IA-86-862, Rev 1 to Maint & Surveillance Program Plan

Rev 1 to Maint & Surveillance Program Plan

ML20207B333
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Issue date:	10/16/1986
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ML20207A713	List: IA-86-862, Rev 1 to Maint & Surveillance Program Plan ML20207A709 ML20207A715 ML20207B329 ML20207B333 ML20207G140
References
FOIA-86-862 PROC-861016, NUDOCS 8611130061
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MAINTENANCE AND SURVEILLANCE PROGRAM PLAN U.S. NUCLEAR REGULATORY COMMISSION APRIL 12, 1985 0CTOBER 16, 1986 (REV. 1)

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TABLE OF CONTENTS Page

1.0 INTRODUCTION

...................................................... I 1.1 PURP0SE...................................................... I 1

1.2 BACKGROUND

3

2.0 DESCRIPTION

OF THE PR0BLEM........................................

3 2.1 DEFINITION AND SC0PE.........................................

3 2.2 PROBLEMS AND OBJECTIVES......................................

4 2.3 REGULATORY ISSUE.............................................

4 2.4 TECHNICAL ISSUES.............................................

8 3.0 PLAN FOR PROBLEM RES0LUTION.......................................

3.1 MAINTENANCE AND SURVEILLANCE PROGRAM STRATEGY................ 8 3.2 MAINTENANCE AND SURVEILLANCE PROJECTS (PHASE I)............. 11 3.3 MAINTENANCE AND SURVEILLANCE PROJECTS (PHASE 11)............ 15 3.4 RELATED PR0JECTS............................................ 22 3.5 INTERACTIONS WITH OUTSIDE ORGANIZATIONS..................... 34 1

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1.0 INTRODUCTION

1.1 PURPOSE The purpose of the Maintenance and Surveillance Program Plan (MSPP) is to provide direction for the NRC's efforts to assure effective nuclear power plant maintenance and surveillance and to do so in a manner that is consistent with and responsive to the Commission's 1984 Policy and Planning Guidance (NUREG-0885, Issue 3). (

The Program Plan describes the problems and issues to be addressed and proposes development of alternative NRC approaches to regulating nuclear utility maintenance activities consistent with the Policy and Planning Guidance. The plan addresses those plant functions required to carry out a systematic maintenance program.

It includes, therefore, corrective and preventive maintenance and repair; surveillance and testing; operations / maintenance interface; maintenance management; procedures; and technical documentation.

1.2 BACKGROUND

The NRC's current regulatory approach to nuclear power plant maintenance is embodied in requirements for (1) quality assurance (QA) during design, construction, and operation for structures, systems and components to an extent consistent with importance to safety (10 CFR 50, Appendix B), and (2) surveillance requirements to assure that the necessary quality of systems and components is maintained (10 CFR 50.36). Despite these requirements, the NRC's rules and regulations presently provide no clear programatic treatment of maintenance.

Many challenges to safety systems originate from systems and components which are not classified as safety-related. The principal contribution of maintenance and non-safety related

! activities to safety system performance will be addressed as part of the overall approach to maintenance improvement.

Faulty maintenance practices are a principal contributing factor to operating abnormalities. Preliminary estimates by the staff indicate that aside from design deficiencies, more than 35% of the nuclear power plant abnormal occurrences reported to Congress since 1975 may be directly attributed to maintenance factors, with the trend increasing as more plants become operational.

Reviews of operating experience by the staff show a high frequency

of degraded system performance due to bc2h the lack of maintenance l (especially preventive maintenance) and improperly performed maintenance, including human error during repair and surveillance testing.

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NUREG-1192, completed as part of Phase I, concluded that although operations personnel were most often responsible for wrong unit or wrong train errors, the errors often occurred during preparation for maintenance (including surveillance and testing). The types of maintenance errors described by Licensee Event Reports (LERs) and the Nuclear Plant Reliability Data 3ystem (NPRDS) include such human maintenance errors as: failure to follow procedures; installing electrical connectors incorrectly; mounting equipment (e.g., check valves) backwards or out of alignment; using the wrorg parts in equipment repair; removing from service and working on them wrong system or component; misaligning valves after maintenance; and failing to remove lockwire from critical switches after service.

The impact of maintenance on plant safety was illustrated by an engineering evaluation of a stuck open isolation check valve on the residual heat removal system at an operating boiling water reactor (BWR). Human error during maintenance resulted in a safety problem when the maintenance error was not discovered during post-maintenance testing nor during routine surveillance of control room position indication for the component. The safety significance of the undetected error increased the probability of an interfacing LOCA for4the plant. The probability of the LOCA was estimated to be 2x10~ during this period of four months while undetectedascomparedtoanormalestimateof10yheerrorwas per reactor year. This is considered to be a substantial reduction in safety margin caused by a maintenance error.

For two to three years prior to 1985, the NRC has initiated several studies, the results of which showed that there were problems in l nuclear power plant maintenance activities. For the most part, studies have been conducted or sponsored by various NRC offices (e.g., Research; Analysis and Evaluation of Operational Data; Nuclear Reactor Regulation) with little or no coordination and no integrating programmatic framework for maintenance issues. This had resulted in a fragmented effort that did not address all the relevant issues and may have been duplicative in some respects.

This Maintenance and Surveillance Program Plan (MSPP) is intended to integrate and plan the staff's maintenance activities, and responds to the Commission Policy and Planning Guidance (NUREG-0885, Issue 4) goal to encourage a high level of quality in reactor design, construction, operations, and maintenance and to understand the causal factors leading to problems. As part of Phase I of the MSPP, coordination of the various staff initiatives regarding nuclear power plant maintenance was accomplished (memorandum dated April 29, 1986, from Denton, Taylor, Minogue, Davis to Stello).

2.0 DESCRIPTION

OF THE PROBLEM 2.1 DEFINITION AND SCOPE The scope of the Program Plan includes the entire maintenance process. Maintenance as a process is defined herein as a function with the o.ijective of preserving the reliability and safety of plant struc+.ures, systems and components which provide assurance that the plant can be operated without undue risk to the health and safety of the public and/or restoring that reliability when it is degraded. As such, the scope encompasses those components which may affect the performance of safety systems.

For the purposes of this plan, maintenance and surveillance include (a) diagnostic or periodic testing, calibration and inspection to determine the condition of structures, systems and components, (b) preventive or corrective actions such as repair, replacement, lubrication, adjustments, or overhaul; and (c) proper removal of equipment from service, restoration to service, and post maintenance testing. Maintenance is performed during all modes of plant operation by plant staff, vendors, or contractors.

It is not the intent of this Maintenance and Surveillance Program Plan to address the technical problem of how to maintain a particular component (e.g., a pump, valve, pipe or steam generator) but rather to consider the programmatic aspects of maintenance.

The objective is to identify the factors that contribute to maintenance effectiveness (e.g., procedures, training, and management) and how they may best be integrated into a functional maintenance program.

2.2 PROBLEMS AND OBJECTIVES These problems or combination of problems exist at some plants.

Other plants appear to have effective, well run maintenance programs. The maintenance safety problems and the objectives being addressed by the plan. consist of the following:

1. There is indication that needed maintenance is not being accomplished or is not performed effectively. The objective is to determine the effectiveness of current nuclear power plant maintenence programs, to detect the causes and effects.of equipment performance degradation, and to identify corrective action to minimize equipment failures and unavailability.

