ML20058E598

Transcript of 901026 Briefing in Rockville,Md Re NUMARC Perspective of State of Nuclear Industry.Pp 1-107.Related Documentation Encl

ML20058E598
Person / Time
Issue date:	10/26/1990
From:	NRC
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REF-10CFR9.7 NUDOCS 9011070235
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{{#Wiki_filter:- yd iUNITEDLSTATES OF AMERICA l NUCLEAR 1 REGULATORY COMMIS SION e 4 a Tkkel . BRIEFING ON NUMARC'S PERSPECTIVE OF THE STATE OF THE NUCLEAR INDUSTRY' LOCatiOD: ROCKVILLE, MARYLAND C 3" _ h&I6l'- OCTOBER 26, 1990 _PageS: 107 PAGES c s NEALR.GROSSANDC0.,INC. COURT REPORTERS A N O. T R'A N S C R I B E R S. 1323 Rhode Island' Avenue, Northwest Washington, D.C. 20005 (202) 234-4432 9011070235 901026 'J PDR 10CFR PT9.7 PDC

.g; f & 1 i DISCLAIMER 4 This is an unofficial transcript of a meeting of $ m the. United - States Nuclear Regulatory Commission held on October 26, 1990, in the Commission's office at one L White Flint North, Rockville, Maryland. The meeting was y open-to pub'lic attendance and observation. This transcript a has not been reviewed, corrected or edited, and it may

. 4 contain inaccuracies.

The ' transcript is intended solely for ' general informational purposes. As provided by 10 CFR 9.103, it.is a not.part-of the ' formal or. inf ormal record of decision of the matters ~ discussed. Expressions of opinion in this transcript" do not - necessarily - reflect final determination or' beliefs. No pleading or other paper may be filed ~with o the Commission 'in any' proceeding:-as -the result ' of, or m addressed to, any. statement or argument contained herein, j except as the Commission may authorize. [ l.. i ii NEAL R. GROSS COURT REPORTERS AND TRANSCRittR$ 1323 rho 0E ISLAND AVINUE, N.W. (202) 234-4433 - W ASHINGToH.' O.C. 20005 (202) 232 6600 - =

!Y i s. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BRIEFING ON NUMARC'S PERSPECTIVE OF THE STATE OF THE NUCLE AR' INDUSTRY PUBLIC MEETING Nuclear Regulatory Commission One White Flint North Rockville, Maryland Friday, October 26, 1990 r-- The Commission met in .open

session, pursuant 'to notice, at 10:00 a.m.,

Kenneth M.

Carr, Chairman, presiding.

-COMMISSIONERS PRESENT: KENNETH M.-CARR, Chairman of.the Commission KENNETH C. ROGERS', Commissioner JAMES R. CURTISS, Commissioner FORREST'J. REMICK, Commissioner i. .4 NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 i ,i

k.

9; s i 2 r-- ' STAFF'AND PRESENTERS SEATED AT THE COMMISSION TABLE: s_ S AMUEL J. CHILK, Secretary EUGENE

McGRATH, Chairman of the

Board, NUMARC; Chairman and CEO, Consolidated Edison Company of New York u

JOHN

BRONS, Executive Vice President, Nuclear Generation, New York Power Authority PHILIP

CLARK, President and

CEO, GPU Nuclear Corporation BYRON LEE, President and CEO, NUMARC JOE COLEMAN, Executive Vice President, NUMARC e- -

t i, J'i. t 7 .t 'k 4 F '~ l NEAL R.' GROSS 1323 Rhode~. Island Avenue, N.W. Washington, D.C. 20005 l-(202) 234-44'13 s m.

y j. 3 i i 1 1 P-R-0-0-E-E-D-I-N-0-S l e t' 2 10:03 a.m. K 3 CHAIRMAN CARR: Good morning, ladies and 4. gentlesen. I S' Let me first apologize for a con. Having 6 said that, keep your distance. [c 7 This morning we will hear from the members 8 of the Nuclear Managemont and-Resources

Council,

'I i 9

NUMARC, on their perspective on the state of the-i 10' nuclear industry.

Specific topics include updates on j i I ~ -industry maintenance and procurement activities. 11-12 On December 1989, the commission approved -j i - to its policy statement on maintenance of i 13-revisions 14 nuclear power plants to emphasize the Commission's-f 15 expectations and actions planned in ' the maintenance 1 ^ 16-aren' nnd to restate the commission's views with [17 ' respect t o. w h a t' constitutes an effective maintenance 18 program. 3 l ' 19" The Commission = believes safety can be 20 er.hnneed by-improving nuclear power plant maintenance El anroca the nuclear. industry. NRC maintenance team ' 22; . inspections have confirmed that further improvements j i L23i .are.necessary, especially-with regard to - ef fective J24 implementation of-maintenance programs. 'l 26' The~ Commission recognizes that' the r i

