beneficial in the long term.

12 I, myself, do not always like to be criticised 13 sometimes. But when I hear someone that=I respect-saying-() 14 something that makes sense to me, then I take heed of it. I 5

, 15 think that is true of anyone in an operations organization. i 16 Any other questions? Ron?

17 MR. NIMITZ: I just had a quick question on this 18 rad waste issue. Discussions with your staff up there, they 19 were not able to give me any clear information relative to

  • 20 storage locotions, capacities, and that sort of thing.

21 Where it is going to go, what your interim storage locatione 22 were going to be. Storage of rad waste around the facility 23 can cause fire protection problems, seismic loading, l 24 radiation exposure problems. And there does not seem to be 25 any long-term plan as to what you are going to do with this, ,

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relative to your capabilities to shift off stuff off-site.

You are backed up seven or eight weeks there with ,

3 material stored in your waste processing building, that you 4 are backed up trying to process. And I guess that we do not l t

5 see a long-term plan as to, we could come in and see 6 something that says where is this going to be, is this i 7 adequate or not adequate. It appears to be in the ,

i 8 formulation stage now. .

9 MR. DRAWBRIDGE: That is correct. We have, under 10 Dennis McClain, who also reports to me -- he does not report '

t 11 to Don Moody. He has an individual who is tasked with '

1 12 looking at that this fall, as to what we plan to do in the 13 interim short term; that is, the next four or five years.

( ) 14 And then also, you know, long-term interim, the next year or 15 so. And then-longer term, the next four or five years and 16 beyond. >

17 There is a couple of different options we are 18 looking at. But he is still in that process. And they have 19 not yet sat down with me and given myself and Don a full (

20 briefing on it yet, because they are still looking at the i 21 different options.  ;

20 MR. NIMITZ: Currently, it is'a good waste 23 rsduction initiative using the ventilizer systems.

24 They have no ALARA design. And as the source term 25 increases, you are going to cause exposure control problems, 3

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2 But overall, we do not see -- how can I say -- a  !

l 3 complete rad waste program, in terms of what you are going  ;

l 4 to do with that stuff.

5 MR. DRAWBRIDGE: That is right, Ron, and that is 6 because it is being developed. They are looking at it now.

7 And it is not internal, the station that is being done by my  ;

8 production group, production support group.

9 MR. NIMITZ: Do you have some sort of goal as to  ;

10 when this plan will be developed?

11 MR. DRAWBRIDGE: Yes, it should be developed by 12 the end of this year.

13 MR. JOHNSON: Okay, well,-that certainly will.be

() 14 an area we will be inspecting and then monitoring.

15 We understand why you did not have.a plan, I guess, initial -

16 operation. But I think, just by the questions, we are 17 interested in it, and interested'in where you are going.

18 But also we will'be conducting routine inspections of that  :

19 area. j 20- Anybody have any other questions?

21 MR. MARTIN: I have a couple here.' My 22 understanding is that you now need to operate with three 23 condensate pumps continuously.

24 MR. DRAWBRIDGE: That is correct.

25 MR. MARTIN: What is the ramifications of that, a Heritage Reporting Corporation O (202) 628-4888-l l

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1 and are there any plans to resolve that. issue?

2 MR. DRAWBRIDGE: I alluded to it briefly in my 3 presentation. On occasion, during power ascension, and on 4 occasion afterwards, we have seen some perturbations on the 5 secondary side. And because of that, the suction of our 6 feed water pumps will tend to oscillate. And if it diverges  !

i 7 enough, you could get a trip on low suction on the feed j 8 water pump.

l 9 Because of that, we have the third condensate pump  :

10 on. We have been able to get up to, I think 98 percent?

11 MR. MOODY: Ninety-nine plus.

12 MR. DRAWBRIDGE: Ninety-nine, well, okay, I will 13 call itH98 percent power on the two condensate pumps.

() 14 However, when an oscillation occurs, the operators 15 justifiably do not like to see those swings. And so they 16 want to keep that third pump on.  !

17 We have a task team that is assembled that is 18 looking at the entire feed water string. There is one thing 19 that came out of it already, and that is a configuration of 20 a pipe on some MSR drains. We think if we reconfigure, it 21 will help on the situation, because that, in turn, feeds 22 down to our heater drain tank, and causes some perturbations 23 in a level, and initiates some of these oscillations that i 24 occur.