2. Many failures result from improper performance of maintenance.

The objective is to reduce failures from improper maintenance by identifying the fundamental causes of human maintenance errors, by identifying practices which reduce the error rate and which increase the probability of error detection prior to

t system demand, and to assess the effectiveness of licensee strategies for improved maintenance performance.

3. The interface between maintenance and operations is presently inadequate. The objective is to determine the causes of poor coordination among activities, to assure proper integration of maintenance, operations and other organizational interfaces for maintenance activities.

4. The number of maintenance-related challenges to safety systems is excessive. The objective is to determine the causes of the high rate of challenges and improve the effectiveness of nuclear power plant maintenance programs in assuring operability of safety systems.

5. A major portion of occupational radiation exposure and many radiological hazards occur to personnel performing maintenance activities (NUREG-0713). Improved planning and control of maintenance activities may significantly reduce occupational 4 exposure. The objective is to assure that by performing preventive and corrective maintenance in a planned and optimized manner, the unnecessary and unanticipated radiological exposure of maintenance personnel will be reduced.

Phase I activities have confirmed that these problems are still evident throughout the industry.

2.3 REGULATORY ISSUE The regulatory issue to be addressed is deciding on an NRC approach to assure effective maintenance performance. Several alternative approaches are being considered. They are:

NRC monitoring and endorsement of industry activities and initiatives to improve maintenance effectiveness (e.g.,

INP0 or national standards development activities);

NRC guidance in the form of Policy Statements, Regulatory Guides, or regulations to ensure maintenance effectiveness in the U.S. nuclear power industry; or Some combination of the above alternatives.

2.4 TECHNICAL ISSUES Significant developments were made in the resolution of several technical issues, especially in areas concerning data and methods for evaluating industry maintenance. These technical issues are:

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1. Human Error in the Performance of Maintenance Operators and maintenance personnel (in about equal proportion) account for about 2/3 of all human error incidents resulting in LERs. Many maintenance errors have had serious safety consequences. Most of these errors result from poor human factors design of plant equipment, inadequate procedures, and/or insufficient personnel qualifications and training.

Although Probabilistic Risk Assessment (PRA) studies have treated human error, it is difficult to quantify the impact of human error in maintenance on risk, and to assess the effect of proposed changes to reduce the incidence of human error in the performance of maintenance. Consequently, there are no currently acceptable criteria for determining the optimum methods for reducing human errors occurring during maintenance activities.

2. Indicators of Maintenance Performance Measures of maintenance performance include Licensee Event Report data, the frequency of reactor scrams or safety system challenges, equipment performance data, SALP ratings, violations and enforcement actions, reportable human errors in maintenance, and work force man-rem exposure. The term maintenance performance measure was used in Phase I to indicate that the data collected had not yet been validated and that these data were to be used as precursors for performance indicators. These measures will be used to evaluate maintenance effectiveness of individual utilities (needed to identify plants with poor maintenance histories) and to compare maintenance performance across the nuclear utility industry as a whole (needed for feedback on effectiveness of regulatory and industry initiatives). Also, if NRC elects to rely on INP0 programs to upgrade maintenance performance in the industry, this measurement methodology will be used to determine maintenance program improvement or lack of improvement. Output from this effort is being integrated into the NRC's overall performance indicators Task Force Program, as reported in SECY-86-144, "Perfonnance Indicators."

3. The Role of Preventive Maintenance in Counteracting Aging and l

Service Wear Effects The degradation of operational characteristics and reliability of plant systems with age and service wear needs to be documented and expressed in quantitative terms or by performance trending. The appropriate resolution of the aging issue depends on answers to some basic questions: (a) what aging effects are likely to impair plant safety; (b) what methods of testing, calibration and inspection will be

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effective in detecting system degradation due to aging prior to l the loss of the system function; and (c) what is the ,

appropriate mechanism for implementing remedial actions identified from testing, surveillance, and inspection? It is-likely that a partial resolution of the aging issue will 1- determine the appropriate role of preventive and corrective maintenance programs in detecting and correcting aging and service wear effects in selected electrical and mechanical components.

Significant technical questions must be resolved to ensure the effectiveness of a preventive maintenance program in enhancing safety. These questions include: (a) what are the components I to be maintained; (b) what type of maintenance is to be performed (e.g... replace components, overhaul, etc.); and (c) what is the appropriate schedule for each maintenance action?

4. Management and Organization Impacts On Maintenance Effectiveness

} Management practice and organizational structure have an

important bearing on performance of an organization. Proper l management of maintenance has been cited as an essential

, element of an effective maintenance program (NUREG-1000). The

NRC currently does not pursue extensive identification and analysis of management-related maintenance problems. There also appears to be insufficient means to document and disseminate lessons learned and to objectively compare 4 maintenance performance in the industry. Management connitments to improved maintenance and dissemination of

effective maintenance practices and industry experience are needed.

5. Maintenance Program Criteria and Standards Many effective maintenance practices have been identified from programs which have resulted in improved reliability and

performance in other industries such as the FAA and the I

military. The nuclear industry has begun to document some effective maintenance practices, e.g., EPRI's maintainability guidelines and INP0's maintenance guidelines (INP0 85-038).

i There is a need to identify acceptable maintenance practices for application to plants with poor maintenance histories and l

for guiding routine NRC inspections. Standards and criteria for maintenance practices are needed for generic application and for development of improved inspection methods.

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The national standards organizations, such as IEEE, ASME, ANS, or ANSI, presently do not have comprehensive standards on maintenance for industry use in developing effective maintenance programs. Industry self-regulation through such standards could create a common reference for maintenance practices. With such standards, NRC regulatory activities could focus on developing approaches such as review guidance, revised inspection modules, or statements of good practices as general guidance documents.

6. The Maintenance and Operations Interface Safety-related systems are sometimes taken out of service or bypassed during surveillance testing and maintenance. Errors in surveillance testing and maintenance have resulted in the wrong equipment being taken out of service or in continued unavailability of equipment following maintenance or testing due to a failure to properly return equipment to service, including improper post maintenance testing.

The proper integration of maintenance and operations is needed to verify correct performance of activities and reduce human errors. The provision of accurate information for monitoring the status and availability of systems and equipment before, during, and following maintenance may reduce operational as well as maintenance errors. Interactions among operations, maintenance, and radiation protection personnel in planning and preparing for maintenance work are important in ensuring that exposures to workers are as low as reasonably achievable (ALARA). Means of identifying and optimizing important areas of interaction between maintenance and operations are needed.

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l 3.0 PLAN FOR PROBLEM RESOLUTION 3.1 MAINTENANCE AND SURVEILLANCE PROGRAM STRATEGY Resolution of the technical and regulatory issues will be accomplished by a number of projects. In many instances, fundamental work needs to be completed which addresses portions of several issues. For example, a reliable measure of maintenance performance effectiveness is required for the resolution of issues related to management and organization impacts, maintenance criteria and standards, and the maintenance and operations interface.

The Maintenance and Surveillance Program (MSP) is being conducted in phases to provide for EDO interim evaluation of results and recommendations prior to initiation of additional activities. The phased approach will also provide the industry an opportunity to take an active role in identifying and proposing solutions to maintenance problems.

The initial program consists of two phases, as shown in Figure 3.1:

Phase I Survey and Evaluation .

Phase II Safety Role of Maintenance and Evaluation of Industry Initiatives Phase I activities were completed in early 1986 and a summary report was published in June 1986 as NUREG-1212 " Status of Maintenance in the U.S. Nuclear Power Industry, 1985."