\\

NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20006 l' (202) 234-4433 1

a h 4 4 r 1 industry and individual licensees have made v.. 2 improvements in their maintenance programs and that 3 the_ industry is committed to continue to improve 4-maintenance. In view of this commitment, the 5 Commission decided to hold maintenance rulemaking in G-abeyance for an 18 month period to monitor industry 7 initiatives in progress and to assess the need for 8 rulemaking in this area at the end of this - period. 9 The commission is looking forward to hearing results 10 .of your efforts today. 11 The Commission has also been concerned .j 12 with licensees' capability _ to assure the -quality of i-13-. procured products. In March 1989, the NRC issued for '14 public, comment an advanced notice of proposed 15-rulemaking, acceptance of products,2uichased for use [ 16

in nuclear power plant structures, systems and 17-components, and Generic Letter 89-02, actions to 18 improve.the detection of counterfeit-and fraudulently 19 --

ma'rketed products. 20 In April 1990, the Commission agreed-that 21 the NRC-s taf f will defer programmatic inspections of + 22 licensees, commercial grade procurement and dedication- '23-programs and.will not-issue any. new enforcement ' 24- . actions concerning: programmatic deficiencies. in - this 25 area for one year. ,s T NEAL R. GROSS 1323 Rhode Island Avenue, N.W. W a si.i n g t on, D.C. 20005 (202) 234-4433

y .i ^ n . w. 0 .j -; / - 1 1.' 5 rn 1 NUMARC has proposed a framework for ~ ~ ;F Jl' 2 improving ' performance and procurement' that the 9

3~

Commission is also looking forward-to hearing about 4 t o d a y.~ As you well know, any such initiative requires 1 5 good implementation on the part of each licensee to J G truly produce improvement. I think this particularly important in an area where existing NRC regulations 7' t -. P s j;' 8 require measures to ensure.the quality of parts and-g ( u .9' materials. J E ? 10 Mr. McGrath,- Mr. Brons and Mr. Clark,- we 11' welcome - each of you here.today. We.' appreciate very 12 auch your.being with us this morning and providing us 13-with -your perspective on the state of the nuclear g; 14. industry.

r 15-Do any ;of my fellow Commissioners have l

.16. opening comments they would 1ike to make before we 17c begin? 18' COMMISSIONER'REMICK: Oh,-I'd just-lsay we 19. welcome Mr.. Lee and Mr. Coleman al'so. l ' 20 - CHAIRMAN CARR:- Do you think we really do? ,.;u, 4 -21 A114 right, .We'll grant that. Do you want to-vote on 22 it? 23 Any other comments? n ' [ 24-

If not', Mr. McGrath,'you may~ proceed.

'25 MR. Mc0 R A'f H : Good morning. I'm ' Gene j NEAL R. GROSS 1323~Rhode Island Avenue, N.W. Washington, D.C. 20005 i (202) 234-4433 i

'4 } 1 G g 1 'McGrath. I'm Chairman and Chief Executive Office of 2 Consolidated Edison Company of New York and I'm 3 Chairman of NUMARC. With me today are Phil Clark, 4' President of CEO of GPU Nuclear, and Jack

Brons, 5

Executive Vice President of New York Power Authority. G Also, Byron Lee, President and CEO, and Joe Coleman, L 7 Executive Vice President of NUMARC. I' 8. Phil, Jack and I are all members of the J ~9 NUMARC Board and on the Executive Committee. 10 We appreciate this opportunity to share 11 with

you our.

view of several key recent ^ 12 accomplishments and to discuss some of the ongoing i 13 . challenges [ d:" for the industry. We hope to give you ani .c;4 W{ 11 4 understandi'ng of some of our overall activities and to l

15 f ocus' on areas where we need NRC. - suppor t to. ' achieve 16 our'mutuni goals.

~ 17 Attached to - your' viewgraphs. is

a. handout 18

-entitl'ed, " Major Issues Affecting the Nuclear ~f the -major ; issues the .19 Industry."~ This is a list o p 20; . nuclear power industry is' working on through' NUMARC, l' sues, which. ~ 21 this list currently. covering. 57 major s I '22 .should give you a feeling for~the significant industry 23 resources be'ing committed to resolving regulatory 24' issues. .These resources are being drawn from across g 25-the entire nuclear industry. All nuclear utilities, u_ NEAL R. GROSS 1323 Rhode Island ~ Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 1

---.e i , -) h '. - :P = qi : 7 Y .1 - the four NSSS vendors, and five architect / engineering 2 firms participate fully not only in-their own shops, 3 but also in the NUMARC board working groups and 4 committees. 5-NUMARC is the focus of our efforts to 6 enhance our operational effectiveness on regulatory- '4 7 'related matters' and-to improve the quality and = 8 constructive character of the industry's contributions q.. 9' to the-regulatory process. NUMARC represents the 10 entire nuclear power industry on generic issues .11 through ; the active involvement of ' the industry as a e 4 and when I say we, I mean the ' entire 12-

whole.

We n y are expending tremendous _13 -nuclear power industry s 14 resources to-improve our operations and to-address our e 15 concerns'.and-the concerns of the NRC. 16 Today we' d-like to brief you_ on recent Ll7

industry efforts _in two of the-- major areas 1on: the list

-18 -of' issues.1

First, Jack Brons. wi~11 update. you on n9 19' recent activitles and' progress:

in-the area of 4 1 20~ maintenance:and-then phil Clark will summarize recent-4 21 activities and accomplishments. in .the area of r = procurement. Following their discussion, I'll-discuss 22' 2 3 -- some ofsour views and the state of our industry, a s' 24 ,well_as areas where we need your support. 25 Jack? t-NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

'g a] { 6 r q-3 s p 4 f 8 w, J q

e 11 MR. BRONS:

Good morning. I'm Jack.Brons 2 Jfrom the New York Power Authority. Today I would like 3 to discuss overall industry activities in the 4 i 4 maintenance area. y p '5-Let me start by assuring you that this 6 industry's leadership is' committed to the goal of &4 't 7 achieving improved reliability and safety through /dM 8 better maintenance. That commitment was stated early l- ~"

9.

