ML19327A717

Provides Commission W/Nrc Proposed Response to INPO Re Use of Performance Indicators

ML19327A717
Person / Time
Issue date:	10/13/1989
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
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ML19327A718	List: ML19327A717 ML19327B601
References
TASK-PINC, TASK-SE SECY-89-317, NUDOCS 8910170126
Download: ML19327A717 (5)

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The Consiissioners 6

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James M. Taylor

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for Operations j

Subject:

RESPONSE TO'INPO LETTER REGARDING THE USE OF PERFORMANCE INDICATORS.

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Purpose:

To provide the Commission with the staff's proposed response to the'INP0 letter of September 8, 1989.

Discussion:

On September 8,1989, the president of the Institute of Nuclear

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Power O mrations (INPO) wrote to the NRC requesting the support i

of-the Executive Director in addressing what INP0 perceived as the inappropriate regulatory use of nuclear plant performance indicators. The staff's proposed response to INP0 is enclosed.

The proposed response consists of a cover letter that-speaks to the two major issues that were raised and an enclosure that addresses the six specific proposals that were listed at the L

end of.the INPO letter. The first major issue was that i

t' emphasis by NRC, state regulatory agencies, and the public on L

specific indicators of licensee performance such as unplanned scrams.andforcedoutages,couldcauseunsafepracticesto develop among the operations personnel at commercial power reactor faci ities. Secondly, INP0 urged that we adopt the l

recently selected set of international performance indicators.

Their proposals involved the reshaping of NRC's Performance Indicator Program to change the current indicators, to abandon

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the development of maintenance indicators, and to exert our influence to sssure the proper use of perfomance indicators by economic regulators.

In general, we do not agree with INPO that the NRC staff is making inappropriate regulatory use of performance indicators.

The examples cited by INPO are not indicative of widespread misuse of performance indicators by the staff. However, in view of the widespread use of performance indicators by

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The Comissioners industry, individual licensees, the,NRC, and the attendant potential for misinterpretation, we intend to reaffirm the policy stated in Announcement No. 30, and to issue revised and clarified guidance.

On September.26,1989, Comissioner Roberts requested staff comments regarding INPO's claim that the staff overemphas12es the indicators tn many regulatory activities, especially in the staff's evaluation of licensee performance. The proposed staff letter is intended to be responsive to Comissioner Roberts' concerns.-

Recommendation:

That the Comission:

1. Note that a proposed response to INPO is enclosed TYKclosure1). The staff intends to send this letter 10 working days from the date of this paper unless otherwire instructed by the Comission.

It would be desirable for INPO to receive our response prior to the i

CEO conference on November 2 and 3, 1989.

Coordination:

The letter and enclosures had input from the Regional Offices. NRR contributed acd concurred in the package and OGC has no legal objection.

e Driginal Signed Byi Jamcs M. Taylor James M. Taylor Acting Executive Director for Operations L

Enclosure:

Letter to Mr. Zack T. Pate F

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i industry, individual licensees, and the N

, and the attendant potential for misinterpretation, we int d to reaffirm the' s

policy stated in Announcement No. 30 d to issue revised.and clarified guidance.

t On September 26, 1989, Comissio r Roberts requested staff comments-regarding INP0's claim that the staff' overemphacizes the indicators n many regulatory

' l activities, especially in th staff's evaluation of licensee performance. The Jrroposed staff letter is intended to be responsive o Comissioner Roberts' concerns.

l Recommendation:

That the Comission:

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1. Note that a propo ed response to INP0 is enclosed ITnclosure1).-

he staff intends to send this-letter within 10 worki g days of the date of this paper unless otherw e instructed by the Comission.

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Coordination:

The letter and nclosures had input from the Regional Offices. NRR ontributed and concurred in the package and OGC has no legal objection.

i James M. Taylor Acting Executive Director for Operations

Enclosure:

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Operations Sutte 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339-3064 Telephone 404 953 3600

' September 8.-1989 6

Mr. James M. Taylor Acting Executive Director.for Operations U. S. Nuclear Regulatory Commission

. Washington, D.C.

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Dear Mr. Taylor:

.The purpose of this_ letter is to request your support in addressing the critica1' issue of what we view as inappropriate regulatory use of nuclear plant performance indicators.

INPO has_had several longstanding concerns with

.NRC's continuing focus on performance indicators as a method of comparing plants and for exerting regulatory pressure on utilities and their nuclear 3

-plant staffs. This letter and its attachments describe'the following:

1) the history of the industry performance indicator program 2). our concerns with' NRC's use of these indicators

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3) recommended actions concerning the NRC's use of performance indicators Beginning in 1980, nuclear utilities, through INPO, embarked on an effort to identify and define mutually agreed upon quantitative indicators of plant performance.

These indicators were intended to be used by-utility line manage-ment to monitor progress, establish goals, and spur healthy competition and i

emulation by comparing results and trends with other utilities. By 1983, most utilities had implemented performance indicators of their own selection using an INP0 Good Practice as a starting point. By 1985, a set of industrywide plant performance indicators was agreed upon, and each nuclear utility then established challenging 1990 goals for those indicators where sufficient data were available. The industry has made impressive progress over the past few years'as measured by these indicators and as frequently acknowledged by the

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NRC. Attachment-1 provides a detailed history of the industry's development y

and use of performance indicators.

It should be evident from this attachment s

that the industry (and INP0) has invested substantial time and resources in the development and subsequent refinements of this program.

-Through the cooperative but extensive efforts of UNIPEDE, WANO, and INPO, broad international agreement has now been achieved on ten overall performance

indicators for internationsi use beginning in 1990.

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Nr. James M.-Taylor September 8, 1989 Page e I

More'important than the effort and resources expended, however, are the principles / policies that have been developed over the years regarding-the use of performance indicators by INP0 and the industry.. These are as follows:

o_ INPO communicates with utilities.regarding performance indicators primarily at the senior executive level. We purposefully avoid actions that could ovt:remphasize the indicators at the middle manage-ment, operator, or technician level. For example, INPO has an estab-lished policy that evaluation findings are not. written with a. focus F.

on performance indicator comparisons. Each finding must focus on the performance shortfalls, and not on a possible symptom.

o Utilities set their own goals with respect.to the performance. indica-tors.

INPO has explicitly designed its approach so that utility managers retain this important prerogative, o The importance'of managing the plant, and not seeking to manage the indicators, is frequently stressed in correspondence, at workshops, and in other forums, o The potential pitfalls of putting too much emphasis on a single or a few indicators are routinely emphasized.

o Performance indicators provide useful additional perspective but are not used as the principal basis for conclusions or recommendations.

Performance. indicators can lag actual performance by several months, or even years. Therefore, INPO's process.for evaluating and assessing station performance relies primarily on site visits by experienced evaluation teams.

o We have discouraged the use of performance indicators by outside organizations that are not directly involved in, or sufficiently knowledgeable of, nuclear plant operations, and that seek to use these indicators for their own purposes.

o Throughout this industry initiative, we have actively sought the L

involvement and input of international nuclear utility organizations to achicve international consensus and avoid confusing or conflicting 1-L performance comparisons or trends.

l-Beginning in 1984, the NRC began to get involved in the use of quanti-tative indicators. Attachment 2 chronicles the NRC's efforts (and NRC/INPO

interactions) in this area.

INPO has spent hundreds of hours in meetings and j

correspondence with the NRC in an attempt to keep the NRC effort from being duplicative of industry efforts or counter to the principles listed above.

One of the NRC's justifications for its effort was that some new insightful

_ indicators might be developed. This has not occurred. The industry's overall performance indicators have stood the test of time in that NRC's efforts have not identified any new overall performance indicators that provide significant I

additional insight.

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g Mr. James M. Tay1:r s

September 8,_1989 Page,

We have been attempting to reach an agreement with the NRC since March 1987 on the appropriate use of performance indicators.

Furthermore,-as shown in Attachment 2, we have consistently expressed concern about the potentially adverse safety. implications of.the NRC's use of performance indicators.

However, we have not reached an agreement on the fundamental issues.

In fact, from our perspective, NRC's misuse of performance indicators continues desoite the Commission's and senior NRC management guidance to the staff. Specifically, in contrast to the guidance to the NRC staff in NRC Announcement No. 30 of February 5, 1988, regarding use of performance indica-tors. NRC activities are frequently breaching the principles that we believe are vitally important:

o We continue to receive reports that regional personnel are employing the indicators to put direct pressure on nuclear plant personnel.

o A review of 61 recent SALP reports showed that unplanned automatic scrams (or scrams per 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> critical) were mentioned in over half (37) of the reports. - For plants with perceived high scram rates, the SALP reports typically state or imply the need to reduce the number of scrams.

In addition, collective radiation exposure or forced outage rates were discussed in many of these reports, o Recent SALP reports have included statements as follows (direct quotes):

November 1988

" Operations displayed both new strengths and continued weaknesses during this assessment period. (Plant) --'

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increased the capacity factor for Unit 1 from 65.7% to 83.5% and for Unit 2 from 53.5% to 57.2% over the pru 'ous assessment period. Particularly noteworthy and a contrh.. 'nr to the above accomplishments was the effectiveness of the 1 b 'see's scram reduction program."

March 1989 "A comparison with the previous SALP shows that the l

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unit forced outage rate increased from 4.01 to 6.20 percent. The outage rate is above the industry mid-1988 one year median of u

l 4.8.

The reactor trips (scrams), when compared with the previous SALP increased from seven to eight. The trip (scram) rate, even though some improvement was shown in 1988, is still above the industry one year median of approximately two."

March 1989 "Added management attention is also needed to reduce the number of. reactor trips."

April 1989 "During this assessment period only one reactor scram occurred, compared with ten during the previous two assessment periods, indicating a significant improvement in performance."