1 25 So what we have the task team doing is looking at j

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88 1 that. They are also looking at feed water levels to make 2 sure that those are exactly where they should be. And  ;

3 looking through the whole string, to make sure that we can ,

4 nail down these oscillations. )

5 And once we can get the oscillation problem 6 corrected, and we think we should be able to take off that 7 third condensate pump. But a concern is for your feed water 8 pump suction during the oscillation.

9 MR. MOODY: We have not counted all the way down.

10 We get an automatic start on the condensate pump of 330  :

11 pounds of pressure, suction pressure. Food pump people, l 12 that trip could be as low as'190.- We have not challenged' 13 that. We have left that, and not looked - <we have not  !

am i

( ) 14 challenged that set point. t 15 MR. MARTIN: Is it a trip of the feed pump?- Or is l 16 it a start of additional condensate pump?

17 MR. MOODY: We have an automatic condensate pumps 18 status of 335, 330 pound suction on the feed pump. The feed 19 pump trip is set right now at about 220 pounds. y 20 MR. DRAWBRIDGE: And that is not instantaneous 21 trip, though, Don. There is a time delay.

22 MR. MOODY: No, there is a time delay of about 23 20 seconds on that trip. ,

l 24 MR. KLINE: That will set you back to 55 percent 25 power.

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1 MR. MOODY: And that will run you back. We did, 2 as I say, got up to -- well, you said 98 -- 99 plus before 3 we got that automatic etcp on that third pump. After we i 4 come up the last time.  !

5 MR. MARTIN: You know that we are going to be 6 doing a maintenance team inspection in November. We have a 7 number of initiatives and we are engaged in to enhance the 8 maintenance program. Are they going to be in effect, what 9 we are going to look at in November? Or will it be a 10 completed program? Or will there be a lot of things that i 11 are still in transition? ,

12 MR. DRAWBRIDGE: We will, in the November time 13 frame, we will still have things in transition. I believe,

() 14 unless I am mistaken, I thought the maintenance audit was 15 going to be changed to the -- I think it was a March time ,

16 frame. Is that true?

17 MR. DUDLEY: I have not been able to track it, 18 track the source of that in the region.

19 MR. DRAWBRIDGEt Oh.

20 MR. DUDLEY: There is no knowledge of'that in the 21 region.

22 MR. JOHNSON: Bill, anybody know?

23 MR. MARTIN: We will have to get back to you on 24 that.

25 MR. FEIGENBAUMt It is my understanding that it is i

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(~" 1 November, 2 MR. DRAWBRIDGE: Okay, that is_whct we originally 3 heard. And then it was our understanding that_there was'a l

L 4 potential that that was going _to be. shifted out to the 5 March, I think it was the March-time frame of next year.

6 But to answer your. question --

7 MR. FEIGENBAUM: It will be in the middle of'--

8 MR. DRAWBRIDGE: -- in the November time frame, we 9 would be going through this transitional process.

r 10 MR.-MARTIN: Okay.. You pazegd'your power 11 uscension program. What kind of assessment. program do you ,

12 have now of operations? And does'it involve back shift 13 activities?

() 14 MR. DRAWBRIDGE: You mean. independent assessment?

15 Or ongoing assessments?

16 MR. MARTIN:- Independent assessmentLof what is- I 17 going on in '.he plant. ,

?S MR. DRAWBRIDGE: Neal, you want to get that?

'9.

, MR..PILLSBURY: Sure.. We have. routinely utilized- r 20 nuclear quality group back' shift assessments. We have also 21 routinely used the independent safety engineering group I 22 on-site evaluation activities on back shifts. I'cannot i 1

'23 quote percentages to you, but that'is_a routine part of both [

24 the operational quality assurance program and the 25 independent safety' engineering group responsibilities.

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1 1 MR.= MARTIN: How frequently was that done?

2 MR..PILLSBURY: I cannot quote hours. Hours or 3 frequency. I would have to go back.and look that up. I 4 would assume on the order of two .or three surveillances on a-(

5 quarterly basis. So somewhere around a dozen times a year, q I

6 MR. MARTIN: What about senior managers?

i 7 Operations managers, in particular. They come in~on their.

t 8 own back shifts, and observe operations? '

4 9 MR.. MOODY: They all come in, including myself. f 10 But over the test period, there was a lot of activities'  ;

11 goins; on. So I am not sureiyou would see a representative .