The objectives and expected products to aid the ED0 evaluation at each phase of the program are as follows:

Phase I: Survey and Evaluation of Maintenance Effectiveness Objective: to survey current maintenance practices in the nuclear industry and to evaluate their effectiveness.

Phase I activities resulted in the publication of the following documents which relate to the specific expected products:

NUREG-1212, Status of Maintenance in the U.S. Nuclear Power Industry, 1985 NUREG/CR-3883, Analysis of Japanese-U.S. Nuclear Power Plant Maintenance NUREG/CR-4600, Human Factors Study Conducted in Conjunction with a Mini-Round Robin Assessment of Ultrasonic Technician Performance

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h0 REG /CR-4611, Trends and Patterns in Maintenance Performance in i the U.S. Nuclear Power Industry - 1980-1985 NUREG-1192, An Investigation of the Contributors to Wrong Unit or Wrong Train Events Products:

Description of current industry practices in maintenance and surveillance and methods for NRC use in assessment of plant maintenance effectiveness (NUREG-1212)

Preliminary objective indicators of maintenance performance effectiveness (NUREG/CR-4611)

Survey and comparison of Japanese and U.S. nuclear power plant maintenance (NUREG/CR-3883)

Staff assessment of industry maintenance program effectiveness (NUREG-1212)

Description of in-service inspection methods and human error potential (NUREG/CR-4600)

Job performance requirements and maintenance personnel qualifications (deleted from MSP)

Identification of factors contributing to wrong unit / wrong train human errors (NUREG-1192)

Participation in industry standards committees to initiate maintenance standards development activities

• Recommendations for subsequent maintenance program activities (NUREG-1212)

Phase II: Safety Role of Maintenance and Evaluation of Industry Initiatives l Objective: to define the role of maintenance in safety, evaluate the effectiveness of industry initiatives in improving nuclear power plant maintenance, and develop reconinendations for good practices in conjunction with industry improvement initiatives.

Phase II proposed projects are discussed in Section 3.3.

Coordination with other NRC offices will be necessary to utilize results of planned and ongoing activities related to maintenance and its impact on safety.

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3.2 MAINTENANCE AND SURVEILLANCE PROJECTS (PHASE I)

The projects described below are intended to provide the technical basis for developing an NRC position on maintenance, to provide measurement techniques for use in evaluating maintenance programs of licensees and license applicants, and to provide a basis for licensing decisions relevant to assuring adequacy of maintenance.

The following is a description of the projects which comprised efforts undertaken in Phase I.

3.2.1 Survey of Current Maintenance Practices The objective of this project was to assimilate data for assessing the present status of maintenance in the nuclear industry and to develop a method to describe the performance of the maintenance programs at nuclear power plants.

Eight sites were surveyed onsite to determine the maintenance program status and effectiveness. The reviews (1) provided baseline data as reference for the assessment of future developments due i.. implementation of new or revised maintenance practices, standards, etc., and (2) identified areas where improvements in maintenance programs are needed to enhance safety of operation. Trip reports were written for each of the surveys describing the status of plant maintenance in each of the functional areas.

A maintenance review protocol was developed for obtaining information on licensee maintenance program status. Input to development of this protocol included experience gained from initial surveys of current maintenance practices. The protocol can be used as a tool to determine licensee maintenance performance effectiveness and response to maintenance program improvements as evidenced by its use during Region based maintenance inspections.

This project also included a review and analysis of inspection reports for operating reactors and identification and review of additional information needs and sources (e.g., AE00 analyses, INP0 evaluations, PAT inspection reports and Safety System Functional Inspection (SSFI) reports) in order to identify the characteristics of current maintenance programs and practices in the U.S. nuclear power industry. Problems identified at the plants surveyed were discussed in the appropriate functional area of the trip reports.

The development, implementation, and the effectiveness of the preventive maintenance program at Salem was evaluated as an example of a recent licensee response to a requirement

for maintenance. Other industry experience with and need for preventive maintenance was compared with the Salem program. As a result, important factors influencing the success of a preventive maintenance program were identified in a preliminary fashion.

3.2.2 Maintenance Performance Indicators Objective and quantifiable variables were identified for use in determining maintenance effectiveness as it influences safety. Preliminary investigations of plant performance safety indicators have shown that multiple variables may be selected which in combination, indicate the effectiveness of a nuclear utility's maintenance practices. The development of maintenance safety indicators built upon preliminary analyses of variables to derive a set of indicators which may be used to describe industry maintenance performance, compare plant maintenance effectiveness, and assess maintenance trends and patterns. This task provided further baseline data as reference for industry progress in maintenance program improvement. Alternative data sources and methods were evaluated for applicability to maintenance performance assessment. An NRC Task Force has been formed to review, evaluate and develop performance indicators. The work performed to develop maintenance performance indicators has been utilized by this Task Force. Some of the maintenance performance indicators have been included in the proposed set of NRC indicators. Plant-specific data and information from an industry survey being conducted by INPO to develop maintenance performance indicators were not made available for NRC use in trending industry maintenance effectiveness during Phase I. NUREG/CR-4611 has been published which presents findings obtained during Phase I of the MSPP.

3.2.3 Monitor Industry Activities Throughout all phases of the Maintenance and Surveillance Program, the NRC monitored industry progress and experience in developing strategies for improved maintenance.

Coordination with INP0 was necessary to monitor the effectiveness of the INP0 plant evaluations, accreditation of training, and good practices in enhancing maintenance performance in the nuclear industry. In the 1984-85 period, a number of utilities have initiated major new maintenance programs as determined from our site surveys. However, because of the limited sample size, the staff cannot determine the extent of the changes nationwide.

Implementation of INP0 guidelines and the results of i

industry initiatives were monitored and their impact l

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assessed, although it is too early in the implementation process to draw firm conclusions regarding their effectiveness. This aspect will be carried out during Phase II. In addition, industry activities such as standards development and data reporting provided input to the NRC development of performance measurement methods, guidelines, and criteria for maintenance and surveillance.

3.2.4 Participate in Standards Groups During all phases of the maintenance program, NRC representatives plan to participate in development of industry national standards for maintenance by IEEE, ASME, ANS and ANSI groups. Industry standards are perceived as a means of promoting maintenance program improvements without NRC regulation. NRC endorsement of industry standards will be considered during the maintenance program. During Phase I, NRC representatives participated in ASME and IEEE standard development work related to maintenance. We reviewed and commented on six IEEE draft recommended practices which are in the various stages of development.

3.2.5 Maintenance and Surveillance Program Integration Numerous projects sponsored or monitored by DHFT as well as by other NRC offices and industry groups produced data and information which is necessary to evaluate the safety significance of maintenance problems and potential solutions. The purpose of this project is to coordinate planning as well as to review, evaluate and integrate the results of multiple projects in order to develop appropriate conclusions and make recommendations based on available technical information. The results of the survey of current maintenance practices, plant maintenance reviews, and maintenance indicators investigations were reviewed and assimilated as part of Phase I to provide conclusions and recommendations for maintenance program improvement strategies and subsequent maintenance program plan activities.

3.2.6 Analysis of Japanese /U.S. NPP Maintenance Programs This project involved a comparison of U.S. and Japanese nuclear power plant maintenance programs in the following areas: the differences in U.S. and Japanese NPP operating experience, the organization and management of NPP maintenance in Japan, and the comparison and contrast of Japanese and U.S. preventive maintenance requirements. The results of this project will be utilized in Phase II to provide technical inputs as an aid to determining the l

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appropriate balance between the requirements for surveillance testing and preventive maintenance.

Information on Japanese nuclear power plant maintenance programs is provided in NUREG/CR-3883.