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Mr.' James M. Taylor.

September 8, 1989

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June ~1989

" Performance in this area was rated. Category 2 with a declining trend in-the previous SALP assessmentc Although the i

trip (scram). rate had been significantly reduced it was concluded that it could be further reduced through better procedural control

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of operational activities and attention to detail by the operators.

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... In' contrast to the previous SALP period no trips (scrams)

I were caused by deficiencies in operations during the current SALP period.

This reflects a significant improvement from previous SALPs."

August 1989

" Plant Operations was rated as a SALP Category 2 during-the previous assessment period.

Licensee strengths

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included a strong management team and an improved trip frequency.

.... During the current SALP period there werf 16 reactor trips between the two units (5 on Unit 1, 11 on Unit 2), including six trips directly or indirectly attributable to the operations i

functional-area. The 16 reactor trips were more than twice as many as during the previous assessment (seven). The number of i

trips two SALP cycles ago was 18.

The licensee's trip reduction

'i efforts appear to have been ineffective since the last SALP...."

l o _The indicators are being widely discussed among NRC staff personnel during their visits to nuclear plants, with the clear potential for putting-pressure on plant operators to avoid scrams, avoid plant or equipment forced outages, etc.

o NRC concerns over certain performance indicator results are routinely l

discussed in the trade press, again with the potential to put undue

-pressure on plant operating staffs.

During the staff briefing of the 1

Commission of December 21, 1988, regarding status of nuclear plants, a regional administrator's comments on the high' number of scrams at a l

particular nuclear unit were subsequently reported by INSIDE NRC as L

the reason for that unit being added to NRC's list of problem plants.

l (SeeAttachment2)

S o The NRC continues to use definitions of some performance indicators (and publish data) that are similar but not identical to the industry developed performance inJicators. This results in confusing and conflicting reports regarding performance trends.

L It is not in the best interest of reactor safety for the NRC, as the regulator, to put direct pressure on utilities to operate their reactors (e.g.

to avoid scrams, or to reduce forced outages, or increase availability).

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W ar contrast to the recent activities by the NRC, the Federal Aviation Administration (FAA) does not put pressure on airline flight crews to conduct scheduled flights (or to reduce flight cancellations or deviations due to equipment problems). The FAA requires that certain equipment be operable before a departure can be made, but beyond that it is lef t to the prerogative of management and the pilot in command, l'

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b Mr. James M. Taylcr N

September 8,'1989 E c Page Pressure by the NRC to avoid a scram, or a forced outage, or to achieve high capacity factor or availability is surely just' as unwise as FAA putting pressure on a pilot to "go," or NASA putting pressure on middle management to

" launch." This principle is illustrated ir. an article by Jerome Lederer, h

former director of the Flight Safety Foundation, published in the December 1987 issue of AVIATION SAFETY (Mr. Lederer was director of safety for NASA during the very successful Apollo Program and was a member of INP0's Advisory Council for six years).

In this article, Mr. Lederer, in reference to the aviation industry. states:

"I still keep my eye on things and one of the things that disturbs me is that when... (the Secretary of Transportation)

... put out an edict requiring the airlines to report deviations from schedule, but not i

because of inechanical problems. That's a very dangerous thing, because it puts pilots under pressure. That's the reason we killed so many pilots in the U.S. Mail Service

- because of the pressure put on them by the post office department, which had to prove to Congress that air mail was reliable."

L Former NRC Commissioner John Ahearne expressed a similar view in the October 30 1986 issue of Public Utilities Fortnightly. After summarizing serious concerns about the use of performance incentives in safety or economic regulation of nuclear utilities he went on to say:

" Performance incentives are basically a sound idea.

People work best if they know in advance the standard b

against which their performance will be measured. But I L

would not want to fly on airlines where the incentive L

system established by their regulators was based on how many hours could an airplane be in operation per day."

1 In the same. article he quoted 1983 remarks by Dennis Wilkinson, the first i

president of INPO, as follows:

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If emphasis is placed on safety and reliability, a good capacity factor is a natural result.

If however, the principal emphasis is on capacity factor, adequate safety is not a natural result."

Of particular concern, we believe that continued NRC emphasis on the number of reactor scrams as a measure of nuclear plant regulatory performance can, over time, establish a mind-set among nuclear plant personnel that is detrimental to reactor safety. Reducing the number of unnecessary scrams without eliminating a necessary scram is a delicate matter. A mind-set among nuclear plant personnel that any scram is a highly negative indicator of performance may lead to actions that preclude a needed scram (e.g., an operator may be hesitant to initiate a scram that he feels is warranted or other technicians may take unconservative actions or make unconservative adjustments or calibrations). Thus, the purpose of the scram function as a primary means of preventing core damage could be defeated. This concept was

w Mr. James M. Tay1cr S:ptember 8, 1989 Page '

l stressed in our July 10, 1985 letter to Bill Dircks and included in letters of November 5, 1986 and May 14, 1987 to Chairman Zech and has been the subject of t

discussions with NRC staff on a number of occasions since.

(See Attachment 2 for copies of.each of these letters.)

As a related matter, we are also concerned that the NRC is tracking, publishing. and speaking publicly about manual unplanned scram data.

INPO has t-clearly and consistently objected to this practice as noted in our letter to the NRC of August 18, 1988 (see Attachment 2). This emphasis only adds to the

' worry that an operator will_have.about initiating a manual scram.

For this reason, INP0 does not publish manual scram data.

As an industry, with well over 100 operating nuclear units, the bottom line' concern is that regulatory pressure to reduce scrams will eventually lead to the failure to get a necessary scram.

If core damage occurs as the result of such improper use of a performance indicator, the cost to the industry and the nation will be enormous. A number of events have already occurred at nuclear plants since early 1988 where operators were slow in initiating a manual scram when plant conditions warranted rapid shutdown. While these delays

, cannot be directly attributed to NRC pressure on operators, a review of SALP reports shows that the NRC has and continues to emphasize scram trends at most of-these plants. This practice is clearly pressuring plant management and operators and technicians to reduce scrams.

INP0 continues _through the industry's long-term goals program, to encourage its members to understand the causes of unnecessary scrams and take appropriate corrective actions, but we constantly stress the need to manage for excellence using a broad set of performance indicators, of which scram performance is only one. We also consistently advise member utilities that in striving for improved performance against measurable objectives, they must keep these efforts in perspective for their operational and technical l

personnel.

In the case of scrams, we cannot afford to have any operator feel l.

concern over initiating a scram that he thinks is warranted. An attitude must l

be. instilled in the operator that he is a key factor in taking actions to prevent or mitigate the consequences of an accident, and thereby protect the public. Regulatory use of this indicator is not consistent with this objec-tive, and, in effect, bypasses the attempts of line management to keep this issue in perspective. The industry is making excellent progress in the area of reducing unplanned automatic scrams by addressing the causes, and this trend was clearly evident before the NRC became involved with the scram performance indicator.

From 1980 to 1988 the number of unplanned automatic scrams per unit has been reduced by a factor of 3.5, and the projected industry unplanned automatic scram rate for 1989 is less than 2 per unit through the end of July. Thus, it appears that regulatory focus on this area was and is unnecessary, notwithstanding the more important reason cited above.

Another area of particular concern is the NRC's intent, expressed in SECY-89-143 of June 19, 1989, to " encourage the further development and use of maintenance performance indicators by the nuclear industry such that the Commissioners and the industry may closely monitor the progress of industry improvement initiatives." SECY-89-143 also directs the NRC staff to invite I

f Mr.' James M. Taylor

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- September 8,'1989 Page i I

participation by a group of utilities in identifying quantitative-indicators of~ maintenance performance and to proceed with the development and validation of a " maintenance effectiveness indicator" based on NPRDS data. These NRC l

acti.vities are an unnecessary duplication of previous industry (and NRC staff) work and. current industry initiatives and represent another area where NRC t

emphasis on specific indicators can lead to undesirable actions by utilities.

For example, it was noted recently at a nuclear station that emphasis by the NRC region on reducing the backlog of maintenance work orders resulted in-station personnel being reluctant to submit work requests on identified defi-ciencies. As_a result, the INP0 evaluation team found that an exceptionally large percentage of materiel deficiencies identified by the team were not'in the work order control system. As another example, excessive NRC focus on equipment reliability,_as measured by NPRDS failure reporting, will tend to penalize the most conscientious reporters and could inhibit utility reporting of this.important reliability data.

The industry-developed set of overall performance indicators currently reflects maintenance performance. A nuclear plant cannot achieve substantial progress and consistent performance as measured by this set of indicators without having an effective maintenance program.

In addition to the develop-ment of these overall performance indicators, INP0 worked with the industry to examine ne feasibility of defining other quantitative indicators of maintenance performance that could be mutually agreed upon and shared among utilities. Some

. items (such as preventive maintenance overdue, corrective maintenance or work order-backlog, maintenance overtime hours, etc.) have been tried on a pilot basis.

INP0 and utilities have expended substantial resources in defining and redefining these indicators, collecting and trending data, and correlating this

_ data with maintenance performance as assessed by INP0 evaluation teams, the overall performance indicators, and NRC inspections (SALP).

From this effort, we have concluded the following (which has been shared with the NRC staff):

o The other indicators do not correlate well with maintenance performance as determined by site visits (visits by both NRC and INP0).

l o Some potential indicators cannot be defined in a manner that 3

l facilitates consistant industrywide reporting.

o Most of these indicators are readily subject to administrative manipulation (particularly when used for comparison among plants).

o Such indicators are useful only to utility management on a plant-specific basis to help monitor selected maintenance activities.

(We are encouraging and assisting utilities in development and use of internal methods to monitor progress and identify problems in key maintenance areas, including use of the NPRDS data base and other quantitative data.)