.in an: October 28th, 1988 letter from the former NRC q. 10-Chairman, Lando Zech, to then NUMARC Chairman Robert 4 11:

Campbell, and. signed by every member. -of NUMARC's 12-Board.-that is all nuclear-utilities.

That commitment' w. wasireaffirme~d by the NUMARC Board of Directors at its ' 13 - J l' '14-June 1990 meeting. The commitment goes beyond mere 15 'words. Tha-ical proof is a significant-utility 16 investment and involvement - in improving -maintenance. '17 As ' I will' discuss later,-allffactors demonstrate that- >v '18: 'this: investment lis: paying off. T The industry began to address maintenance 19: 20 'in a coordinated manner in.198.4 through a NUMARC 21 working' group. The'many initiatives and efforts that. l 22 -resulted from this effort.have been-discussed with you 23 previously. Through the-work of, individual utilities, 1 .24 INPO, EPRI and others, these efforts have paid off'in c 25-improved performance. Rather than repeat those .u i L NEAL R. GROSS ? 1323 Rhode Island Avenue, N.W. Washington, D.C. .20005 (202) 234-4433

^ F b l 9 1 ' : t-- 1- ~ points,-I would like to focus on what we have done to 3 l 2-sustain continued improvement. 3: The focal point of our activitles'hos been 4 the' development of a comprehensive, integrated action 5 plan to coordinate and focus-industry actions to 6 improve nuclear power plant maintenance. This plan 4 '7 includes,many key activities being undertaken by 8 nuclear utilities, industry organizations such as- ..e 4 9 EPRI. -INPO and NUMARC, as well as the four vendors 10 owners groups and various codes and standards ~ 1 11 developing organizations. This morn ing -..It will review 12 'the status of-plan implementation and focus on several-13 specific accomplishments since this plan was provide'd

1.4

'to.you last. February. 4 - 15 The plan covers the following broad 1 16 subject areas:- 17-

INPO plart 2"aluation and assistance 4

' 18 activities;> monitoring 1the performance and maintaining 19' ,the: reliability of-equipruen t ; training;- monitoring: ' 20 activities; communications and. regulatory interfacei i 21 tools'and techniques; ownersigroup activities. These-22 'are areas that we believe need additional a t t en t iori. e 23 In1many. cases, these were identified by both industry '24 and=NRC special: maintenancetinspection teams. 25

overall, there are 189 specific action i r--

l: .NEAL D. GROSS. 1" 1323 Rhode Island Avenue, N.W. l Washington, D.C. 20005 (202) 234-4433 6 y

rc,.. u u: w ; s' s \\

9

} l o 10 $n f s- _ -1 items to be accomplished within the seven-major areas. v.: ( 2-Many of these actions are ongoing and are expected to ) r;r ' a way of life. As of September 30th, 1990, the 3 become -i I I ,g. 4 last update of plan status, 109 have been completed. 5! Of the open action items, 22 are overdue or have been /, G rescheduled. Seven are overdue because the original

i n

~ 7 completion dates were based.upon NRC actions yet to be mm 8 completed. ^ sy 9 Management attention'to maintenance.- Let - 10. - me now-discuss some of the specific actions that we've ' w .i 11 1 taken. One important area of.the plan emphasizes the i >l2- 'need for greater management attention to maintenance n q 1;.

13

~to ensure that corrective actions are effectively il l l,4 ~ 1'4 implemented'. This' includes 'providing assistance' to j i 15" plants most in need of improvements in the maintenance ,i i e i 16-ares.. As you might. imagine,' the, focus of these s 1 3, s 17 . efforts .has been; through INPO's. dvaluation; and q .4 ' 18. Assistance Program. j p, s t g 19 -Specifically,.INPO has increased the focus 1 .oo 20l of their. evaluation on maintent-9 placed additional-y\\ 1 1 y 21 emphasis on areas such as moni.oring of key aspects..of-j ~22 maintenance, use of

goals, effectiveness in j

9, "

q 23 identifying and correcting recurring equipment-i t -a ? 24-problems,- engineering support for maintenance and i .) 1: x 'l L '25 .others. -They've conducted in-depth reviews of key

v.