3.2.7 Maintenance Personnel Qualifications The purpose of this research project was to identify from job and task analysis data, the knowledges, skills, ard abilities required for the duties of electrical, mechanical, instrumentation and control, and supervisory maintenance personnel. The pertinent education and vocational training g'" backgrounds as well as any aptitudes which provide the appropriate knowledge, skills, and abilities were to be determined. The goal was to determine the appropriate maintenance personnel qualifications for use in developing standards and by which to assess current industry practice in ensuring the qualifications of maintenance personnel.

The results of this research were to be used to determine format, content, and use of job performance aids as means of y

• I improving maintenance personnel performance. As a result of the Policy Statement issued on training and qualification of nuclear power plant personnel (Connission Policy Statement gy Ao on Training and Qualification of Nuclear Power Plant Personnel, published in the Federal Register March 20, 4., , 1985), the NRC will refrain from rulemaking in this area for pq two years. Therefore, the subject of maintenance personnel qualifications was not included in Phase I. The area of training and qualifications of maintenance personnel has been included in NRC post-accreditation reviews. The results of this project will be utilized in Phase II of the Maintenance Program, as applicable, to provide infonnation about the present level of maintenance personnel skills and the necessary personnel qualifications, i.e., knowledges, skills, and abilities, for correct performance of maintenance tasks. .

3.2.8 Human Factors in In-Service Inspection (ISI)

NRCregulations(10CFR50.5N(g))requirethatnuclearISI power plants have an effective ISI program in place.

constitutes one facet of a preventive maintenance program.

Ultrasonic testing (UT) makes up part of an effective ISI program. UT is subject to variability based on the accuracy of the UT technician performing the inspection. >

Therefore, in order to obtain sufficient objective information to determine accuracy of UT and to ultimately improve UT technician performance, a feasibility study investigating UT techniques and associated human error potential was performed. This project was conducted in

conjunction with the RES-sponsored program titled

" Integration of NDE Reliability and Fracture Mechanics."

contributing to ineffective UT/ISI process methods of representing inspector performance wer >

identified.

3.2.9- Human Error in Events Involving Wrong Unit or Wrong (Generic Issue 102)

In January 1984, the Office of Analysis and Evaluation of Operational Data (AE00) issued a special study report describing a number of events that resulted from human error in removing equipment from service or restoring equipment following maintenance that involved the wrong unit or wrongAlt train of equipment being rendered unavaila events identified resulted from human error duringAE0D conside maintenance and surveillance testing. events to h I significance due to potential loss of safety syste functions.

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"' Information licensees to theNotices (84-51 potential safety and arising problem 84-58)from were wrong iss Lj unit and wrong train personnel errors.

0Mq As part of Phase I, the NRC reviewed operating experien conducted site visits, and interviewed licensee personne regarding 35 wrong unit / wrong train events at 10 sites determine the extent and nature of loss and to identify factors (i.e., labelling, procedures, training) that contribute to human error involving i

unit / wrong train. Recommendations for NRC actions to resolve th NUREG-1192. A decision on the Generic Issue cre given in the NUREG. imp DHFT/NRR.

3.3 MAINTENANCE AND SURVEILLANCE pROGR'AM PROJE The projects described below are intended toBecause accomplish the objectives of Phase II (as described in Section 3.1).

issues are complex and affect a number of different asp maintenance, the resolution of individual issues will be de from multiple efforts conducted by the NRC as well as by th industry.

To accomplish this multi-directional solution, the projects will contribute to the resolution of more than

in maintenance, as shown in Figure 3.3. Figure 3.3 is a matrix which displays how the output of each project will contribute to the resolution of the various issues. In the development of this project plan, strong emphasis was placed on a comprehensive integration of NRC activities which are related to maintenance and those which were initiated by the industry. Such an integration is intended to eliminate any duplication of efforts. Integration with industry initiatives consists of information exchange meetings before project initiation, briefings on progress, and exchange of findings.

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Planning activities for Phase II projects of the MSPP were approved in June 1986. Phase II is anticipated to be completed in October 1988. This time period corresponds to the schedule which was developed originally for Phase II. The overall schedule for Phases I and II and their interrelationship is given in Figure 3.1.

Current schedules for Phase II activities reflect implementation by NRC staff and do not consider contributions from contractor d

efforts..

It is anticipated that an interim report on Phase II will be prepared in October 1987. A final report describing the developments in industry maintenance programs and resolution of the maintenance issues is expected to be issued in October 1988.

3.3.1 Site Surveys NRC will survey maintenance programs at operating reactors not previously surveyed to:

1) Broaden our data base on industry maintenance programs.

2) Provide an in-depth examination of specific functional areas identified by a detailed review of the plant

maintenance measures, resident inspector questionnaires and site survey reports.

3) Examine the implementation and effectiveness of maintenance programs through a detailed review of system reliability and availability. Systems to be reviewed will be determined by examination of LER and NPRDS data.

4) Determine the contribution of maintenance to plant safety, including the role of preventive maintenance, human performance, management responsibilities and the maintenance / operations interface in achieving acceptable levels of reliability and availability.

5) Validate measures of maintenance effectiveness including both NRC and INPO indicators.

6) Collect information regarding the implementation of industry maintenance initiatives and evaluate their effectiveness in improving individual plant and industry-wide maintenance performance.

7) Identify industry practices that can be endorsed or recommended by NRC.

The protocol used during Phase I site surveys will be used

, as modified to assure collection of data pertinent to the areas mentioned above. All five Regional Offices will continue to be involved in this project.

During the second half of Phase II, the staff will conduct follow-up surveys at sites surveyed during Phase I which were identified as having initiated major new maintenance programs in 1985 and 1986. These surveys will be aimed at assessing the implementation and effectiveness of the new programs.

3.3.2 Analysis of Maintenance Measures Within the context of the MSPP, an extensive data base containing measures of plant maintenance performance was developed in Phase I. During Phase II, relationships and correlations among the data will be examined in order to improve the use of plant maintenance performance measures.

Validation of the measures as reliable indicators of plant maintenance performance will be accomplished through analyses of qualitative maintenance programs descriptions (i.e., SALP, PAT reports) and the site surveys described in Project 1. The INP0 Maintenance Performance Indicators will also be monitored. Those based upon data available to the NRC will be compared with NRC measures, while those based upon industry data not available to the NRC will be qualitatively analyzed, to the extent possible, in a manner similar to the NRC maintenance performance measures. It is expected that the staff will continue to interact with INP0 regarding the maintenance indicator data by reviewing plant specific data at the INP0 Offices. NRC has been told by NUMARC that some plant-specific data may be available for analysis (see Section 3.5.1). All indicator activity will be closely coordinated with IE as the Program Office responsible for development and implementation of the overall Plant Safety Performance Indicator program. This

, coordination will eliminate redundant data collection and i

analysis and is expected to result in development of a validated maintenance performance indicator for adoption by the overall Plant Safety Performance Indicator program.

3.3.3 Assessment of Industry Initiatives ,

The staff will continue to monitor industry generic maintenance activities. This task will be accomplished by:

1) review and evaluation of industry standards and guidelines for the conduct of maintenance (e.g., EPRI research programs and reports, INPO programs designed to improve maintenance guidelinedocuments)  ; 2) performance,andINP0 continuation of NRC/INP0maintenance information exchange meetings; 3) evaluation of industry self-assessment programs by direct observation of INP0 plant evaluations; 4) evaluation of industry maintenance initiatives as described in Project 1; and 5) monitoring the extent of implementation of industry initiatives (e.g.,

use of INP0 maintenance guidelines, 0&MRs, good practices; utilization of EPRI research results; use of NPROS/SEE-IN, participation in maintenance workshops).