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September 8, 1989 Page -

We understand that previous NRC staff work in this area-(as part of the Maintenance Surveillance Program Plan, SECY-85-129. and in support of the recent deliberations on a maintenance rule) has essentially agreed with the' above conclusions regarding the usefulness of other Indicators that Monitor maintenance processes.

In summary, experience has demonstrated that maintenance performance is

'best monitored-by the industry set of overall performance indicators or by site visits.

Further, while other quantitative indicators of' maintenance can be 't useful management tool on a plant-specific basis, they are not

" performance indicators" per se, and they aro not suitable for use by outside organizations to measure or compare the quality of maintenance at various sites. Because maintenance has such a broad impact on plant performance, the focus for monitoring maintenance effectiveness should be on the results of on-site inspections and the industry set of overall performance indicators, and not on any detailed maintenance-indicators or even on a single overall performance indicator, such as scrams or. equivalent availability.

As a related matter, the recent strong focus by the NRC on performance indicators has led some state safety regulators to develop an interest in the indicators.

In many cases these personnel are interacting directly with the plants on this matter.

In addition, economic regulators are bacoming involved in performance indicators. Several are considering or have initiated schemes whereby the utility rate of return is tied to achievement of specific performance indicator values. Our view is that these activities undermine utility line management authority and ultimately have an adverse impact on nuclear-safety. We are aware-that the NRC staff and the Commission are periodically monitoring this area and share these same concerns.

in view of all the above considerations, and principally with respect to the potential nuclear safety consequences, we urge you to substantially 3

reshape the NRC's use of performance indicators.

In this regard, the following actions are recommended:

1.

Recognize and encourage the use of the industry's internationally agreed upon set of overall performance indicators. Adopt this set of e

performance indicators for appropriate monitoring of industry and utility progress by NRC senior management.

Discontinue using performance indicator definitions that are similar to (but not L

identical to) the industry performance indicators.

2.

Refrain from emphasizing the number of reactor scrams. Discontinue tracking ard publishing the number of manual scrams.

3.

Discontinue using other quantitative indicators in a manner that drives nuclear utilities to manage the indicators and thus to take actions that can be adverse to plant safety and reliability.

4.

Discontinue attempts to define other maintenance indicators. Avoid use of a " maintenance effectiveness indicator" based on NPRDS data for regulatory action.

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Septemper.8, 1989.

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Review and strengthon the guidance"in NRC Announcemer.

h. 30 and hold-

. the NRC ttaff accountable for adhering to its guidance. SL cifically -

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eliminate:.01.1 reference to performance indicators in-SA'P. reports.

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Encourage state safety:anj economic regulators to adhere to the.prin-

,ky ciples outlined in this letter and Announcement No. 30.. Continue to-t use th RC's-authority under the Atomic Energy Act'to discourage-using t~rforman e. indicators to put pressure on utility personnel in a

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r manner that can be counterproductive to public healch and ssfety..

We firmly believe that an NRC approach'to use'of-performance indica' tors' ds outlined, coupied with ongoing INP0 and industry initiatives in this impor--

. tant. area,;best serves our mutual! objectives.and is in the best interest of-

• the public.

NRC senior manage & nt would have the benefit of the insight-that

_ performance indicators provide. But utility line inanagement use of.quantita-tive indicators to achieve better overall plant performance would'not be o

undermined. More' importantly, regulatory and other outside pressure at the plant staffz and working level, and thus the potential for a,nonconservative-safety action by plant personnel could be avoided.-

Sincerely.

O g

.Zack T. Pate President s

ZTN1'ar 1

' Attach'aents (as stated above) cc/w: Chairman Kenneth'A. Carr Commissioner J ees R. Curtiss.

Commissioner inomas M. Roberts 1

Commissioner Kenneth C. Rogers

- Members of the' Advisory Con'mittes on Reactcc Safeguards

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ATTACHMENT li T y, y

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HISTORY OF THE INDUSTRY'S DEVELOPMENT AND USE'0F' PERFORMANCE INDICATORS-

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'First.CEO Workshop ' Pat Haggerty, a member of,the May 1980, Kemeriy Commission and:INP0's Advisory Council, pointed out the'need to measure industry progress:.

y "I simply would not ba satisfied, if'I were you, until,there.is an' adequate, quantita-tive' measure of the status'and progress of

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~ the entire. industry and of each ' utility within it."

October 1982 CE0' Workshop - INP0 President discussed! nuclear C

operations parameters that a CEO could monitor. A set of such parameters was provided to'the partici-pants and discussed as part of workshop activities.

lNovemoer 1982'

.INP0 President directed the INP0 staff to develop N

a coordinated plan to collect, assess, and trend 2

industry performance in selected areas, s

' January 1983 INP0' established 'a Data Collection Task Force to define a package of data to be collected and analyzed to assess and trend industry performance.

o April 1983 The Data Collection Task Force recommended data to be collected starting with the third round of INP0 evaluations.

It was anticipated that it would take approximately 18 months (one evaluation cycle) to visit each plant and collect baseline data.

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ATTACHMENTf1i

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<May1983l Appendix A of INP0's Institutional' Plan describes.

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INP0's role in: collecting and. trending nuclear.

' station performance data.

x August 19831 Preliminary _INPO Good Practice OA-102, " Performance-

. Monitoring Management Information,".was distribut'ed.-

This good practice'provided directions and procedural

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guidance for utilities'on how to implement a comprehensive and effective performance monitoring

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program. An example set of performance indicators.

j and graphical, presentations was included.

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September 1983

.CEO Workshop - A package containing the definitions, descriptions,= and historic data.for potential perfor-mance. indicators was provided to the participants.

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Performance monitoring and the use of performance g

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indicators were the subjects of a panel discussion.

June 1984.'

Final Good Practice OA-102, " Performance-Monitoring Management Information" was published.

/ July _1984 In a letter to NRC Executive Director for Operations.

t 1

l.

(ED0), INP0 President expressed concern about p

erroneous scram data released publicly by the NRC and the difficulties this had caused.

L.

August 1984 The-INP0 Advisory Council completed an in-depth.

i review of activities relating to performance indica-tors and data gathering.

The-subject'had been under continuing and active council consideration'since February 1980.

October 1984 INP0 President, in a speech to AIF, stated that INP0, in concert with the industry, had developed selected performance indicators to help executives and 4 9/8/89

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ATTACHMENT:1

,W, a-managers track performance. Also discussed was the s industry quest for excellence by using five example l

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performance indicators. -Industry progress in these:

five indicators was noted, l

i

November 1984L CEO Workshop - INP0's' Chairman presented current and.

Ik j

j

. historic information on six "overall" performance indicators.

In addition, development of the L'

- performance indicator program received considerable

~

attention, especially in trending year-to-year

. performance.

INP0 President, in summarizing the workshop, noted that:the industry needs a quantitative record of improving performance.

.INP0 issued a' report, " Nuclear Power Plant Oper-ational Data," that was used in conjunction with CEO

-r workshop. This report included 45 parameters that reflected industrywide performance and_ provided each l

utility with specific data.on their plants. The report included yearly data 'from various sources through 1983 and data collected during evaluations for.one evaluation cycle.

~

December 1984

-An INP0 letter to CE0s' requested that utilities

- t develop goals for those indicators listed as "over-all" indicators in the November 1984 report, " Nuclear

. Power Plant Operational Data."

January ~1985-Development of industry long-term goals was discussed s

by the INP0 Board of Directors.

An action plan for implementation was developed.

January 1985-Three ad hoc review groups comprised of (1) utility representatives (selected to represent size, loca-tion, plant type, and the INP0 Industry Review

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Groups)', '(2) the: senior nuclear ~ executive from 'each U.S. nuclear ^ steam system supplier (NSSS)L and '(3),

a independent ~ experts-(Joe Hendrie, Tom Pigford, Norm Rasmussen, Forrest Remick)-began work'in concert with.

[

INPO to develop a uniform set of "overall"-

performance. indicators and-long-term goals as y}

imechanisms to support: achievement of:" benchmarks of-excellence."

-+

l February 1985:

-INPO President briefed the Commission on the major areas in which INP0 is involved including performance monitoring activities and the program for establishing long-term goals for the industry.

7 March:1985-INP0's.1984 Annual Report discussed performance

.f

. indicators and goal setting.

Six industrywide performance indicators were displayed to show his-j toric performance, l

l JApri111985

'Ad hoc utility group and NSSS group-(including a j

representative from EPRI) met separately at INP0 to

' consider candidate indicators and possible long-term-goals and. to review domestic and international r

quantitative performance.

DuHng a visit to INP0, the ACRS chairman and four members were briefed on the efforts to date on-performance indicators and the development of long-term goals for the industry.

'May 1985 The concept of using performance indicators and data to assist the utilities in establishing long-term goals was added to Appendix A of INP0's Institutional Plan.

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j.:

g-Ad hoc group of independent experts! met'at.INP0 to

- review efforts to select overall performance indica-tors and establish long-term goals.

INP0 updated the-ad hoc" utility group.and sought input; from;all of its I

i

established review and ' advisory mechanisms: including

[

- the Advisory Council, supplier and international-

advisorygcommittees, and technical' division Industry 3

Review Groups.-

INP0. issued a brochure, " Performance Indicators for the'U.S. Nuclear Utility Industry," showing historic

_ performance;for nine indicators through the end of 1984.

June 1985-In testimony to the Senate Subcommittee on Nuclear.

- Regulation, INP0 President discussed nine "overall" performance indicators and provided industry'perfor-mance.and progress in these areas.

INP0 issued " Nuclear Power Plant Operational Data Update," which provided updates-for 19-quantitative L

indicators provided in the November 1984 report.

l

-July 1985.