12 of what the-day-to-day operation would-be, because it"was--

13 not on the additional people from operations on,--test-

, ( ) 14 personnel, maintenance -- supplemental' forces.- So-I am not 3 15 sure you would see in that environment what you might be' 16 looking for in an operating plant, on a-day-to-day basis, on 4-17 a back shift.  !

L 18 We do plan'to have people come in on the back l

19 shifts, back shift meaning both.the. swing and the. morning 1 20 shift. We have that now, that some people come in. It has 21 just not been part of a plan, orientated, closely 22 structured,-that so many times you.will come.in; orLso many .

23 times you-will come in, and so forth. We have done that cnr L

24 a scheduled basis.

25 .t l MR. MARTIN:- So.it is not an articulated,;then,. /t i

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92 1 goal-of management that senior managers,-.with certain 2 frequency, will get in the plant on back shift to observe 3 the operators, particularly in the control room? l 4 MR. MOODY: No . - Thatlis not stated-in the policy, i

5 as such.

.l 6 MR. MARTIN: I bring it up, because we=just 7 recently experienced a licensee:which has a fairly good 8 record. A resident inspector walked in and found both the 9 RO and SRO inattentive at the controls. And no licensee can-10 tolerate that. And one of the things that we will be-11 following up on is how this: condition developed. _ It

-12 appears, at least on the back shifts, in' discussion with the l

13 operators, they believe a different' standard exists than the j 14 day shift. '

_(}

15 MR. FEIGENBAUM:- We will take that back and look

', at it, i 1

17 MR. MARTIN: .How long does it take you to get a i

18 new rad con staff member up and running, so that he can be i 19 an effective part of your staff?

20 MR. MOODY: A technician?-

21 MR. MARTIN: Rad con.  !

22 MR. MOODY: Again, it is going to depend on the l 23 level of experience of the individual. We can hire in-at 24 the senior level. But if we have some contractors, let's 25 say building up for the refueling or coming.out of the i

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l 93 1 refueling, we feel that we do need to supplement our staff,-

2 we can roll a contractor into any wide position, in a very 3 short period of time. And bring that individual'up to 1

4 speed.  ;

5 Ed, we can hire a senior technician, assuming they-6 are familiar with our own internal-programs.

7 MR. MARTIN: My understanding'right now, you.have' 8 got a rad con staff on the order of 20 permanent people.

9 Is that a fair number? f 10 MR. MOODY: Fair number.

11 MR.' MARTIN: And that you are running right now, 12 the source term you got overtime rate--of'about-15 to 20-13 percent for those-people. As the7 source term continues"to1

( ) 14 grow, are you going to have enough~leadLtime to maintain 15 that. number of openings?

16 MR. MOODY: If you look at the.15 to~20 percent,.

17 that includes a number /of hours-rolled.in there.for'the <

18 surveys that were made coming: up to the various power 19 levels. I believe that-is rolled in there.  ;

20 MR. MARTIN:- They were one-of-a-kind typer that is 21 what you are --'  !

22 MR.' MOODY: Yes. I do not expect that number to ,

23 be anywhere near that.--

24 MR. NIMITZ: Well, this is-based-on information I l 25 gathere relative to the month that you: were. at '100 percent: '

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-94 1 _ power. So that would be essentially --

.O 2 MR. MOODY: August? l 3 MR. NIMITZ: I am sorry, that would be reflective 4 of routine conditions.- So it raises some questions in terms.

5 of personnel coming in on weekends to perform-routine  !

6 surveillances', and,small,-minor source that you have now,

)

7 the activities that -staff could perform very easily, triple 8 or quadruple based on the source term.

9 MR. MOODY: That was also the time frame, we made 10 a number of, I believe, containment entities for various 11 surveys, or work'-- i 12 MR. NIMITZ: Well,. I am'just talking routine work, 13 not non-routine.

( ) 14 MR. MOODY: I do not expect it to be anywhere near 15 that level that you quoted.

16 MR. NERSES: When you-say that, when would I 17 expect to see it? The month of September? November? When 18 would I expect to see it?