3.3.4 Study of Federal Aviation Administration (FAA) Maintenance Guidelines The responsibility of the FAA with regard to the airline industry is similar to the NRC respensibility for regulating commercial nuclear power. Although differences exist between the charters of each agency, both are charged with assuring public safety. The safety record of the airline industry has evolved from a changing regulatory philosophy.

Over a period of years, maintenance in the airline industry has moved from a hard time philosophy (whereby a component must be serviced on or before a specified time based upon engineering judgment) to condition monitoring (a reliability based process which considers the entire population of components in service). The reliability based maintenance program in the aviation industry is based on extensive collection and analysis of reliability data on aircraft systems and components. Thus, the FAA has accumulated extensive experience regarding reliability analysis and regulatory review of maintenance activities.

Nuclear power plants and jet aircraft are technically complex machines composed of numerous individual components which must function together in order for the overall machine to function properly. Maintaining individual components, many of which operate continuously for long periods of time, is a key aspect of both the airline and nuclear power industry.

The purpose of this project is to: 1) determine whether the reliability approach toward maintenance developed by the airline industry is a viable and appropriate approach for nuclear power plant maintenance; 2) detennine if the FAA methods and policies regarding maintenance program review and approval are appropriate for consideration in the NRC approach to maintenance; and 3) determine if the collection and analysis methodology employed by the aviation industry in determining maintenance requirements can be utilized in developing reliability based programs in the nuclear industry.

The staff will: 1) review FAA regulatory requirements with respect to maintenance; 2) examine the evolution of FAA regulations; 3) examine the implementation process for these requirements; and 4) review FAA oversight activities.

In addition, the staff will examine the evolution of maintenance within the airline industry from hard time to condition monitoring. Information obtained by the NRC Office of Research on these subjects will be reviewed and incorporated into this study as appropriate.

The current NRC approach to maintenance is to monitor and evaluate industry initiatives. However, if industry initiatives prove unsuccessful, the NRC must be in a position to recommend alternative regulatory approaches to improve nuclear power plant maintenance in accordance with the Commission's 1984 PPG. This study will provide input to establishing those alternative regulatory approaches should they prove necessary. It is anticipated that this study will be undertaken only if industry initiatives appear unsuccessful.

3.3.5 Integration with Related Programs Projects underway in other NRC offices and industry groups are expected to produce data which may be useful to evaluate the safety significance of maintenance problems and potential solutions. The purpose of this project is to coordinate planning as well as review, evaluate and integrate the results of multiple NRC/ industry initiatives in order to develop appropriate conclusions and make recommendations based on available technical information.

The results will be reviewed and assimilated to provide conclusions and recomendations for maintenance program improvement strategies. Within the activity of this project, NRC staff will participate in the work of national standards groups (e.g., ASME, IEEE, ANS) toward developing and implementing performance-oriented maintenance criteria and standards. Endorsement of maintenance standards will be considered during the maintenance program.

3.3.6 Prepare Commission Policy Statement on Maintenance Results of Phase I activities will be analyzed in order to prepare a Commission Policy Statement. The Policy Statement will: recognize the initiatives of the industry in developing programs to improve nuclear power plant maintenance; 2) encourage further industry activities toward self-improvement; 3) outline the schedule for further NRC activities concerning plant maintenance including the intent to continue to monitor industry '

programs;4) indicate a time frame acceptable to the staff for implementation of the industry initiatives and evaluating their effectiveness; and 5) emphasize the responsibility of the NRC in assuring the health and safety  !

of the public such that imediate safety concerns will be addressed upon their identification. This task will meet the 1985 PPG regarding recognizing the contributions of industry programs to the extent that they are effective and i consistent with NRC regulatory responsibilities.

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3.4 RELATED PROJECTS Related ongoing and planned projects have been identified which may provide technical data and other products useful to the maintenance ,

and surveillance program. A listing of related projects in NRC offices and industry organizations is given in Figure 3.4. A description of the interfacing programs extends only to those elements that are related to the maintenance and surveillance program; it must be noted that the scope of these programs encompasses other objectives as well.

Although sufficient information has been developed to initiate Phase II projects, detailed milestones and interfaces have not been identified for all related NRC and industry programs. Specific project details are being coordinated with other offices and may result in the need for changes or modifications to project schedules to provide interim products as appropriate.

Major programmatic responsibilities for NRR include projects to measure maintenance performance, assess industry developments and scope NRC activities, with the Division of Human Factors Technology (DHFT) having lead responsibility. These goals are related to DHFT activities concerning maintenance indicators, assessment methods and maintenance practices.

Coordination with IE is necessary for projects related to the evaluation of importance to safety issues and QA program impact on maintenance standards and criteria development. Participation of IE headquarters and Regional staff with NRR staff to evaluate licensee maintenance performance and monitor industry programs was effected in Phase I and is expected to continue in Phase II. l Inspection data was an important source of information for Phase I projects.

Coordination with RES will provide support for program elements to review surveillance and Technical Specification requirements and investigate reliability methods and their applicability to maintenance programs.~ The projects described below have been identified as important interfaces for the Maintenance Program.

DRA0 will coordinate ongoing and planned activities to support these program elements. The Nuclear Plant Aging Research of RES/DET provided information related to the role of maintenance in counteracting the effects of plant aging during Phase I. Plant aging will continue to provide input to the MSPP as the topic develops.

AE00 supported IE and NRR review of licensee operating experience related to maintenance. LER data was an important source of data for measurement of maintenance performance effectiveness and will continue as an important source of data.

S FIGURE 3.4 RELATED PROGRAMS Responsible Organization NRC Quality Assurance Program Plan IE Safety Implications of Control Systems (USI A-47) NRR Technical Specifications Research NRR Technical Specifications Improvements NRR Nuclear Plant Aging Research RES Effectiveness of Industry ALARA Programs NRR Equipment Qualification - R.G. 1.89 NRR Reliability Program RES Training and Qualifications of Personnel NRR Industry Maintenance Activities Coordination NUMARC Standards ANS,ASME,IEEE,ASQC Plant Evaluations INP0 NPRDS, SEE-IN INP0 Maintenance Superintendent's Workshops INP0 Good Practices INP0 Accreditation of Training INP0 Maintainability Guidelines EPRI Reliability Centered Maintenance EPRI Personnel Selection EEI

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3.4.1 Quality Assurance Program

! The goal of the NRC is to assure a high level of quality in 4

management of reactor design, construction, operations, and maintenance. The NRC policy with respect to improving the quality of nuclear plants is,to (1) assure utilities ,

, provide the appropriate management framework and capability i for safe operation and maintenance of nuclear plants;-

! (2) to improve quality in utility 1 operations and in procedures, systems,'and components used in operations; and (3) to develop better guidance for the treatment of plant systems. components, and equipment'that can adversely affect 4

safe operation (NUREG-0885, January 1984). l The draft of the NRC's'Qutlity Assurance Program Plan, developed by IE, was conipleted in October ,1984. The Quality Assurance Program Implementation Plan was submitted to the l Commission via SECY-85-65 on February 25, 1985. Several

major initiatives of the QA Program are anticipated to have i important implications for Maintenance Program activities.