Final proposed package on overall performance indica-tors and long-term goals was mailed to the ad hoc review groups and the INP0 Board of Dinctors for review and comment. The proposal introduced the concept of INP0 providing background information to assist utilities in setting long-term goals and then l'

determining industrywide goals based on individual utility goals.

On July 11, 1985, the Board approved 1

the proposed approach.

L y

An INP0 letter to CE0s proposed a uniform set of

)

"overall" performance indicators and provided 9/8/89 w

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ATTACHMENT l10 l

yX-L information and guidance'on' setting long-term 6

' performance goals. The letter emphasized the'need to' H

- use.a-set of overall: performance indicators rather j

than a' narrow set or one indicator.

INPO also =

requested that. preliminary 1986;.and long-term (1990).

- goals be. set-for each nuclear unit.in preparation for-discussions at the 1985 CEO workshop.. Tl.4 1 cept'ofi

" baseline goals"--goals that_ most plants she., be able to achieve over time--was ' introduced for the'

. following indicators:

7 s

o' - equivalent availability factor

- o.: unplanned automatic setams while critical-o collective radiation exposure o volume of low-level solid-radioactive waste-o industrial safety (lost time accident rate)'

i p,

In a letter to NRC EDO, INP0 President expressed concern about the impact of increasing NRC pressure

-on the industry to reduce scrams. He. stressed that, i

"we cannot afford to have.any operator' feel concern L-over initiating a scram that he thinks is. warranted."

t August 1985 Quarterly data reporting by utilities was initiated.

All operating plants were requested to submit' data' l

directly to INP0 starting from January 1985.

Detailed maintenance indicator data and data neces-sary to support the industry long-term goals program l,

were incorporated into data collection efforts.

> November 1985 CEO Workshop - The workshop focused on the industry initiative to develop and use performance indicators and long-term goals to monitor and-improve perfor-mance of their nuclear units. The 10 "overall" y

performance indicators were presented and utilities

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ATTACHMENT'l:

N Q) were requested to ' establish long. term goals for as -

.many of the "overall" performance. indicators as hh feasible.

INP0 President traced the development of'

^

th'e' performance indicator effort since:the first'CEO-Workshop and discussed goals related to performance-

[

indicators.

In a panel ~ discussion, members of-the'-

l L.,

Advisory Council _ also ' stressed 'the development.'and.-

7

' implementation of_ performance' indicators and E"

long-term goals.

Utilities were requested to provide 1986 and five-~

December'1985' year (1990) goals. Utilities'were provided data e

sheets showing-their plant data and industry values for key _ parameters included in the industry long-term goals effort. -

l t

~M' arch 1986 INP0's Annual Report entitled " Focus on Performance,"

concentrated on performance indicators and their application. Nine industrywide performance-indica-

[

tors were displayed to show historic performance.

j L

J

. pril 1986' INP0 issued " Industry Nuclear Power Plant Performance -

y i

l Indicator Report" with 32 parameters and' data through

)'

1985. This report was based on the data provided in the quarterly data reports and selected historical i

data from previous reports.

May 1986 In a presentation to the Commission, INP0 President provided information on performance indicators and goals and discussed how these efforts are imperative to the improvement of plant safety and reliability performance. The development and use of "overall" indicators and long-term goals was discussed in the contert of performance data that had been collected through the end of 1985. 9/8/89

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Juneil986.

INP0. issued annual brochure " Performance Indicators -

for the U.S. Nuclear. Utility ~ Industry," which showed j

historic performance for nine in'dicators through the-l

~

~

~

end. of.1985.

5 u

. An INPO letter to CE0s updated industry on develop-ment of long-term goals and provided industry x

averages and histograms' related to long-term g'oals..

~

y In testimony to the' Senate Committee on Energy and j

- Natural Resource's', INP0 President discussed INP0's m

efforts to

promote excellence in the industry using performance indicators to provice a mearure of--

1

-progress.

An INP0 letter to international participants encour-:

aged them to set long-term goals and to adopt as. much I

of the INP0 program relating to performance moni-r toring as possible.

' August l1986-An'INP0 letter to utility oxecutive points of contact

?

provided an update on the development of'the safety

. system unavailability performance indicator and n

-transmitted Safety System Unavailability Monitoring,-

(INP086-021).. Informed utilities of pilot program to be completed by mid-1987.

I September:1986 An INP0 letter to utility executive points of contact i

provided information on industry efforts to monitor and improve nuclear fuel integrity and noted INP0's efforts to refine the fuel reliability indicator to compensate for the effects of past fuel failures and L-allow more meaningful unit-to-unit comparisons, n - <.

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',[0'ctober1986:

-INP0 issued "Industrywide Nuclear Power Plant Perfor--

I

.mance Indicators', 1986 Mid-year _ Report" with results' for 28 indicators;through the secnnd quarter of 1986.-

'I i

' An INP0. letter to the: ad~ hoc utility' group,? NSSS j

group, and independent. expert group. involved inLthe 1

development' of long-term goalsitequested comments ~ on.

several' alternative definitions for the fuel

{

rel i abil i ty and thermal, performance < i ndi cators. Also.

providedanupdateonsafetysystemunavailability.

~

November!!986 In a: letter to NRC Chairman,-INP0 Preside'nt expressed INP0's concerns' about the potential adverse consequences of the adoption of a formal-performance n

indicator program ~by the NRC.

-i y,

CEO Conference - Performance indicator results and long-term goals were emphasized in several sessions.

Possible alternative definitions for the' fuel reli-i ability ar,d thermal performance indicators were presented.

M December 1986

. After incorporating comments from the long-term goal L

review groups and discussion at the CEO Conference, revised ~ definitions for the fuel reliability and thermal' performance indicators were transmitted to INP0 Industry Review Groups for review and comment.

L.

l An INP0 letter to CE0s requested that utilities provide their 1987 overall performance indicator j

goals for operating units to INF0.

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~ ATTACHMENT I ft In~ aLletter to: IAEA Nuclear: Safety Director,- INP0_-

1

President urged IAEA'not:to adopt a proposed

performance _ indicator assessment process. He urged g: -

-that quantitati.ve: indicators;be preserved as a utility management tool =and offered to share generic V,

overall-performance _ indicator data, i,

. February 1987 After resolution of Industry _ Review Group comments, r

revised definitior.s for the _ fuel reliability and

. thermal performance indicators were transmitted to utility executive points-of contact along with revised quarterly data report forms.

March 1987 INP0's Annual. Report ' included a foldout section with-.

performance data from 1980 to 1986.

Industrywide goals'for 1990 based on individual utility goals were displayed on the annual trend graphs.

IApril 1987-The 1986 Year-end Report on Industrywide Nuclear Power Plant Performance Indicators was issued to member utilities and international / supplier partici-pants.

A detailed description of the overall plant.perfor-mance indicators was developed in preparation for-inviting INP0's-international participants to begin submitting performance indicator data.

June 1987 An analysis of possible approaches for the safety-system unavailability performance indicator was completed and three viable approaches were found.

The INP0 Analysis and Engineering Industry Review Group was briefed on the results.

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= Aisgustl1987.

--Information on the status of:the Safety System q

4 Perfo'rmance' indicator was luailed to.the industry ad.

hoc. review' groups on performance indicators, the'INPO

<i Industry Review Groups,;the Supplier Participant j

s

. Advisory Committee, and the utility participants-in-the pilot program for safety system unavailability lf monitoring.

i September.1987-The-1987 mid-year Industrywide Nuclear Power Plant l

-Performance Indicators report was mailed to the-industry.

October 1987-

'The mid-year performance indicator results and the-l'

. status of development of the safety system' l

j performance indicator were presented..at the Supplier U

Participant Advisory Committee meeting.

l 1 August-1987, Preparation began on a year-end mailing to utilities to provide clarifications and additions to the 3

industry's. performance indicator definitions and

'l reporting instructions. This included reporting j

. guidance for the: safety system performance indicator, j

and associated revisions to-the data collection form.

.' November 1987 A final definition and reporting instructions were 1

developed for the safety. system performance indica-l tor, taking-into account comments from the industry 3

ad hoc review groups on performance indicators and j

other reviewing organizations.

~t December 1987 A revised quarterly plant performance indicator data reporting form (Revision 4) and detailed descriptions of the overall plant performance indicators and the other indicators were sent to the utility executive points of contact. The data collection form was 9/8/89 4

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revised to include the new' safety system performance; indicator and-to reflect revisions, based on utility; j

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" comments,to'certainmaintenance, chemistry land' y,3 radiation protection indicators.

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-February 1988

- A. letter was sent to the international points of, scontact providing detailed descriptions of-the

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' industry's.overall performance-indicators-.

March:1988-LThe-1987; year-end report; "Industrywide Nuclear Power.

n.

. Plant Performance Indicators," was sentLto the a

' industry..INP0. discontinued presentation of trend

,7y

~

, graphs for the.other indicators because the-aggregation of thisidata was generally:not-a meaningful indicator: of industrywide' performance trends.

a Computer software development be'gan for an interna-tional performance indicator data base.

Inter.-

national performance indicator data (covering from 3 j

.to 8 indicators) for 1987 was-received from Brazil, 1:

Canada, France, Japan, Korea, Taiwan, Spain,-Sweden,

and the United ~ Kingdom. An international' performance indicator report was planned for mid-1588.

.,a

. April 11988 Preliminary international performance indicator data and proposed formats for an international performance indicator report were prepared and presented at a 1

meeting of the International Participant Advisory Committee. Software development proceeded for data y

entry and for data summaries, graphics, and reports.