19 MR. MOODY:

~

I guess the best estimate to take a  ;{

i 20 look at what it looks like, I would take the last part of --  !

21 assuming that we have.got no major evolutions planned,-no l

22 outages and so forth planned. I think if we take a look at 23 the last quarter of 1990, we get a pretty good feel of what 24 the routine would be.

25 MR. MARTIN: .Well,.we will do that, i Heritage Reporting Corporation (202)- 628-4888 1

95 1 - MR. - JOHNSON: Well, I guess that is something good 2 to take a look at your data, too. But I guess there is lots 1

3 of other probably similar plants that have gone through this 4 exercise, that are fairly new, in the same condition, and-5 have gone through this, Maybe even a little bit older, so:

6 you can see what their experiences were, ,It is probably:  !

7 worthwhile to take a look at that,.too.

8 MR. MOODY: Oh, I believe that we do all-that.

9 MR. JOHN 3ON: Okay. Anybody else have any 10 questions? .I 11 MR. DRYSDALE: Could I get b'ack to your. issue l 1

12 of - prior to the' achievement of, commercial' operation,,you i

13 had a goal of having your -- referred:to as the plant-i 14 labelling program, I think is what you referred.to, 15 completed by the time you achieved commercial operation._

16 I understand what you are saying about this 17 configuration control program, it still being in  ;

18 development. Have-you, in fact, completed formally this 19 plant labelling program? Or has-3t-kind of been absorbed- i 20 into the new configuration controlcprogram?

21 As you know, I think these instrument'rega, we 22 have discovered some labelling problems several4 months ago.- j 23 And I am -)uct interested, - to what extent have you actually 24 completed that program?

25 MR. MOODY: We have not completed the program as '

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96 1 such.- We have taken a look to a task force, how the 2 configuration control was laced through all of the -- and so 3 forth. As part of that,-labelling,na useful~ label amounts-4 to a much larger program. We do not use non-vent names on 5 labelling required. We are looking at going-back,~

6 reassessing that. Looking at bigger tags.

7 So the labelling program, as a result of our own 8 internal task force, has expanded a-good deal beyond what 9 -the initial concept was.

10 MR. DRYSDALE: Well, I know you have done a number. [

t 11 of log -- configuration controls verifications. -What is 12 your feeling now about problems that' might- be out -there-13 still with-respect to components that are not labelled?'

A 14 MR. MOODY: -Well, as I mentioned, I do not feel t

s,j .

15 there is a lingering problem out there.- Because if we find 16 something that is not labelled,sif you will, be it an-17 instrument valve or something like-that.- If the valve was i

18 going to be moved, then we were contract -- it would be 19 contract control and so forth, identified on1a 4.1, what we= -s 20 call a 4.1 form, which is the same form we used for, as I l 21 say, slide lengths --

22 -Operate that valve, and put it'back in its i

, 23 original position. And then take a look to see if that i

24 valve was, in fact, should be or should not be identified on

- 25 some document or procedures they were-using. -That is the s

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l 1 vehicle that would be used today. If you found that-2 situation.

l l 3 MR. OLIVEIRA: Back in November, November last l l

4 year, our examiners found the problem of EOPs not' l 5 specifically addressing malfunction.- In other words, you go .

6 through an action item and something else;comes up. And

[

7 during the power ascension, when: there is a lot of taings .

8 like having to bring in condensate pumps,Ehaving to do:

9 something else, and other things.

10 And I was just wondering, how is, dealing with  ;

11 these problems when the issue right here,.the initial issue 12 is that the EOP itself is not addressing 3thermalfunction.' i 13 - In doing these tests there were~ malfunctions, and they'had say let's go to something else,.let's do something else.

{ } 14 15 But I have a difficult' time trying'toLfullySunderstand if r

you do have a problem, how will'you'handleithe EOPs?

16 When 17 the EOPs themselves are-not dealing;with these. problems.

18 MR. MOODY:' Let.me.try tofunderstand the question.

19 MR. DRAWBRIDGE: I did not hear (the entire

-20 question.

21 MR. OLIVEIRA:' I said back in November of last 22 year, one of our examiners said that-the EOP'being i 23 implemented in this event'did not specifically address the 24 actions that were taken to correct a malfunction. What 25 happened here, a valve did not' reseat.during a test. - 'AndTI

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98 1 was likenitag,it to observing.some of the-ascension testing, 2 if things did not function -- we have to get the.consig pump 1

3 on-line, number three consig pump back on-line, because we j 4 were having -- from the flow.