These include: s i development and use of QA performance measures and trends for assessing the effectiveness of QA programs; j

the NRC inspection program (including IE team inspections and agency SALP reviews);

l personnel issues (deleted);

f revision to quality assurance standards (e.g., Regulatory Guide 1.33); and l

the important to safety issue d d development of improved

methodology for identifying and classifying systems, i structures, and components.

i i Performance measures will be used to assist the SALP process in assessing effectiveness of QA programs as well as

< revisions to NRC inspection programs. The Maintenance and <

l Surveillance Program, Phase I activities, provided j assessment methods and preliminary indicators of licensee i maintenance performance elements. Information from'IE assessments of licensee maintenance performan;:e from routine l inspections, SALP reviews, and PAT and SSFI inspections l provided information about the current status of maintenance i

performance in the industry. 'These data were used as one source of information in order to develop techniques for i objectively assessing licensee maintenance performance l

during Phase I of the Maintenance Program.

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The Maintenance Program project to study the qualifications of maintenance personnel was deleted from the program and, therefore, the previously identified interface with IE personnel issues no longer exists.

Revisions to the QA/QC standards (i.e., Regulatory Guide 1.33) as part of the IE QA Program may involve coordination with IE for Regulatory Guide modifications.

The IE plant surveys for the important to safety issue were a source of information for Phase I of the Maintenance Program. IE has visited several utilities to examine their overall approach to ensuring quality in nonsafety-related systems and activities. The IE surveys provided data regarding plant practices in maintaining equipment important to safety. The scope of the Maintenance Program concerns maintenance of systems and equipment regardless of classification. The agency policy regarding systems and equipment important to safety will help to determine the scope of regulatory concern for maintenance. The nature and i safety significance of maintenance problems identified during Phase II may also clarify the definition of important to safety in terms of risk. For each of the QA program projects described above, working contacts have been established between IE/QAB and NRR/DHFT.

3.4.2 Safety Implications of Control Systems (Unresolved Safety Issue A-47)

The Division of Safety Review and Oversight (DSR0),

Engineering Issues Branch (EIB), is the lead organization for this unresolved safety issue. The project identifies nonsafety grade ccatrol systems in which a failure or malfunction could have significant impacts on plant safety.

The study was designed to identify the control systems that are important to safety, to conduct computer simulations to determine the effects of failures,'to evaluate licensee responses to relevant regulatory actions, and to propose criteria or guidelines to improve the reliability of l

nonsafety grade systems. The evaluations did not explicitly include the effects of maintenance upon component failures l

leading to scenarios of interest and, thus, this project was not reflected in the Phase I report.

3.4.3 Technical Specification Improvements l

In December 1984, H. Denton, Director, NRR, established the Technical Specification Improvement Project (TSIP) in the Division of Safety Technology to reconsider the entire area of Technical Specifications, including philosophy, scope, l

, l 4 content, depth, and the process by which'they are  ;

i incorporated into licensing.

. l The Project completed its work and published its  !

recommendations on September 30, 1985. This work (called PhaseIofTechnicalSpecificationimprovements)wasdonein

. .' 4 close coordination with similar work by The Atomic Industrial Forum (AIF).

- At the certter of the TSIP work was a recommendation to issue a Commission Policy Statement. Its purpose would be to encourage licensees ~ to adopt clarifications in the scope and purpose of Technical Specifications and in irrprovements in bases and human factors aspects of Technical Specifications.

It wot1d, therefore, serve as a basis for the NRC anc industry to implement voluntarily Technical Specification improvements consistent with TSIP and AIF recommendations.

In organizational changes implemented in January 1986, a unit, Technical Specifications Coor'dinat,1cn Branch (TSCB) in the Division of He; nan Factors TechnologyJwas created by the Director of NRR to implement recommended improvements (Phase II of Technical Specification improvements) and to provide oversight and generic Techaical Specification functions.

Since its formation, a prcgram plan for implementation of improvements has been develope ( and approved that schadules the tasks and assigns responsibilities for their completion.

The draft Policy Staterent has'been prepared and most other 1, planWd actions are underway.

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Phase III planning for continuation of Technical Specification improvement is underway. This work will

initiate a complete evaluation of thr Technical Specifications revised under Phase II using.rfsk techniques to give a greater risk perspective to thc' Technical Specifications. Thisievaluation will include enmination of

- cumulative equipment allowed outage times, optimum surveillance interval., test relevance, effects of different channels of separate safety systems being concurrently out of service, allotment of risk, risk (safety-goal) as affected by degraded plant conditions snd composite effects 4

' on overall risk from individual parameters including maintenance.

Areas of Interaction Identification of the role and the scope of mainter:ance as an element of ths Technical Specifications s

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Identification of maintenance errors and reportable occurrences related to Technical Specifications requirements from Phase II of the Maintenance Program.

• Recomended short-term Technical Specifications improvements which may impact maintenance performance effectiveness to be evaluated during Phase II of the Maintenance Program.

3.4.4 Technical Specifications Research In August 1983, the Executive Director for Operations (ED0) requested the Deputy Executive Director for Regional Operations and Generic Requirements (DEDR0GR) to establish a Task Group to identify the scope and nature of problems with surveillance testing in current Technical Specifications and to develop alternative approaches to provide better assurance impact plantthat surveillance safety. testingfound The Task Group does(NUREG-1024 not adversely) that because of the interdependence between surveillance testing, limiting conditions for operation (LCOs) and their bases, it was necessary to broaden the scope of the review to include potential generic problems with Technical Specifications in addition to the original charter which was limited to problems associated with surveillance testing. The EDO endorsed the thrust of the recommendations and the implementation methodology outlined in the Task Group report.

A November 14, 1983 ED0 directive also indicated that the Office of Research (RES) would provide the research and analytical support needed for the NRR program. As a result of this action, the Division of Risk Analysis and Operations (DRA0) initiated a broad-based program, Procedure for Evaluating Technical Specifications (PETS), designed to examine approaches for developing a quantitative basis to support engineering judgments in evaluating Technical Specifications, and to demonstrate and fully document the methodology.

In a related activity, the Division of Safety Review and Oversight (DSR0), Reliability and Risk Assessment Branch (RRAB), has the lead responsibility for the resolution of Generic Issue B-61 to optimize ECCS allowable outage periods and test / maintenance intervals to reduce system unavailability. Presently, the maintenance unavailability of a component depends not only on the average length of time that a component is out for maintenance, but also on the frequency with which the maintenance is performed.

Present Technical Specifications do not control the

frequency of such unavailability, but a cumulative outage limit may be effective in doing so.

Since analytically based criteria are needed as a basis for determining surveillance and test intervals in Technical Specifications for emergency core cooling systems (ECCS),

NRR/DSR0 has requested that RES incorporate into the PETS l program the need to identify and evaluate possible means of implementing limits on cumulative outage times. The RES methodology for analytically deriving cumulative outage limits for ECCS will be completed in 1986.

The PETS program provided a method for setting limits on reliability levels for diesel generators. The Division of Safety Review and Oversight, Reactor Safety Issues Branch, has the lead responsibility for the resolution of Generic Issue B-56 on diesel reliability. Issue B-56 has a high priority ranking due to its impact on plant safety concerning successful accident mitigation. The PETS program investigated several criteria, which are important to the development of a methodology to rciate cumulative outage time with diesel reliability level, diesel configuration, and surveillance frequency.

Phase I of the PETS program was designed as a concerted effort to urgently resolve some generic questions surrounding the risk importance of both corrective and preventive maintenance procedures, as well as to provide timely support for Generic Issues B-61 and B-56.