t [ ). i L NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 a (202) 234-4433 e,, < l -. [_ N I '

s D 11 r-I I equipment performance during e ". evaluation. They've 2 added additional evaluators to teams to focus 3 specifically on maintenance and root cause problems, 4 conducted assistance visits to plants needing 5 additional improvement and maintenance. Specifically 1 6 at least one special assistant visit was conducted at 7 each of the 12 tions most in need of additional 7 8 help. ~. 9 Anoth r important area is that of {W 10 monitoring the performance and monitoring the t 11 reliability of equipment most important to safe and 12 reliable plant operations. We placed additional 13 emphasis on improving NPRDS effectiveness and use, and r B 14 emphasis on enhancing our ability to analyze equipment N 15 problems and determine their root cause. 16 Specifically, each utility has implemented 17 a quarterly review of component failure analysis 18 reports which allows it to use NPRDS to identify L 19 plant-specific components with higher failure rates 20 compared to the industry average. The scope of NPRDS 21 was expanded. A detailed analysis of events and 22 equipment failures that resulted in loss of generating 23 capability over a recent six year period was 24 conducted. As a result, approximately 80 additional e 25 balance of plant components were added to the over r-NEA1, R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 c (202) 234-4433

O 12 O c..J l 5,000 components per plant tracked by NPRDS. INPO has 2 issued good practices on predicted maintenance 3 techniques and how to conduct effective root cause 4 analysis. 5 The industry has expended significant G resources on the maintenance indicator area over the 7 Inst six years and has attempted to define a set of 8 quantitative indicators that accurately represent the 9 quality. of maintenance performed in the plant. From 10 those

efforts, we have concluded that while it's 11 possible to monitor elements of the maintenance 12 process, it is not possible to quantitatively measure 13 the quality or effectiveness of maintenance itself.

14 The recent efforts of your staff to 15 develop a maintenance effectiveness indicator bear out 16 this conclusion. Their recent report, SECY-90-351, 17 recommended against adoption of the proposed indicator .18 for similar reasons. 19 We' continue to believe the industry .20 overall performance indicators, taken. in the 21 aggregate, combined with other direct assessments, 22 such as observation, provide the most effective seens 23 of monitoring maintenance performance. '24 Each utility has also established plant-25

specific, long-tern 1995 goals for each of the r-s~

NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

E, i, c-o- 4 13 - r-- 1 industry overall performance indicators. These are 2 consistent with the worldwide consensus set of 3 performance indicators developed by WANO. INPO will e 4 determine the appropriate industry-wide 1995 goals p S' based on this input by November this year. Although 6 we believe the overall performance indicators are the 7 best way to. monitor maintenance performance, we 8 haven't.given up on learning from each other. We have 9 emphasired identifying plant-specific techniques 10 different utilities use to monitor effectiveness and 1 11 set goals. Each utility has provided that information L -r 12 to INPO. They are collating it and will determine 13: what follow-up action is most effective. 14 The industry has cantinued to develop.and 15-refine a variety 'of tools and techniques to support 16-effective, maintenance programs'. One of these tools 17 under development-is reliability. centered maintenance. 18 Significant industry resources are being placed on 19 this to determine the appropriate methodology for 20-integrating this approach into maintenance programs. t 21 We're pursuing RCM because we believe it holds the 22 potential for reduced costs and improved operations. 23 In effect, we hope it will allow us to optimize the 24. preventive maintenance programs at our stations, that 25 in to perform smart maintenance. t-- NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 c. (202) 234-4433 2

.c i I 14 4 1 The demonstration of the RCH concept has l 2 been focused through the Cinna and San Onofre l 3 reliability centered maintenance projects coordinated l 4 by EPRI. These are nearing completion. The final ,5-reports have been submitted for final review and G publication. Expected results include preventive 7 maintenance optimization, improved reliability and 8 reduced costs in many plant systems. Further, we know 9 of at: least 17 other stations that are evaluating or 10 have completed. an RCM process on selected systems. 11 To facilitate information exchange, EPRI 12 held three reg 4 nal workshops this year to transfer to y 13' transfer the me.nodologies developed during'the pilot 14 program to other utility participants'. 15 '. We. continue to place emphasis on specific '16 equipment and systems. A significant portion of that r 17 effort is completed by the NSSS Owners Groups. The 18 NSSS-Owners Group'n ' involvement is essential in 19 addressing areas that are NSSS specific and in ~ 20 emphasizing ways to improve plant performance in areas t ~ 21; such as reduction of-reactor scram frequency.and 22 improvement in plant transient response. 23 My. time is obviously much too short to

24 cover the many actions identified in the plant in 25 depth.

The best way to understand the scope and depth k .o u_ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. . Washington, D.C. 20005 (202)'234-4433

Fm i 15 T-1 of industry actions to improve maintenance is to r e b.i ] 2 the plan and the status report that was sent to you 3 carlier this week. I encourage you to do so. We 4 would appreciate any questions, cornmenta or i 5 suggestions you may have. G Let me now summarir.e the status of 7 maintenance in the industry.

First, maintenance 8

performance, as well as overall plant performance, 9 continues to improve. All ten overell performance 10 indicators tracked by INp0 show improvement for the 11 first six months of 1990. By example, equivalent 12 availability

factor, which is one of the b e s t.

