ML16288A473

Proposed Revised Policy Statement on the Maintenance of Nuclear Power Plants

ML16288A473
Person / Time
Issue date:	10/12/1989
From:	Remick F Advisory Committee on Reactor Safeguards
To:	Carr K NRC/Chairman
References
D891012
Download: ML16288A473 (11)

Text

D891012 The Honorable Kenneth M. Carr Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

PROPOSED REVISED POLICY STATEMENT ON THE MAINTENANCE OF NUCLEAR POWER PLANTS During the 354th meeting of the Advisory Committee on Reactor Safeguards, October 5-6, 1989, we discussed with the NRC staff the proposed revised policy statement on the maintenance of nuclear power plants. During this meeting we had the benefit of the document referenced. We had also discussed this matter during our 353rd meeting, September 7-9, 1989.

The Commission's objective in issuing the policy statement is not clear to us.

Since no one doubts that the quality of maintenance plays an important role in assuring the safety of nuclear power plants, we judge that the perceived need for a policy statement derives from a Commission sense that the fact needs to be emphasized and that industry initiatives in the area are insufficient to provide assurance that the common objective is being met. These initiatives have certainly resulted in improvements in most plants, and more improvements are in the pipeline, yet the Commission has directed the staff to continue working toward a rule.

The current version of the proposed policy statement recognizes the importance of developing measuring tools for the effectiveness of maintenance, without which it is difficult to judge whether or not maintenance is a major problem in the industry. Certainly, a study of licensee event reports (LERs) would reveal incidents whose origin is in ineffective maintenance, as it would reveal also some whose origin is in overly zealous maintenance; therefore, it is important to develop those tools necessary to make better than visceral judgments about the direction in which change is needed, if any.

We believe that more input from the regional offices as well as from the public and industry would improve the proposed policy statement. There are a number of contentious elements in it, which will surely not survive careful scrutiny. For example, the proposal that errors in maintenance be penalized more severely than other errors with the same public consequences would encourage licensees to divert resources from other safety-related activities into maintenance, with a net negative impact on public safety. That is surely not the Commission's intent. We are loath to make a big issue of this one because it is so manifestly wrong (and the staff has committed to reconsider it).

We recommend that the Commission not rush to judgment on this matter. The

proposed policy statement contains the explicit determination (again, surely not intended) that there is no licensee with an acceptable maintenance pro-gram, and makes the determination without even a hint of what is acceptable, or how it can be measured. We think it would be best to spend effort in determining just how serious the problem may be, just what it may be, and only then, whether something needs to be done about it. Armed with this infor-mation, the Commission will be better able to make defensible choices among possible ameliorative programs. It is not beyond the bounds of probability that it will only be necessary to support and encourage the industry in-itiatives. If, in the end, it is determined that a policy statement, or even a rule, is necessary, one will have a better idea of just what it should say.

Additional comments by ACRS Member William Kerr are presented below.

Sincerely, Forrest J. Remick Chairman Additional Comments by ACRS Member William Kerr I am concerned that the Commission appears to be moving inexorably toward an inadequately defined goal. For example, the draft regulatory guide lists several suggested indicators of appropriate maintenance programs, but nowhere is there mention of risk reduction or of increased plant availability, which must surely be important elements in plant performance goals.

I suggest an exercise that should provide useful information to the Commis-sion. Ask the staff to identify, on the basis of information in the recently released version of NUREG-1150, those plants that have acceptable and those that have unacceptable maintenance programs. If this proves feasible, it should enable the staff to identify the characteristics of at least one, and perhaps several, good maintenance programs. It should also permit an identi-fication of the risk reduction attributable to an acceptable maintenance program. If this is not feasible, then it indicates that something judged by the Commission to be a significant contributor to, or reducer of, risk is not identified in what are said to be state-of-the-art analyses of several repre-sentative plants.

Reference:

Memorandum dated September 29, 1989 from Bill M. Morris, Office of Nuclear Regulatory Research, for R. F. Fraley, ACRS,

Subject:

Revised Policy Statement on Maintenance of Nuclear Power Plants (Predecisional)

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