Work began to recommend overall performance indicator 6

definitions for use after 1990. As a part of this effort, a letter was sent to Electricite de France 9/8/89 E

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(EDF) proposing that INP0 work with~EDF and

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International Union of Producers'and-Distributors of -

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- Electrical-Energy (UNIPEDE) to develop a uniform setL t

'of overall performance indicators for both INP0 and d

UNIPEDE member utilities.

1 i

- A-letter from INP0 President to the Director Genera" h-.

of the International Atomic ~ Energy Agency requested -

l f

_ support in achieving. optimum worldwide use:of'perfor-

~ mance in'dicators and expressed concern about IAEA use 3

N.

- of performance indicators during a recent OSART mw >,

visit.'

A letter from INP0 to IAEA expressed continued concerns on IAEA's plans-to conduct a workshop on the-Operational Safety Indicators Program since-significant international progress had been made by I

the ' joint efforts of INP0 and UNIPEDE.

May 1988.

A detailed action plan was developed for re-examining the plant performance indicator and long-term goals program for use beyond 1990. As part of this effort, 6

each INP0 Group Vice. President was. requested to review the current overall indicetors for possible I

revision, taking into account the-desire to develop a uniform set of overall performance indicators for worldwide use that would be consistent with those proposed by UNIPEDE.

Work began in May on a draft international perfor-mance indicator report.

Each international member of INP0 was contacted to ensure that the data requested was complete and to identify any inconsistencies with the INP0 definitions. 9/8/89

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b A' meeting was held at' INP0Lwith representatives' ofl 0

June ~.19881 j

IAEA to discuss the agency's plans to hold _ a workshop '

h on development.of performance indicators. -IAEA j

Lagreed to recognize,_ support, and not_ duplicate the.

~

work'done bylINP0 and UNIPEDE.on overall performance 4

indicators.

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' June'1988-A letter wcs sent to all utility CE0s discussing the economic benefits achieved by improvement in thei industry overall performance -indicators. - Industry i

improvements _in unplanned automatic' scrams,' thermal-a i

performance, and volume < of low-level solid radioactive waste had produced'an.industrywide:

estimated savings of_$900.million annually.

-Potential. economic benefits from progress..in 'other -

perfor. nance indicators were also-noted. The overall l,

performance indicators therefore strike a-reasonable 4

L balance' for monitoring economic' as' well as safety' performance.

A new industry ad hoc review group on performance indicators and long-term goals was selected to advise INP0 on the use of performance-indicators and goals-after 1990. The group _ included members from the s

INP0 Industry Review Groups, Advisory Council, k

International and Supplier Participant Advisory Committee, Academy Council, _ World Association of

^

Nuclear Operators (WANO), NUMARC, EPRI, UNIPEDE, and U.S. utilities.

l f: i July 1988 The draft report, " International Nuclear Power Plant Performance Indicators," was sent to International Participant Advisory Committee members for review and comment. The report presented overall performance indicator data for 12 countries. 9/8/89 m

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ATTACHMENT-l' 7-H.

p l August 1988 A meeting of.the 'newLindustry ad hoc review group _ on.

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performance'.indicaters and long-term' goals was - held --

at-INPO. The purpose'of.the meeting _was to'obtain Lindustry comments-and_ suggestions on performance t

indicators. and approaches to goal setting to be _used' after 1990.-

September 198t..

Revised propsals for performance. indicctor defini-tions. and an-' approach for long-term goals. for. use-beyond 1990 were n' ail' d> for comment to the INP0.

e 7

Indcstry Review Groups, Snpplier Participant Advisory Committee, International-Participant Advisory

. Committee, UNIPEDE,'and an industry ad hoc review group. The proposals were revised based on-comments

)

and. suggestions from.the industry ad hoc review group meeting held at INPO in August 1988.

I The 1988 mid-year performance indicator report, "Industrywide Nuclear Power Plant' Performance Indica-3 tors,".was issued.

i INP0 attended an IAEA workshop on " Approaches to Quantitative Assessment of Operational Safety Perfor--

mance of Nuclear Power Plants." As a result of I

l discussions at the workshop, participants recommended that IAEA' encourage utilities to use a common set of perfornance indicators being developed by INP0 and UNIPEDE.

i October 1988 As part of the reevaluation of the plant performance L

indicator and long-term goals program for use beyond 1990, comments on proposed indicator definitions and i

L approaches to goal setting were obtained at meetings of the INP0 Industry Review Groups and the Supplier L

Participant Advisory Committee.

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L November'1988!

'The' safety system performance indicator detailed

' description was' updated for'use in 1989'and mailed'to'.

[

I utilities. "he indicator was revised:to include; component ur,4vailability due to all' causes.

~

. As part of the reevaluation of the plant performance indicator and long-term goals program for use beyond 1990, comments on proposed indicator definitions and-f approaches to goal setting were obtained at the; International Participant Advisory Committee meeting.

q December 1988 An' updated version of the Detailed Description of j

Overall Performance Indicators and'0ther Indicators,-

and a revised data n11ection form for use in'1989 i

were mailed tc, the utilities.

Several other maintenance indicators were discontinued because they were generally not representative.of maintenance performance.

January 1989.

A meeting was held with the Chairmen of groups of UNIPEDE-experts to develop final definitinns of

?

overall' performance indicators for use-after 1990.

March 1989-A draft proposal-of overall. performance indicator l

definitions, for use beginning in'1990, was mailed for final review to the industry ad hoc review group, the INP0 Analysis and. Engineering ~. Industry Review Group, and UNIPEDE. The proposed indicator definitions waro developed through the combined efforts of INP0, UNIPEDE, and their respective D

members and participants.

Copies of the proposed indicator definitions were also sent for information i

to the chairman of the WAN0 steering committee, IAEA, and the North American Electric Reliability Council.

l 9/8/89

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g ATTACHMENT industrial safety ' lost. time-accident rate 3

The'1988 year-end' report, "Industrywide Nuclear. Power ~

4

- Plant. Performance Indicatcrs," was sent toJINP0 members and participant.

i LMay1989-The first Governing Board Meeting of WANO adopted the t

INP0/UNIPEDE proposal _as a first draft of WAN0 4

performance indicators'and requested the Atlanta Center of WAN0 to take the lead in _ assembling a final document to be provided to WAN0 for final review and acceptance.

The draft report, " International Nuclear Power Plant Performance Indicators, 1988 Year-end Report" was provided for review and comment to members of the International Participant Advisory Committee and the international points-of-contact.

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eg' l July l1989'

• LThe 1988 year-end report " International Nuclear Power F

.P1 ant Performance Indicators" was mailed'to all INP0

~

members and participants.'- The report-provided data p

d for-the industry's overall performance indicators for the U.S. and 179' operating units in 12_ international

-l

. participant countries.

f Present' The' performance. indicator and goals programs hase l

achieved a reasonable _ level of maturity.

o. Ten overall performance indicators, are now monitored ~and trended for the industry by INP0 on-ra quarterly basis.

q o' There is participation from all. of INP0's interna--

tional participants ~

o There is 100 percent support and participation

, from the U.S. nuclear industry, o Industrywide recognition of a set of overall performance indicators has-been achieved.

o A common set of ten overall performance indicators has been internationally agreed upon. Mar.y of INP0's international participants are using the overall performance indicators and some. have a

established long-term performance goals.

o Long-term goals for most of the overall indicators-l have been established by U.S. utilities for each p

operating unit.

o The average of 1990 goals established by utilities f

is better than the recommended baseline in every

Case, o Utilities are using data, trends, goals, and other information in monitoring and improving plant performance.

l' L

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-ATTACHMENT'2-o l

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HISTORY OF:THE-NRC'S INVOLVEMENT IN PERFORMANCE !NDICATORS I uly.16 1984 Letter from President of INP0 to NRC Executive J

1 ;:

R Director for Operations.(ED0).

INP0 expressed concern about erroneous scram data released )ublicly by the NRC and the.

difficulties-t11s had caused.

September 1984.

R. C. DeYoung memo to Denton, Stello, and NRC-Regional Administrators Proposed.to replace " current-requirement.for a QA Program Description with a requirement for tracking of_ performance indicators in key

- functional' areas." ' As benefits of.this y

proposal, the memo stated "these changes should i

serve-to identify those plants above and below-I the industry average and so allow the NRC to better' allocate its inspection resources. More importantly, it will require licensees to identify and trend the most ~significant indicators of plant performance and give NRC an objective method for. measuring-utility management. effectiveness." Example given was a utility's' effort' based on INP0 Good: Practice

0A-102 July 10, 1985 Letter from President of INP0 to EDO -(see

-Appendix A):

g Informed the NRC that INP0 is seeing examples of increasing NRC pressure on the industry to a

L reduce. scrams. Noted that it is not in the best interest of reactor safety to pressure utilities on scrams. Warned that such NRC use 1

n of scram information could result in i

nonconservative or incorrect decision by f i operating personnel.

l February 24, 1986 Letter from Utility CE0 to President of INP0

_j CEO discussed recent meeting with NRC Regional r

Adininistrator. Administrator told CEO that his l

Region was tracking the performance of nuclear power plants under fourteen different criteria

[ including weighting factors for different types of unusual events). The CEO also told u,

L INP0 that NRC is reducing number of NRC I'

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inspections'at certain plants in the Region' and-that there would not be more inspections unless-brought-about by an increase in personnel

.a t,

errors or swams.-

j 4

l May5J1986-

' SECY-86-144;LPERFORMANCE INDICATORS w

,4'

- Stated that.the-staff was~re'cently asked to submit a proposal to Commission for approval.

Noted that several-parts' of the. staff "are -

j

- using and developing performance indicators for.

R

.various purposes." SECY.' asked for Commission

,m:

approval of plan which includes' establishment of interoffice task ~ group, development: of a trial -indicator program, and a final proposal

- by September 1986...SECY' stated that-interoffice group will discuss coordination ~-

1 with-industry-groups such as INP0.