Areas of Interaction 1

The MSPP is designed to examine the surveillance requirements in the technical specifications in view of the preventivo maintenance program. The PETS methodology will be reviewed to determine how to utilize it in analyzing the hypothesis that an effective maintenance

' program may compensate for some of the surveillance requirements in existing Technical Specifications. DHFT will prepare the user need as appropriate for continuation of the PETS program to analyze the hypothesis.

i The PETS program will complete the technical analysis during Phase II: (1) to determine the requirements for changing the surveillance requirements in relation to the preventive maintenance programs and (2) to establish surveillance requirements on the basis of system reliability.

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The ECCS outage research will provide input to Phase II of the Maintenance and Surveillance Program. The risk-based methodology for deriving Technical Specification outage limits will be evaluated as a means of determining maintenance needs and the results of trial Technical Specifications evaluations will be used to determine the nature and extent of maintenance problems at operating plants.

The results of the trial applications of methods for deriving ECCS outage limits will be assessed for Phase II to determine the impact on safety.

The need for limits governing maintenance and surveillance outages will be determined so that recommendations from the Maintenance and Surveillance Program may be used for development of a licensing position by DST for ECCS outage limits as appropriate.

3.4.5 Nuclear Plant Aging Research The Nuclear Plant Aging Research (NPAR) program sponsored by the Office of Research, Division of Engineering System (DES), is intended to identify and characterize aging and service wear effects associated with electrical and mechanical components, interfaces, and systems likely to impair plant safety. The research will identify and recommend methods of inspection, surveillance and condition monitoring of electrical and mechanical components and systems which will be effective in detecting significant aging effects prior to loss of safety function so that timely maintenance and repair or replacement can be implemented. Aging research will also identify and recommend acceptable maintenance practices to mitigate the effects of aging and service wear. Investigation of root causes and current maintenance problems and practices on a number of selected equipment has been completed. Analyses

' and evaluation for acceptable maintenance practices are

' being initiated with results to be incorporated in the NPAR program recommendation.

Areas of Interaction Survey of maintenance practices for selected components (survey completed)

Anticipated results from the NPAR which will be useful for Phase II Identification of Problems and Impacts will be an evaluation of the relative benefits of preventive l

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and corrective maintenance and identification of potential mechanisms causing equipment degradation through improper maintenance for selected components.

Recommendations for preferred maintenance practices for selected components provided from the NPAR will be used in the Phase II Maintenance and Surveillance Program.

The NPAR will provide an evaluation of the role of maintenance in counteracting aging effects.

• As in Phase I, Phase II of the Maintenance Program will continue to provide infonnation regarding plant maintenance indicators and current industry practices to the NPAR.

Recommendations for inspection surveillance and monitoring methods, including means of mitigating the effects of aging and service wear of selected components as appropriate, will be provided for Phase II of the Maintenance Program from RES.

3.4.6 Effectiveness of Industry ALARA Programs The NRC is concerned with the high proportion of occupational radiation exposure which is attributed to maintenance activities. Consequently, RES sponsored a project intended to identify the issues and perform cost-benefit analysis on new dose-reduction techniques and industry-developed equipment. The Study was completed in December 1985, with the results published in NUREG/CR-4373,

" Compendium of Cost Effectiveness Evaluation of Modifications for Dose Reduction at Nuclear Power Plants."

A related research project has been completed which compared occupational dose experience at U.S. and foreign nuclear power plants with the results documented in NUREG/CR-4381,

" Summary of Comparative Assessments of U.S. and Foreign Nuclear Power Plant Dose Experiences." Additional research completed and documented in NUREG/CR-4254, " Occupational Dose Reduction and ALARA at Nuclear Power Plants: Study on High Dose Jobs, Radwaste Handling, and ALARA Incentives,"

includes an identification and evaluation of high-dose maintenance tasks as well as new industry incentives for dose reduction. One aspect of the RES program is to evaluate the effectiveness of industry (e.g., INP0) programs to reduce occupational exposure and determine the need for further regulatory guidance. Additional work to survey industry and DOE dose reduction research is ongoing at the BNL ALARA Center.

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• The results of the research and assessment of industry-programs were used in developing measures of maintenance practices and problems during Phase I of the Maintenance and Surveillance Program. Occupational exposure data was used as an indicator for assessing licensee maintenance effectiveness.

High-dose maintenance tasks that were identified from the RES programs will be used in evaluating the safety impact of maintenance problems during Phase II of the Maintenance and Surveillance Program.

• ' Dose-reduction techniques identified will be evaluated for their impact on maintenance effectiveness in Phase II.

The survey of industry maintenance practices and problems from Phase I of the Maintenance Program provided information on maintenance practices that impact ALARA programs.

• The above information, as well as information about the relationship between occupational exposure data and 4

maintenance effectiveness as safety indicators, will be provided from Phase I and Phase II of the Maintenance Progra:a input to the determinction regarding the need for regulatory guidance.

3.4.7 Equipment Qualification

, The equipment qualifications program (10 CFR 50.49) requires that each licensee maintain information regarding age-related performance, degradation of equipment and components and maintenance and surveillance activities which affect equipment integrity and operability. Results of the Nuclear Plant Aging Research will provide implications for the environmental integrity of electrical and mechanical components and equipment qualifications. Information and i methods by which licensees may identify and perform necessary maintenance effectively is needed to evaluate equipment qualification impacts. The ongoing IE inspections of EQ programs focus on the technical adequacy of the initial qualification process. The maintenance activities involved in the initial qualification process are those necessary to preserve qualification.

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Area of Interaction The need for guidance to ensure the preservation of qualified equipment will be identified as the safety impact and nature of maintenance problems are investigated during Phase II of the Maintenance Program and provided to the NRR licensing divisions.

3.4.8 Reliability Program The Division of Risk Analysis and Operations (DRA0) of the Office of Research sponsors the reliability research program with objectives to design and build reliability into systems that are important to safety and prevent degradation of this reliability during operation. The tasks to be performed under the reliability research program include a screening evaluation to survey available reliability techniques applicable to LWRs. Elements that appear most promising for applicability to nuclear plant reliability has been l developed for trial application.

Areas of Interaction The reliability research program produced methods and recommendations for determining priorities for maintenance (e.g., frequency, preventive or corrective type) and would help to prioritize equipment for maintenance action.

The results of the trial applications are important for evaluation of the safety impact of maintenance problems during Phase II of the Maintenance Program.

Recommendations for reliability-centered maintenance strategies from the reliability program will be considered in the Maintenance Program.

Information from Phase I surveys of current maintenance practices was provided to DRA0/RES to identify current reliability practices and implementation constraints at operating plants.

Related projects being sponsored by EPRI are being monitored for use in the Maintenance Program through the RES Reliability Program. These EPRI' projects include efforts to evaluate Technical Specifications requirements affecting safety system reliability as well as a trial application of reliability centered maintenance methods at a sample of plants.

3.4.9 Training and Qualifications of Personnel The Commission has approved a Policy Statement (SECY-85-01) whereby the industry would be allowed to proceed for two years under the INP0 accreditation program. The NRC endorses INP0 accreditation as a means of achieving implementation of a systems approach to training (SAT) in the nuclear industry. The accreditation of industry training programs, including training for maintenance and I&C personnel, is being monitored by the NRC and will be reevaluated at the end of the two year period.

The NRC will continue to review training and qualifications as part of the license application and safetr evaluation process. The NRC will exercise some discretion in enforcement matters related to training and qualifications for a minimum of two years. The NRC will continue to inspect training and qualifications programs on a routine basis in order to ensure effectiveness of industry improvement efforts.