13 indicators of long-term performance and depends 14 strongly on effective maintenance, shows an increase 15 from 65.2 percent in 1989 to a_ projected 1990 value of 16 69.1 percent. 17 Comparing the performance of U.S. plants 18 with other countries shows the name results. Two 19 years ago we were compared with the Japanese and the 20 French as examples of people who were doing things 21 right. This curve shows the capacity factor for l 22 nuclear plants in the United States, France and Japan. 23 The U.S. average year to date at over G7 percent is 24 above France, but still below Japan. 25 This

slide, in the distribution of i

NEAL R. GHOSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 i

P o o 16 r-i I capacity factors, shows part of the reason. Seven of 2 our plants have capacity factors under 10 percent due 3 to extended shutdowns, mostly for regulatory reasons. 4 If these plants were operating near the average i 5 capacita factor it would boost the U.S. average to 6 nearly 72

percent, very close to Japan who we're I

always compared against. 8 Your own special maintenance team results I 9 through August 1990 show similar results. To date, 10 only one station has been assessed as poor in its 11 programs and only two stations in implementation. 12 Contrary to the view that you expressed, 13 Chairman Carr, I think in looking at an area as broad L -- 14 as maintenance that these are excellent results. This 15 is especially true when you recognize that the scope 16 of your' inspections cover the total maintenance aren 17-at our plants and they're even based on guidance very 18 similar to the i,austry's own guidance developed in 19

1985, i

'ata to show d 20 We wanted to use~ SALp 21 maintenance improvement, but we couldn't correlate the 22 SALp to the results of the maintenance team 23 inspections or necessarily to overall plant 24 performance. All other indices of performance show 25 similar trends. For example, NpHDS shown improving r - i NEAL H. GHOSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o 17 F I trends over the past three and a half year period in j 2 motor operated and check

valves, inverters, main 3

feedwater pumps, feedwater regulating valves, reactor 4 coolant and rAcirculation pumps, reactor coolant and 5 recirculation pump motors. These are areas on which l C the industry has pinced additional attention. 7

Second, we have tried to address the 8

Commission's concern over the perceived lack of a 9 maintenance standard. In April of this year, NUMARC 10 transmitted to you INPO-90-008, maintenance programs 11 in the nuclear power industry. This document sets 12 forth the industry standards for maintenance that.all 13 utilities, as members of INPO, are committed to meet. 14 A comparison of the Commission's revised policy 15 statement on maintenance, the NRC's maintenance team 10 inspection criteria. 'and the industry standard 17 demonstrates the similarity of the industry and 18 regulatory views. We are still awaiting the results 19 of' staff acceptance of this approach. 20

Third, the-industry is still under the 21 threat.of a rule on maintenance and'now the Commission 22 has directed

t. h e staff to prepare an alternative 23 maintenance rule on which we hope to have the 24 opportunity to comment.

As you are well aware, the 25 industry firmly helieves that utility-specific and l. NEAL R. GROSS i L-1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 h (202) 234-4433 m

s-6 18 1 industry-wide initiatives to improve maintenance are 2 the best and quickest way to achieve a high standard 3 of maintenance. Any

rule, no matter how well 4

intended, will only divert our effort. 5 The NRC and industry have seen that G problems can be resolved without the need for 7 additional regulation, as proven by our successes in 8 training. Conversely, we have seen that even broad i 9 general rules can be devastating. Appendix R and 10 environmental qualifications are examples of this i 11 point. 12 In the maintenance area, the industry has 13 in-depth-expertise in the commitment to ensure 14 improvement, not just in words but by demonstrated 15 actions. The results I've discussed clearly show this 16 fact and the NRC has the means today to evaluate 17 maintenance performance and to require additional 18 action on a case by case basis if necessary. With all 19 the progress made in the-maintenance area, we continue I 20 to be~ surprised by the intensity of the commission's 21 continuing focus on maintenance and maintenance t 22 rulemaking. l 23 Let me focus on the importance of NRC 24 evaluating performance. This'goes to the alternative 25 maintenance rule proposal the staff is addressing.- We r-- L NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

19 F 1 view looking at performance as an essential ingredient 2-to effective regulation. Too many times we find that 3-performance is satisfactory, yet NRC inspections and 4 pressures exist to make changes to our programs that 5 do not yield positive results. More often than not, 1 0 however, they result in significant increases in cost. 7 We see the Commission's proposed alternative rule as 8 one way to address the issue of bottom line results. 9 In my opinion,

however, I don't believe 10.

the NRC is ready for'this approach. The best recent 11' example we have to illustrate this point is diesel i 12 generator reliability, nn issue still being addressed 13 by the staff. In 1974, the staff identified Generic ,14. Issue B-50, whose goal was to achieve improvement in 1 15 - average -diesel reliability to 0.95. The industry 1~ 16 responded and since 19f33 NRC and industry agree that '17 ' diesel' reliability.is treater than 0.98. r 18 The indu',try also has taken a number of '19 significant actions to improve dicscl reliability. 20 including the adoption of several NUMARC initiatives El to improve monitoring, set threshold levels for' 22 actions. based on reliability. and so forth. Each 23' rtility.has a. docketed licensing commitment to the NRC -24 through the station blackout rule to either 0.95 or 25 0.975 reliability to which inspection and enforcement NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o 6 20 i r-- I action can be taken. l y _, 2 Given all the above, it's not clear why 3 the issue is not closed. The staff continues to press 4 for detailed prescriptive and programmatic 5 requirements in diesel reliability programs and have G indicated their intent to achieve this through a 7 generic letter. It's also of concern that there's a 8 proposal to use a generic letter to achieve what could 9 not be achieved through rulemaking. 10-From this example, I think you can see the 11 NRC's look at performs.nce at the bottom line results 12 is still not enough to cause the staff to close out 13 the issue. I sincerely hope that I'm proven wrong in i 14 -this aren because the approach is important to allow i 15 us the flexibility to effectively manage our plants 16 and: to do so in a cost effective manner. 17 In closing, as you can see, the industry, 18 utilities.