LJune11,1986 Meeting of NRC' task group on performance indicators.with INP0 representative in attendance INP0 employee in trip report-stated "it appears i

that the NRC is undertaking-a massive effort to reinvent-the; (performance. indicator) wheel. - I -

heard many questions being asked that INP0 has struggled with for a long-time and finally resolved."

At'the meeting, it was-pointed.out that the industry would.be reluctant to accept these

. indicators because of the ; redundancy cf the effort with industry l. efforts.

4 July 7, 1986

- Letter from E.L. Jordan-(NRC) to' attendees at June 11 meeting Reported that task group has selected 17 V

indicators for the trial program.

1

' August 15, 1986 NRC/INP0 meeting on performance indicators The definition of each INP0 and NRC indicator was discussed.

There were seven [of 17]

indicators common to INP0 and NRC programs.

There were differences in definitions of some indicators.

, 9/8/89 1

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.INP0 senior management reviewed INP0fs concerns.

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- with NRC use of-indicators.

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• September)12,-1986:

Telephone conversation between-.INP0 and NRC-j Q

. staff NRC: informed INPO that eigh't of 17 indicators L

discussed at August'15,:1986 meeting had been-q

. selected for trial'use by NRC. NRC would monitor trends-in the~elght indicators they had:

chosen and provide these trends to the-regions o%

- and NRC top management. The regions would.be

,l

- asked to explain adverse trends to NRC

(

. management.

e-September:15,s.1986-NRC meeting on performance indicators with-INP0-representative present-1 NRC stated that the trial program had been conducted with einht indicators.being chosen.

?

Further, the intended use of the program was i

stated' to be to provide; quarterly-indicator i

g reports to the regions and to identify-outliers

[

in performance.

s

. October 28,L1986

- SECV-86-317; PERFORMANCE. INDICATORS

)

The ED0 submitted staff's final plan on performance indicators-for approval:by the l

Commission. Plan identified eight performance E

indicators to be tracked and outlined an action plan to produce the first quarterly report on indicators by February 1987.

l November.5, 1986 Letter from President of INP0 to Chairman NRC 4"

(see. Appendix B)

Letter requested the Commission not to adopt a separate set of performance indicators for use in a regulatory sense.

INP0 offered to share plant-specific data on industry overall performance indicators.

Letter also reiterated INP0's safety concerns with NRC focus on indicators leading to nonconservative action by lt plant personr.ol.

November 7, 1986 NRC Comnissioner meeting NRC staff presented performance indicator l

program to the Commissioners.

Following the

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ATTACHMENT 2 o.,

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n:eeting the Commissioners; voted to approve the 1

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' staff. plan 7 (SECY-86-317).

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November' 19,'1986, INP0/NRC meeting.on performance indicators Various details of the~ NRC's final; program were.

at discussed with the.INP0 staff including:a detailed review of the NRC' indicators and how'-

f' i

the NRC planned to use the indicators.in'-

nanitoring plant performance. The NRC offered q

a memorandum of agreement'with INP0. This-nfa agreement. requested that INP0 and the'NRC' share C

, plant data so that burden on the industry would not be increased by multiple data collection a

s

efforts. The proposed agreement was not clear

[enough on how the NRC would use.the data shared.

INP0 offered to prepare a revised agreement.for NRC/INP0 discussion.

Msrch26;1987 Meeting between INP0 President and Chairman of

~NRC-

[

i Discussed NRC use of performance indicators at

. length.

l,

April '--' May, '1987.

Numerous interactions between INP0 and NRC-

.o staff Attempted to develop an appendix to the a

NRC/INP0 Memorandum of Agreement which would describe NRC/INP0 use.of performance indica-tors.

L

May17, 1987 SECY-87-117; C0 ORDINATION PLAN FOR NRC/INP0 USE OF. PERFORMANCE. INDICATORS The ED3 requested Commission approval of the-3 I-proposed appendix to the NRC/INP0 Memorandum of Agreement.

(Approval was never obtained.)

May 13, 1987-INP0 briefing of NRC Commissioners During periodic briefing of NRC Commissioners by INP0 senior managers, NRC Chairman described how he saw the NRC using performance indicators.

INSIDE NRC quoted the Chairman:

"I think that they [ performance indicators] can be used by us as a tool in regulation... to trigger inspections and the further analyses."

The President of INP0 stated that he is in 9/8/89

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'ATT CHMENT 2 f4

$1o'se ph'ilosophical agreement with the Chairman.

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except;th~at the indicators are best used as'a management. tool and should_ not be used;, for -

example, in SALP ratings.

^

May 14' 1987:

' Letter.from President of INP0 to Chairman of NRC-(see Appendix C)-

Asked the NRC to refrain from tracking the performance. indicators that the: industry was q

usingi INPO-indicated willingness-to work out-1

. agreement with NRC staff on performance:

j indicators that assured pressure would not'be' a

put-on. operators to make nonconservative-j actions and that line utility managementJ q

prerogatives were preserved.. Reemphasized'that y.

'best role for NRC was to monitor and encourage strong industry program that was in place and progressing.

q l

l May.21, 1987 Letter-from President of INP0 to Chairman of NRC Follow-up letter to May 14 letter. Pointed out

?

v J

that NRC's current course of action in 1

performance indicators tended to undermine INP0's ability to undertake.new initiatives.

Stated:"An NRC initiative in an area where INP0

+

had taken aggressive action, and dhere industry involvement and progress is clearly impressive,-

-l has.the certain potential to cause utilities to

-l be less receptive and less aggressive in responding to future INP0 initiatives."

.l

s

-June 9, 1987 NRC staff briefing of the Commission 1.

The staff briefed the Commission on the i

performance indicator program. The program now included seven indicators'of which four were also industry indicators. Staff planned to u

expand the program to include risk basing, L

maintenance indicators, training indicators, H

administrative performance and others, u

August 13, 1987 SECY-87-207; POLICY FOR USE OF PERFORMANCE L

INDICATORS L

L The E00 requested the Commission to review the

?

staff's policy for use of performance l'

indicators.

l D

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ATTACHMENT'2-4 q

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December.2, 1987:

Commission-response'to,SECY-87-207~

1

' Approved issuance of'SECY-87-207 subject'to four major revisions which stress that:the

f

' indicators must be used by NRC senior manage-4 ment only and must be used carefully.

~ February 5, 1988 NRC Announcement No,'30}

Promulgated NRC-employee. guidance on the use of ~

' performance indicators.

Relative to INP0's earlier concerns and the 4

-draft appendix to the NRC/INP0 Memorendum of i

t Agreement, the guidance' addressed several key points but= fell short in several areas:-

o not enough_ emphasis on preserving use of i

F indicators as a utility line-management i

tool o no explicit recognition that the use of certain indicators such as unplanned scrams and forced outage rate isL particularly sensitive wi.th respect to pressure on the plant staff

~

.o emphasized use of indicators' as a tool by senior NRC management but did not specifically mention that interactions with a utility on performance indicators l

should be also at senior management level L

g Numerous interactions between NRC and INP0 January 1988 present staffs Ongoing discussions occurred on the draft appendix to the NRC/INP0 Memorandum of Agreement on performance indicators and on NRC's proposed maintenance; indicators.

INP0 attempted to include sufficient principles for proper use along the lines discussed in Announcement 30.

1, March-1988 Meeting with NRC staff (NRR, RES, AE0D)

INP0 and NRC staff exchanged information ca the development of NRC's safety system performs e indicator.

INP0 expressed concerns that this

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~ NRC.. effort' duplicated andl undermined-considerable industry effort in ~ safety system:

monitoring which began:in:1985 and was' implemented in January of 1988.. Also,cINP0' L

reiterated concern with NRC using performance:

indicators'in.SALP_ ratings.

}

s

' Aprilel5,,1988[

Letter from INP0 to NRC'.

j

+

a Data for four of-the industry overall perfor-j" mance indicators (unplanned. automatic' scrams while critical, unplanned ; safety. system

.actuations, ' forced outage rate,: and collective radiation exposure) for the period.'1985>through; 1987. was provided to NRC.

August'18,51989 Letter from INP0 toLNRC.(see Appendix D) 4

Provided comments on draft.AE0D report on industry: scram reduction.. Stated that'INP0's' primary ~ concern with the> report wastits j

exclusive focus on.a single indicator (scrams)-

and the inclusion of manual scrams. Tone of '

report emphasized continued scram reduction efforts without consideration of negative effects.

3 1

0ctober 7,--1988.

SECY-88-289; PRELIMINARY RESULTS OF THE TRIAL PROGRAM ON MAINTENANCE PERFORMANCE' INDICATORS.

J l:

The ED0 informed the Commission of the prelimi-nary results of the staff's efforts to develop maintenance performance indicators. The'NRC staff concluded' that process indicators' had merit for. plant-specific monitoring and control, but not industry-wide monitoring by NRC. However, th'e use of NPRDS to constructing y

maintenance effectiveness indicators "provided-4 reasonable and encouraging results."

Recommended that the staff-continue to develop-H and validate maintenance effectiveness L

indicators using NPRDS.

n l

'May 18, 1989 Meeting between INP0 and NRC staff i

Differences in published values of common indicators between industry and NRC reports i

were discussed. The differences were largely 4

attributed to different criteria for data l

selection and different rules for exclusion of plants from averaged values. 9/8/89 m

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ATTACHMENT 2<

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O June.26,-19891

.SECY-89-143/COMLZ-89-21;AMENDMENTTC10'CFRD<

.50 RELATED T0 MAINTENANCE OF NUCLFM POWER' PLANTS-

/

The Commission'directhd the staff.to proceed

- with the validation and implementationfof -

maintenance performance indicators on an 3:

expedited basis.