5 The heater drain is not opening and oscillating- i 6 properly. And I was wondering, in view of this, I was  :

7 wondering how does-that relate with the EOPs of people i

8 involved -- {

9 MR. M70DY: EOPs-basically take you through a

.i 10 series of progressive steps to get to either,_in a 11' functional recovery procedure, out~of the-emergency .l 12 operating procedures. Normally-in:the EOP, it works you 4 13 back into a normal operating procedure. .  !

1

( ) -14 For instance, you have low suction on'your feed 15 pump. And an operating procedure would.get you back into  !

16 starting an additional condensate pump by dropping'off one 17 or the other. But we have looked at~the EOP, -- looked at 18 the EOP and the procedures that they-relate'to are mentioned 19 in the text of those to correlate those.together, to.make 20 sure that they, in fact, flow.

21 But the EOP will drive you either into-a condition l 22 to stay within that condition in thel normal operating .

23 shutdown procedures, just using the word.EOP itself.

24 We have looked at all those connections. I 25 MR. JOHNSON: Thank you.

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99 MR. MARTIN:

'l 1 If I might-add something. One of the  ;

(' l 2- primary intentions-we had during the power ascension program j ,

3 is to verify that the EOPs worked appropriately.- And when 4 we performed a test like loss of power, test of the unit, l

5 check of 100 percent power test, we intentionally ~use the--  !

6 EOPs as much as practical to make sure that they were

]

7 usable. And in all of those instances where we did refer' 8 out to an EOP, we had perfect success in using ti.ose 9 procedures.

10 I am not sure exactly the situations you are I, 11 referring to on the condensate pumps. 'There is no N 12 relationship that we experienced during~a power ascension' 13 that relates the oscillations back to an-EOP. But we did-1 l ("h 14 validate the EOPs during power ascension, and'found-no

[ %/

15 problems.

16 MR. DRAWBRIDGE: There is also an EOP audit-going 17 on this week. I do not know'if you are' aware of that.

18 MR. JOHNSON: Right, that is right.. I I .

19' MR. DRAWBRIDGE: - In fact, today they were going to 20 be in the simulator. We are going to walk --

. 21 MR. JOHNSON: Yes, I think we-have an ongoing team )

I 22 inspection at the site'now that will beflooking into that-

- 23 again. So we will'get another fresh look.at that within the 1

24 next week or two.

25 MR. OLIVEIRA: I just remember reading ~this'--

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'100-1 heater-drain 1 system to make sure -- very unique. situation.

O 2, Try to correlate that to an EOP. I did not see and I wasn't 3 going to say stop --

4 MR. MARTIN: There is no relationship there.

5 MR. JOHNSON: Okay. Any other. questions? Okay, 6 well,fI appreciate you spending-the_ time to come in here.

7 And I thank everybody for their questions.

8 What we intend to do-is document the transcript of l

~

i 9 this meeting, and provide that transcript to you and to'the  !

10 public. And we intend to give.you_ feedback on your ]

'i 11 -self-assessment, report..in a routine inspection report, ]

12 similar to the-way we dealt with-the'50 percent-meaning. l 13 Again, thank you very.much. . We appreciate your l time. And the-meeting is concluded.

( } 14 ,

15 (Whereupon, at 3:16 p.m.,-the meeting was 16 concluded.)

17 18 '

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1 REPORTER'S CERTIFICATE:

2 .

l 3 DOCKET NO.:

4 CASE TITLE:

POWER ASCENSION TEST _ PROGRA.% FINAL PHASE II-5 HEARING DATE: September-18, 1990-6 LOCATION: King of Prussia, ' Pennsylw.nla

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' l 8

I-hereby certify that the proceedings'and= evidence'are.

9 contained fully and accurately on the tapes.and: notes-10 reported by me at the hearing;in the above! case'before the 11 United States Nuclear Regulatory Comission, ' '

12 i

13 . Dates 14  ?

i 15 7I ,

W '

16 Official Reporter' .

17 Heritage ReportingLCorporation-18 1220 LLStreet,rN.W' -

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_W ashington,.D.C. 20005 1

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