INPO, EPHI,

NUMARC, owners

groups, have t

19 made a dedicated, long-term commitment to improve -20 maintenance. I brought J,om e of these points to the 21 Commission's attention two years ago in another 22 briefing session. I am intensely proud to report to -23 you ~that the industry has sustained its efforts. 24 Progress has been made and it is clearly measurable. 4 25 I hope this update will prove helpful to 1. i__ l l NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o a 21 r-1 you in your future deliberations on maintenance. 2 Thank you. 3

Now, phil Clark will brief you on our 4

activities in the area of procurement. 6 MR. C l, AR K : Thank you, Jack. 6 Mr. Chairman, Commissior,ers, the industry i 7 has undertaken an enormous effort in the past two 8 years to address issues of alleged fraud and 9 substandard components. As 1 will show you, we've 10 moved beyond the original specific NRC concerns to 11 address iroad-based and programmatic changes. These 12 efforts have - already resulted in significant 13 improvements to utility programs and additionn) 14 improvements are to be implemented over the next two 15 years and will fully address, we believe, the changing 10 nuclear marketplace. 17-As you

know, the industry took the 18 initiative in this area with NUMARC coordinating the 19 program.

NUMARC's involvement in the procurement area 20 began in the spring of 1988. At that time, industry 21 had notified NRC of possibl6 fraud by suppliers of 22 ' piping flanges and circuit breakers. In July of 1988, 23 then Chairman Zech asked the industry to tackle what 24 appeared to be a major problem. 25 The pipe flange issue resulted in NRC' r-- NEAl R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o t 22 r-1 Bulletin 88-05, which dealt with allegedly 2 nonconforming pipe fittings and flanges supplied by a 3 specific supplier. The next visual provides an 4 overview of industry activities in response to this 5 bulletin. The bulletin required the industry to t G perform records reviews to locate the suspect E 7 components, perform in-situ testing or otherwise 8 justify continued operation if we did not have results .9 indicating ASME code material. 10-This written request resulted in an 11 industry-wide commitment of approximately 100 man-12 years per month before NUMARC entered it to coordinate 13 the efforts. NUMARC developed the program to compile 14 and annlyze the reams of data being developed by 15 utilities in response to the bulletin, to perform 10 destructive laboratory

testing, and to provide a

17 generic stress analysis report. 18 As shown on the viewgraph, the record 19 review identified over 20,000 installed ittys. We did 20 in-plant testing of 7,000 items. did laboratory 21 testing of over 600 items and developed hundreds of 22 plant-specific JCOs. We had a generic program to 23 analyze the results. The overall resource impact 24 applied to this issue was $30 million and the result 25 was that all installed items were found suitable for-u.- NEAL R. GROSS 1323 Rhode Island ~ Avenue, N.h. Washington, D.C. 20005 (202) 239-4433

o 6 23 I I service. There were about two dozen blind flanges 2 identified with less than specif$ed strength or with 3 adequate margin te operate safely. This issue was 4 resolved by the fall of 1988 and was officially 5 closed, as you know, last year. i G The second example involved the concern 7 that certain electrical equipment suppliers were 8 providing misrepresented molded case circuit breakers 9' to the industry and resulted in Bulletin 88-10 in 10 November 1988. The next visual summarizes our 11 activities in response to this issue. The bulletin 12 required traceability to the original manufacturers or 13 testing of-safety-related breakers in stock and 14 follow-up actions for breakers installed in safety-15 related applications. As shown on the visual, over 16 24,000 breakers procured as safety related were 17 reviewed in response to the bulletin, with tl.e result 18 of less than one percent were provided or traceable to + 19 the suspect suppliers. 20 In addition, industry extended this and 21 they looked at 36,000 breakers procured as non-safety 22 related equipment. The result there was that -. 2 3 approximately three percent was identified as suspect. 24 In both cases, the numbers identified things which 25 were auspect, not necessarily fraudulent or deficient. .r-- NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

a 1 24 1 Suspect breakers were either discarded or 2 returned to the original manufacturer and the breaker 3 issue is, we believe, moving towards closure, again 4 with no indication of a significant safety impact. 5 As a result of our extensive effort on 6 flanges and breakers and the absence of additional i 7 industry-wide issues of potential fraud in the last 8 two years led us to several conclusions. First, the 9 issues with flanges and breakers were found to be of 10 no safety significance.

Second, it appears the 11 previous procurement practices have been sound and i

12 have not opened the door to widespread ingress of I 13-substandard items. In

fact, it was the existing 14 programs that identifi-d the original suspect parts.

15 Third, the resources required to locate and identify 16 potentially substandard items can be very substantial compared to the item's final sa fety significance. 18 As an overall conclusion, we believe 19 there's no crisis involving fraud and substandard 20 items diminishing the safety of the plants. This is 21 not to say that improvements should not be pursued. 22. Despite the fact that we found no safety significance 23 with flanges and

breakers, we cannot ignore the 24 potential for issues of a greater significance.