_ July'24,.1989-Meeting at NUMARC l'

NRC, NUMARC, and INP0. staffs met at NUMARC headquarters to' discuss NRC development'of-H maintenance. performance indicators' INP0.

reiterated previous. concerns =and expressed:

-specific concern with NRCis proposed use of the 1

]

NPRDS data base to develop:a maintenance.

i effectiveness' performance indicator: as' follows:-

..o the development and use of performance l

indicators should be preserved as an industry initiative instead of regula-3 tory initiative.

1 o, detailed indicators-(such as mainte-nance indicators) should be kept~at.the.

plant for internal management.use --

experience shows:these indicators,are'

- not particularly 'useful: in providing i

meaningful industry comparisons o monitoring of-plant performance should focus on a set of overall indicators, not on maintenance indicators or individual indicators (like scrams) 1

- o using NPRDS as a source of information for a maintenance effectiveness indica-l' tor may impact reporting of failures to NPRDS h

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A-July: 10,1985.

e 1Mr. William J.-Dircks-Executive Director fori0perations-United States 1 Nuclear Regulatory Commission ?

l Washi ton :D.C.

20555 3

Dear eks:

?

.. We are beginning to'see examples of increasing NRC pressure on the?

--industry to: reduce unnecessary. scrams, especially since Dennis.Wilkinson's

,c-letterito thel industry on this subject in early 1984', a copy. of which was-q

,x L

furnishedfto the NRC. '

Reducing the number of.' unnecessary scrams without (ever) eliminating a necessary scram is?a delicate matter.

At11NPO, we are continuing.to encourage a

H the industry to reduce unnecessary scrams, but we constantly stress the need

. to -manage for excellence.using a broad. set of performance indicators, of which p

.scramiperformance'is.only one.

We also constantly stress to member utilitiese that' in striving' for improved performance against measurable objectives, they?

must; keep these: efforts in-perspective for~ their. operational-'and technical

-i personnel.' For example, in the case of. scrams,nwe cannot afford to have any l

-operator feelf concern.over initiating a scram that he thinks its warranted.

+

k

[

I dounot believe:that it-is in the best interest;of reactor safety for the NRC,:as the regulator, to put pressure on1 utilities: to reduce scrams.

I believe: senior NRC management can encourage. industry progress'in general discussionsprelating to a wide' range of _ performance indicators. But specific 4.

cregulatory programs:or activities that put pressure on the utility to reduce j

' scrams, reduce. forced. outages, or-increase availability could result'in an unconservative. or incorrect decision by personnel involved in: operating a

. nucl ear 1 s tation.

s U

Using quantifiable performance indicators is, in fact, a good example of an area where the industry, with INPO assistance, is making progress, but which is not amenable to the regulatory process.

We have beea working in this

~'

area: for some four years now and are beginning to see some encouraging y

results... A copy of a recent summary we prepared is enclosed.

We will try to a

> manage our activ.ities in this important area to best serve the utilities, the

'l NRC.'and the pub 1.ic.

Your support, along the lines I have discussed, will be

' helpful in ' achieving our mutual objectives.

4 i

Sincerely,

$hhg?6d$t 9

Zack T. Pate president

\\f-ladw

Enclosure

Att

:chment 2 j j j App:;ndix B Institute of i

1 Nuclear Power Operations Suite 1500 1100 Circle 75 Parkway

(

Atlanta. Georgia 30339 Telephone 404 953-3600 1

November 5, 1986 1

The'Honoracle Lando W.

Zech, Jr.

Chairman United States Nuclear Regulatory Commission

-f 1717 H Street, N. W.

Washington, D.C.

20555

Dear Chairman Zech:

The purpose of this letter is to express our views on the use of per'ermance indicators to support improved i

performance of U.S. nuclear power plants.

INPO is prepared L

te cooperate with the NRC in this important area, but we do have concerns over how performance indicators are used.

i In our view, the adoption of a formal performance indicator L

program by the NRC has potential adverse consequences.

As you are awarre, INPO has been working with the industry

)

~

on the development and use of performance indicators for several years, and ws have worked closely with the NRC staff as they have explored the use of such indicators.

Industrywide recognition of a set of ten overall perforn.ance indicators i

has been achieved, and utilities ara using these and other indicators as an aid in monitoring plant performance.

Each i

L U.S. utility with an operating unit has set challenging short and long-term goals for most of the ten overall performance indicators.

In additica, many of INPO's international participants are using these performance indicators and some have established l

long-term performance goals.

We have made considerable i

progress in. arriving at common definitions -- not only in the U.S.,

but internationally for several of our overall indicators.

Experience has shown that NRC focus on a particular issue or panaeter exerts a powerful influence on licensee behavior.

Our concerns about the implication and impact of NRC's use of performance indicatora in a formal regulatory sense can be summarized as follows:

Strong NRC focus on minimizing scrams and safety a.

system actuations or reducing forced outages will rand the wrong message to utility middle management and working level personnel, and could result in a nonconservative decision with serious safety consequences.

This vitally important concern is discussed in more detail in my July 10, 1985 letter to Bill Dircks (Attachment 1).

144 M $6H w

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'Tho H nsrcblo L3ndo W.

Zoch, Jr.

N3vcmber 5, 1986 Page Two b.

Use of performance indicators as a formal regulatory mechanism will lead to utilities placing undue emphasis on " managing the indicators" instead of managing the plant.

l c.

NRC use of a set of indicators that is different.

from those widely recognized and in use throughout the industry can detract from this important industry initiative and the healthy compet. tion to achieve goals for improved performance.

hf letter of July 16, 1984 to Bill Dircks (Attachment 2) reflects an example of tha kind of difficulty that can arise in this regard.

Our' experience in working with utilities over the past' five years is that even a carefully chosen set of overall performance indicators cannot provide a real time, reliable l

measurement of plant performance.

Nevertheless, we understand j

your desire to.use quantitative performance indicators to help gain additional perspective on the performance of licensed nuclear units.

INPO's response to one of the Sillin Task l

Committee recommendations (Attachment 3) reflects our willingness.

~

to share plant-specific performance indicator results with j

the NRC and summarizes our position.

e In summary, we urge the Commission not to adopt a separate L

set of performance indicators for use in a formal regulatory sense.

Instead, we request that you consider our offer to share plant-specific data on the overall performance indicators.that are widely recognized and used throughout the industry.

We further recommend that you reserve use of performance indicator data to enhance senior NRC management and Commission perspective on plant performance as opposed to incorporating this effort into core formal regulatory i

interactions with licensees.

We hope these views are useful to the Commission in your deliberations on this important matter.

We would be

~ happy to, discuss this further with you or the Commission at your convenience.

Sincerely,

p. PetL Zack T.

Pate President ZTP tk cc/wt The Honorable James K. Asselstine The Honorable Frederick M.

Bernthal The Honorable Kenneth M. Carr The Honorable Thomas M. Roberts Mr. Victor Stello

,,. ~ _ _ -

. - ~ -

ATTACMENT 1

+

INPO Institute of i

Nuclear Power

)

Operatens 1100 Circle 7s Panrway sune isoo

)

s&>3too July 10,1985 l

Mr. William J. Dircks Executive Director for Operations United States Nuclear Regulatory Commission

• Wash ten. D.C.

20555 Dearj ks:

i We are beginning to see examples of increasing NRC pressure on the.

industry to reduce unnecessary screas, especially since Dennis Wilkinson's letter to the industry on this subject in early 1984, a copy of whir.n was furnished to the NRC.

i L

Reducing the number of unnecessary screes without (ever) eliminating a necessary scrae is a delicate matter.

At the industry to reduce unnecessary scrams,INPO, we are continuing to encourage L

but we constantly stress the need to manage for sace11ence usin scran performance *fs only one.g a broad set of perfomance indicaters, of which j

We also constantly stress to member utilities that in striving for. improved performance against measurable objectives, they must' keep these efforts in perspective for. their operational and technical personnel.

For example operator feel concern ov,er initiating a scras that he thinks is warranted

=

i-L l

I do not believe that it is in the best interest of reactor safety for the NRC, as-the regulator, to put pressure on utilities to reduce screes.

I believe senior NRC management can encourage industry progress in general discussion. relating to a wide range of performance indicators.

But specific regulatory programs or activities that put pressure on the utility to reduce i

screas, reduce forced outages, or increase availability could result in an unconservative or incorrect decision by personnel involved in operating a nuclear station.

Using quantifiable perfomance indicators is, in fact, a good example of an area where the industry, with INP0. assistance, is making progress, but which is not amenable to the regulatory process.

We have been working in this area for some. four years now and are beginning to see some encouraging results. A copy of a recent summary we prepared is enclosed.

We will try to manage our activities in this important area to best serve the utilities, the NRC, and the pubile.

Your support, along the lines I have discussed, will be helpful in achieving our mutual objectives.

Sincerely, T

g.g p p.h% p zac= 1. pate President d-ag, Enclosure

s-ATTACHENT 2 institute of

)

Nuclear Power Operations

)

1100 Cirolo 78 Parkway Sune 1600 -

i Atlan;&. Otorgia 30339 To:epnone 4os ess.3eoo n

J l

July 16, 1984 i

n Mr. William J. Dircks Executive Director-for Operations United States Nuclear Regulatory Commission Washi ton,-DC 20555

Dear ircks:

t A May 28, 1984 INSIDE NRC article stated that a new NRC l

compilation showed an increase in the average number of.scrans per plant'from 5.5 for the 1980, 81 and 82 three-year average to i

6.5'for 1983.- We understand that this data was.ande public by a l

l' senior member of the Division of Ruman Factors Safety during a L

May 11, 1984 ACRS General Meeting.