The NRC will inspect and evaluate licensee training programs, including maintenance training, using criteria based on the systems approach to training.

Areas of Interaction The need for further regulation of maintenance personnel l qualifications and training will be evaluated based on the NRC review of industry implementation of performance-based training.

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• The results of NRC maintenance training reviews will be utilized during Phase II of the Maintenance Program to assess the effectiveness of industry maintenance personnel training programs.

The evaluation of the safety impact of maintenance personnel qualifications and training, as determined from Phase II activities of the Maintenance Program will be part of the NRC assessment of the effectiveness of industry maintenance personnel training.

The training and qualifications of maintenance personnel were reviewed as part of Phase I activities to identify current industry practices.

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3.5 INTERACTIONS WITH OUTSIDE ORGANIZATIONS Interactions with outside organizations will be conducted in order to assess the acceptability of industry initiatives and activities to achieve the objectives of the maintenance program. A number of outside organizations have expressed interest in nuclear power plant maintenance and are concerned in various aspects of maintenance operations. The Program Plan is designed to assess the significance of the contribution of these organizations and to utilize their activities to complement the NRC efforts. The primary coordination point is currently with NUMARC. Through NUMARC and direct NRC contacts, the following organizations are expected to play major roles in a national program for improving maintenance in the nuclear industry.

1. Nuclear Utility Management and Resources Committee (NUMARC)

The NUMARC Maintenance Working Group is taking or considering several actions in its efforts to assess the status of maintenance in the industry and to determine possible alternatives to ongoing industry programs for improvement.

Their activities as described in an October 6,1986, letter from W. Owen to V. Stello include:

a. NUMARC contributed to the development and subsequent issuance of INP0 85-038, " Guidelines for the Conduct of Maintenance at Nuclear Power Stations (Preliminary)," and INP0 85-026, " Writing Guideline for Maintenance, Test and Calibration Procedures (Preliminary)," both of which are currently being applied by the nuclear utilities.

b. Several utilities have volunteered and are conducting pilot self-assessments using the maintenance guideline referred to above in order to determine the worth and techniques for conducting such a self-assessment.

c. NUMARC conducted a survey of predictive maintenance activities that, based on the information provided by 74 responding plants, indicates predictive maintenance is a growing aspect of preventive maintenance at the nuclear utilities.

d. Nuclear utilities are fully supporting the Maintenance Peer Evaluator Program (analogous to the SR0 Peer Evaluator Program) that was implemented by INP0 in May 1986.

e. Considerable interutility interactions to provide technology transfer is occurring both nationally and internationally between individual utilities and through the INP0 processes.

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f. Utilities are beginning to increase their use of NPRDS now that the engineering database exists and failure reporting data history is increasing (e.g., the rumber of on-line data searches by utilities has more than doubled in the past two years).

g. Utilities are voluntarily establishing programs and becoming participants in the INP0-initiated Human Performance Evaluation System which is aimed at focusing upon and helping to resolve human performance issues.

Currently, there are 15 U.S. and 2 international utilities participating in this program. The participating U.S.

utilities represent 33 nuclear units, with 5 more planning to participate in 1986 and others in 1987.

h. Maintenance training accreditation continues on schedule with the objective of 183 craft programs at 61 plants ready for accreditation by December 31, 1986. As of September 17, 29 maintenance craft programs are accredited and 143 more have self-evaluation reports submitted. In addition, several NT0L plants are pursuing mainenance craft accreditation ahead of the accreditation program schedule.

Seven NT0L maintenance craft programs are accredited and 17 more self-evaluation reports submitted.

1. The industry has and is establishing overall plant performance indicators and long range goals, and providing associated supporting data to INP0 in order to provide measurable indicators of performance for the industry.

Progress and generic results are being shared with the NRC.

Data obtained by NUMARC on performance indicators, which include maintenance indicators, has been considered proprietary and has not been provided on a plant-specific basis to the NRC during Phase I. In concert with the recently published report entitled " Leadership in Achieving Operational Excellence: A Challenge for All Nuclear Utilities," NUMARC has indicated that plant-specific indicator data will be shared with the NRC in the future.

2. Standards Organizations The ASME Committee on Operations and Maintenance, the ANS Operations Comittee, the ASQC QA for Operating Plants, Preventive Maintenance Programs Sabcommittee and the IEEE Nuclear Power Engineering Committee have been conducting a

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I dialogue within the last few years on the need for a national standard on maintenance for nuclear power plants. A working relationship has been conducted with these organizations by NRC representatives on the committees and by periodic presentations on NRC activities to the committee meetings. This participation will continue. If a national standard on maintenance becomes available, it will be considered for endorsement by the NRC.

3. Institute of Nuclear Power Operations The Institute of Nuclear Power Operations (INP0) is involved in a number of activities that are closely related to the subject of the Maintenance Program Plan. In addition to the programs described in Section 3.5.1, the following INP0 programs are considered: (a) INP0's periodic plant evaluations address issues in maintenance. The Program Plan will assess the effectiveness of the plant evaluations and will consider it as one means of industry self-monitoring; (b) INP0 has developed qualification guidelines for mechanics, electricians and instrumentation / control technicians. The implementation of these guidelines will be followed; (c) INP0 has conducted a number of workshops for maintenance superintendents. NRC participation and observation of the workshops will be continued;(d) INP0 is in the process of documenting and disseminating information on good industry practices. INP0 good practice activities on maintenance will be followed in the Plan; (e) INP0's Accreditation Program for Training includes maintenance personnel. Training accreditation is being

! evaluated by NRR; the results will be monitored as part of the planned maintenance activities.

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4. Department of Energy The Department of Energy (D0E) has developed a method to assess the performance of maintenance for nuclear reactors within the i Management Oversight and Risk Tree (MORT) program. The method has been used for DOE reactors, and is in the process of being validated with a number of Scandinavian nuclear power plants.

The applicability of the DOE assessment method for NRC use will L be evaluated within this program.

5. Electric Power Research Institute l

The Electric Power Research Institute (EPRI) has been conducting a large number of research studies related to '

maintenance. Some of the EPRI programs, such as the development of a preventive maintenance guide (EPRI Report NP-3416) or the maintainability guidelines (EFRI

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a Report NP-2360) are directly related to some elements of the Program Plan. The results of EPRI research studies, some of which are being monitored by the Office of Research, will continue to be utilized in the program. NRC personnel will continue to participate in and contribute to EPRI maintenance workshops.

6. Vendor Maintenance Programs The maintenance guidelines, maintenance program reconinendations, and maintenance services available from the vendors of nuclear power plants were and will continue to be

' evaluated and utilized in the program.

7. Maintenance Activities Outside the Nuclear Industry The U.S. military, NASA and the Federal Aviation Administration (FAA) have well-established and successful maintenance programs. The technical, organizational and regulatory aspects of these maintenance activities will be included in the program by direct exchange of information, documentation, and data between the above organizations and the NRC staff.

8. Foreign Countries Maintenance Programs The staff plans to continue its exchange of maintenance program information with the Japanese and to initiate information 1 exchange with the French, German, Swedish, Spanish, United Kingdom and Canadian Governments.

9. Edison Electric Institute (EEI)

Edison Electric Institute has been developing examinations for mlection of nuclear power plant personnel. Ability and aptitude screening as selection practices for maintenance personnel should be pursued for possible incorporation in standards and guidance for personnel qualifications. The staff will exchange information with EEI regarding personnel selection and screening practices in the industry.

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