25 Early in t h e. efforts to address the-r u.- NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

[ 25 i I flanges and circuit breakers in September of 1988, j 2 NUMARC formed the Nuclear Plant Equipment Procurement 3 Group under Bill cavanaugh, now President and CFO of 4 Entergy Operations. This group analyzed the problems 3 5 and developed appropriate improvements in procurement l 6 programs for implementation throughout the industry. 7 lt addressed programmatic issues as distinct and 8 broader from the component-specific NUMARC activities 9 described earlier. Several industry initiatives were 10 developed and are summarized in the next visual. r 11 The working roup recognized that the time 12 had come to reevaluate industry procurement practices 13 primarily because today's nuclear equipment l 14 marketplace is very different from that which existed 15 'when t he procurement programa were first developed, i 16 First, we've moved from procuring. complete equipment i 17 assemblies towards procuring replacement components 18-and' pieced parts.

Second, the number of suppliers 19 with Appendix B QA programs has dwindled over the 20 years because of the cost of maintaining those t

21 programs for a limited market.. 22'

Also, the legal implications of

,23 reportability under Part 21 as revised in October,of 24-1989 for manufacturers and suppliers of commercial 25 parts have exacerbated this problem. The result has f r-NEAL R. GROSS 1923 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

O. b ( 2G r-I been the increased need for utilities themselves to s.,, 2 procure commercial grade parts and dedicate them for 3 safety-related use. 4

Third, a growing number of parts in the 5

plants are becoming

obsolete, requiring extensive G

redesign, procurement from the surplus market or other 7 sources not originally envisioned. The working group 8 developed several basic considerations. It recognized 9 that Appendix B was designed to ensure quality through 10 good faith cooperation between vendors and utilities e 11 but not to guard against deceptive practices. 12. Fraudulent practices are possible under any system of 13 rules; so changes to the regulations to address fraud 14 we believe would have limited success. i 15

Rather, the working group believed two 10 fundamental changes were needed.

One was increased 17 awareness by utilities of the potential for fraud and 18 increased vigilance for fraudulent. practices. Thia 19. change in mind set, we believe, has been accomplished 20-through the events _of the past two years which have 21 highlighted to all of us the potential for fraud. 22 .Several NRC. information notices and industry 23 guidelines - for detecting fraud have been issued and 24 utility pereonnel involved in each stage of the 25 procurement process' are now on the lookout for ( u_ NEAL H. GROSS 1323 Rhode Ialand Avenue, N.W. Washington, D.C. 20005 1 (202) 234-4433

o 27 T"~ I deceptive practices. 2 One recognition of this increased 3 owareness i r. reflected in a recent letter n on Jim 4 Taylor to Carolinn power and Light acknowledging the diligence of that utility's staff in detecting G misrepresented equipment and taking appropriate action 7 to preclude its installation. 8 The second change needed is a more 9 fundamental shift in emphasis from paperwork review to 10 verifiention of item performance. Total reldance on 11 paper enn actually increase the potential for fraud 12 through false certificntion or misrepresentation. 13 Fecessary improvement in this aren is affocted through 14 incrensed engineering involvement, particularly in 15 dedication of commercial grride items, in vendor audits 16 and in enhanced testing of-items upon receipt to 17 verify performance. 18 in each of these

areas, the key is 19 defining the appropriate technical verification 20 required based on many

factors, including the 21 function, the procurement channel and the history of 22 the supplier.

It's neither practical nor necessary to - 23 verify every parameter or characteristic of every item 24 in every case. We believe reasonable assurance of 25 item performance remains the key consideration and I NEAL H. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

4 e e I 28 t-~~ 1 criteria. s 2 Increased engineering involvement reduces 3 the potential for fraud and it also addresses many of 4 the considerations of the changing marketplace. The 5 working group has reviewed and endorsed EPHI guideline G documents which provide a defined process for 7 dedication of commercial grade items for performance-8 based vendor audits and to enhance receipt testing and 9 inspection. Several of these guideline documents were 10 being developed before the flange and circuit breaker 11 concerns arose. 12 The working group also recognized that 13 because of this new approach there would be need for 6-14 increased use of joint activities and information 15 sharing among utilities. These allow more efficient 10 use of the utility resources to avoid major 17 unnecessary increases in cost. The working group also 18 recognized INPO's nuclear network as an effective 19 means for tinely sharing of many types of procurement 20 and quality-related information as a way to exchange 21 information and provide more timely awareness of 22 potentially substandard items. 23 For vendor audits, a voluntary industry 24 group called NUPIC was formed and is now perforcing 25 shared and joint vendor audits. One example of the f x_ NEAL H. GHOSS 1323 Hhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o-e t i 29 1 F I benefits is the NUpIC audit of INp0's fitness for duty 2 program which all INp0 members can now utilir.e in lieu 3 of conducting some 50 individual audits of the 4 program. All domestic nuclear utilities are members 5 of NUpIC. G The working group met many times to 7 develop recommendations and held regular discussions 8 with NRC staff and management. The group has 9 . completed its work and the improvements are now being 10 . iinpl em e n t e d industry-wide with two initiatives 11 approved by the NUMARC Board of Directors. The first 12 initiative deals with dedication of commercial grade 13' items for safety-related applications and was paesed 14 by the NUMARC Board in March of 1989 for 15 implementation by the-end of 1989. 16 The second initiative is the comprehensive -17 procurement initiative which addresses vendor audits, 18 Joint activities, enhanced testing and inspection, 19 guidelines for ' f raud detection, information sharing, 20 obsolescence and general procurement. This initiative 21 was. approved by the NUMARC Doard this past June 1990 22 for implementation by all members by July ' of. '92. 23 Many utilities have already implemented aspects of the 24 initiative. c 25 Since past procurement activities have not r-NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o a f 30 I shown any significant safety