As you may know, a recent-L INPO study indicated a declitse in the average number of automatic

{

L plant scrans for 1983 from the 5.5 average for 1980-82 (sources-L NRC Gray Book).

Copies of the INSIDE NRC' article and the INFO letter are enclosed for convenient reference.

l After extensive review,. we conclude that the 6.5 average for 1983 as quoted to the ACRS dust have included all trip-related data from'the informal daily '50.72" phone report (this data includes manual trips, start-up test scrams, and reactor pro-t I

tection system actuations), whereas the 3.5 average.for 1980-82 i

(that has been quoted widely) comes from NRC Gray Book data.

If

.the "non-automatic scram" data is subtractedifrom the raw "50.72'

. data, the 1983 scram rate corroborates the Gr'ay Book automatic

?

scran data and agrees with the INPO report.

'O l

Sill,'we received many questions about our report on the trend of scrans after the inaccurate statement before the ACRS.

l As you know, after such a " media release" occurs, it is difficult L

to set the record straight and some damage to INPO's credibility is an' inevitable result.

I would appreciate it if you would set the. record straight with your statf and with the ACRS.

,a We are a bit slow in addressing this matter but I asked my people to check and recheck the data before writing to you.

i

~Thank you for your support.

Sincerely, hl.

ek T. Pate President G71/Exo

. ~.

-~

ATTACHENT 3 m

j EXTRACT FR(m INP0 RESPONSES TO THE AUGUST 1986 REPORT l

)

LEADERSHIP IN ACHIEVING OPERATIONAL EXCELLENCE

$111tn Task Committee Recommendation C:

2 Continue its development of performance indicators and other means (that correlate with evaluation results):

(1) for use in tracking performance between evaluations; and, 4

(2) for deteimining the need for action where adverse trends are indicated.

The performance indicator results, on an industrywide basis and for each unit, should be mafie available to the nuclear utility industry and to the NRC.

INP0 Response:

The Institute will continue to refine the Plant Performance Indicator Progran,

l including performance indicator correlation with evaluation results.

Currently, i

all member utilities are reporting data on a quarterly basis to INPO on nine l

l

. overall performance indicators and several other selected indicators. A report t

of generic performance indicatnr results will be issued semi-annually on an industry-wide basis.

l In INP0's view, the Performance Indicator and Long Range Goals programs have j

three purposes as follows:

(1) They allow utility managers to trend the performance of their nuclear units. The performance indicators, and the "other" indicators, thus L

serve as a management tool for utility managers.

(2) They provide a basis for healthy competition between nuclear stations and between utilities in the industrywide quest for improved performance.

(3) The performance indicators can serve as useful leeds for INPO evaluation teams, on a selective basis, and can be helpful to senior INPO management in assessing overall performance patterns, on a limited' basis (INPO learns far more about a plant's performance and safety niargin from an evaluation team visit than from a review of performance indicators).

At this point in time, the first two purposes art by far the most important.

For these reasons, and because of the inherent time delays in information determined from performance indicators, INPO does not believe they can or should be used

.for detemining when corrective action is needed at a nuclear station by INPO (or by the NRC). -Instead, this type of use should be reserved for utility managers,

.thus reserving the use of these indicators as utility management tools, in keeping with the relative importance of the purposes discussed above.

The semi-annual report of generic performance indicator results will be shared l

with the NRC as reconsnanded.

In addition, INPO will seek to work out arrangements with the NRC whereby planta pecific results for the overall performance indicators s

i are furnished to the NRC on a periodic and timely basis, subject to the NRC's L

agreement on the purposes of this important effort and the understanding that the NRC will not allow the indicators to become regulatory tools, or regulatory-type measurements of plant performance.

October 22, 1986

h*

• A'ttschment:2l g

App 5ndix C i j Institute of R

,K Nuclear Pouser L

Operations i

1100 Circle 75 Parkwey l

Suite 15o0 Atlanta. Georgia 3o339 Telephone 4o4 953 3600 j

m May 14, 1987 i

1 I

The Honorable Lando W. Zech, Jr.

Chairman United States. Nuclear Regulatory Commission 1

2 Washington, D.C.

20555 4

Dear Chairman-Zech:

During INP0's briefing of the commissioners yesterday, you described your L

thoughts with respect to the use of performance indicators and asked for my l

views. 'I understood your discussion to be of a philosophical nature related to the use of these indicators in the nuclear power business, but my. staff concluded that you were: expressly describing how NRC would use the indicators.

H W

. e generally agree with the philosophical approach you described (subject l-to my points that the performance trends indicated by these. indicators are l

+

very time' late, and that their. principal use should be reserved to utility line management for-their own goal setting, etc.).

However, we continue to

-i L

L believe that the best overall approach from a nuclear. safety standpoint is for 1

the NRC to refrain from tracking and avoid using the performar.ce indicators i;

L that. the industry and INP0 are utilizing.

o l;

Notwithstanding this, in recognition of NRC's apparent determination to use some of the indicators already put in place by the indJstry, we have bee 9 and will continue to seek working agreements with the NRC staff that:

l' minimize duplicat'Jn y

reduce the possibility of a non-conservative decision at the' working i

level in a nuclear plant (for example, as a result of perceived pressure to-reduce scrams or forced outage rate) e preserve utility line management prerogatives, and encourage utilities to continue to set aggressive goals for their nuclear plants, based on the performance indicators.

We re-emphasize, however, our conclusion that the best role for the NRC is to monitor and encoJrage the strong industry initiative that is in place and progressing well, and not use the same indicators in NRC activities.

We stress that this industry initiative began in 1980, and has resulted in every utility's setting year-to-year as well as long-term goals, using the

' indicators developed by INPO. We also st'.ess the impressive progress the yf,

- i v.

.The Honorable Lando W. Zech, Jr.

May 14 1987 l

Page 2 i

industry has made over the past few years as measured by these indicators; as shown in INP0's successive annual reports, and as frequently acknowledged by l

the NRC.

We respectfully request that you consider the above points as we continue l

to work toward a coordinated approach that is in the best interest of nuclear plant tafety and reliability.

Respect fully, j

ack T. Pete President adw t

P b

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! Att chment 2 i g

Appendix D 6

Institute of Nuclear Power Operations Suite isoo 1100 Cacle 75 Parkway Atlanta. Georgia 30339 Telepnone 404 953 3600 August 18, 1988

'Mr. Thomas'M. Novak, Director Division of Safety Programs Office for Analysis and Evaluation of Operational Data U. S. Nuclear Regulatory Commission Washingto, D.C.

20555 Dear Mr.

a:

Thank you for the opportunity to review the draft report entitled, " Operating Experience Feedback Report - Progress in Sc am Reduction." The report is a useful compilation and review of scram data for the period January 1984 to January 1988. Our review of scram data through the end of July 1988 indicates continued industry progress with a 1988 projected scram rate of 2.3 unplanned automatic scrams per unit-year.

Our primary concer'is with the report are its exclusive focus on a single indicator and the inclusion of manual scrams.

On page 2 of your cover letter (in the fourth paragraph) you state that continued improvement ~in the scram reduction rate "will require increased dedication and effort." This same general tone of emphasis on scram l

reduction without consideration of possible negative side effects is I

reflected in the report. While efforts to reduce scrams should continue, determining an appropriate balance in the allocation of resources among scram reduction efforts and other efforts to improve nuclear safety is a utility line management prerogative.

As we have noted before, strong regulatory focus on a narrow set of indicators or a single indicator can be counterproductive _ to safety. - For. exa:'iple, trying to drive the number of scrams to zero sends the wrong message to utility management and working level personnel ancI could result in a non-conservative decision with serious safety consequences, particularly when manual scrams are included. We a

cannot afford to hava any operator feel concern over the inttiation of a scram or other safety system actuation that is warranted.

' is l

vitally important concern is discussed in more detail in Zack ate's

-July 10, 1985 letter (see Attachment) to Bill Dircks, then Ext;utive Director for Operations of the U.S. NRC.

It is recognized that the focus on a single indicator cannot be avoided if the report is to be published.

However, manual scrams should be excluded and additional perspective along the lines noted above should be provided.

N/

%(Q-

p 3 y

e MrJThomas.M.-Novak o-Page 2 The-following additional comments on the report are provided for your review and-consideration

~

o In trying to compare the data in the report with'the data we have collected in the INPO scram database, we did not make detailed comparisons for technical accuracy. Although slight l

differences in data were noted, these discrepancies are i

probably due to d'fferent data classifications and different criteria used by.INPO and the NRC to classify scrams.

l o On page.67, Section 3.3.4.9, item 1 and page 84, Section 4.2.3, the following statement is made:

"since they i

(Combustio1 Engineering NSSS's) constitute just 14 percent of the critical hours, it is possible that the industry as a whole can reach its goals without improvement in scram

-performance by plants with CE NSSS's as long as the major vendors do more than their share prior to 1990." These types of statements should be deleted.. They serve no useful purpose and could be counterproductive t) the industry's initiative in 1

this area.

o On page 18. Table 3 6, the pre-commercial value for scrams per 1

1000 critical hours at Waterford 3 is incorrect.

Based on the l-data shown in the table, the correct value should be 5.82 and not 11.59 l

If you would like to discuss our concerns further or if there are I

any questions, please feel irk to call me.

Sincerely, i.

Terenc b Sullivan l

Group Vice President Ar.alysis and Engineering L

TJS:mp I

Attachment:

(1) Draft " Operating Experience Feedback Report -

l Progress in Scram Reduction" (2) Zack Pate letter of July 10, 1985 to W. J. Dircks, NRC i

cc/wo:

J. M.' Taylor E. L. Jordan Z. T. Pate P. M. Beard Jr.

i L

lE

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