problems, these 2

initiatives are intended to be forward looking. Only 3 its safety concerns are identified during an 4 individual company's review of their progrna or with 5 respect to a particular item procured in the past do 6 the initiatives recommend on item-specific look back. 7 Implementation of these improvements is a significant 8 undertaking and efforta to backfit the improved 9 practices of previous activities will limit our 10 ability to move forward with implementation. 11 As a result, the previous NHC inspections, 12 a number of utilities agreed to apply the improved 13 methodology by dedicating commercial grade items, to 14 apply that to past procurement activities. Once 15 again, no safety concerns were revealed, so we believe 16 our forwerd-looking position in this initiative is 17 proper. 18 The industry has made ma,Jor strides in A 19 this aren over the past M years and these efforts 20 are continuing as the initiatives are implemented. 21 One driving factor clearly was the concern expressed 22 by NRC relative to fraud and substandard parts. It 23 gave us an opportunity to use-industry expertise to 24 alleviate NRC concerns as well as those of the 25 industry in an efficient and more effective manner p r--

L NEAL H. GROSS 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433 i

l' .o e - l' t 31 h r~~ 1 than by adding new regulations. A review of the 2 industry initiatives, which are the final products of 3 the working

group, clearly demonstrates that the 4-improvements go beyond those necessary to address the S

regulatory issues and we believe existing regulations 6 are adequate and there is no need for revision or 7 addition to existing regulations in this area. 8 These improvements represent fundamental 9 changes in the way many' utilities have done business 10 in the past. They require additional resources at a 11 time when O&M costs are coming under increasing 12-- scrutiny. The fact that we have undertaken these 13 improvements we believe speaks to our recognition of n,*~ 14 their long-term importance. We hope that we can 15 continue to work with the NRC staff to assess the 16 value.of our initiatives or any shortcomings and then 17. work together to derive the maximum value from their 18 implementation. 19-We believe the nuclear power industry has 20 been on the forefront in addressing this area of fraud 21 and substandard parts which affects many other 22 industries and we're proud of that. 23 That concludes m) remarks and I'll turn 24 the microphone back to Gene McGrath. 25 MR. McGRATH: Okay. Thanks, Phil. '~ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 + (302) 234-4433 -{

32 [_ 1 With maintenance and with procurement, we 2 have two examples of how the NRC and industry can work 3 together effectively without compromising our 4 respective responsibilities to achieve common 5 ob,)ectives. I believe these two examples can and G should serve as models of how to resolve other issues r-7 of concern to the NRC. Updating you o:i progress in 8 these two areas is only part of the reason we're here 9 this morning. We also want to give our insights into 10 the state of the industry as it relates to the impact 11 of regulation on the nuclear power industry. 12 The results we've achieved so far working 13 together in the areas of maintenance and procurement i 14 are unfortunately not the rule.

Frankly, the view 15 from the trenchen is not too good.

The cumulative 16 impact of regulation and enforcement by the NRC, and.1 17 mean both Headquarters staff and regional offices, is 18 -significant and not always conducive to our efforts to ,19 improve our operations and our striving for 20 excellence. 21 This message comes through loud and clear. 22 in the regulatory. impact survey of licensees and from 23~ your own staff survey. Consider these comments: 24 "A basic - concern of licensees is the 25 number and scope of requirements imposed by the NRC." NEAL R. GROSS i 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

a a 33 I 1 Another quote, "A persistent comment was 2 that NRC requirements and pending requirements are 3 poorly integrated as to their overall effect on plant 4 operations and utility resources." 5 Another quote, " Licensees make a strong 6 plea for NRC to ce+ olish a priority system." 7

rinally,

" Licensees commented that NRC 8 fails to appreciate that licensee preparation for and 9 support of NRC inspection activities involves several 10 man-years of licensee effort each year." 11 When I first read those

concerns, I

12 believed them to be feedback from the recent 13 regulatory impact survey. They were not. In fact, 14 these comments are taken verbatim from the NRC's 15 survey of regulatory impact completed almost ten years 16 ago, better known as the O'Reilly Report. While the 17 NRC made several significant improvements following 1 18 that.1981 survey, like the creation of the committee 19 for Review of Generic Requirements, CROR, similarities e 20 between the 1981 survey results and the 1990 survey 21 show that significant fundamental problems have not 22 been corrected. 23 It's-the long-term nature of these 24 problems that is of most concern. It is here, we 25 believe, that strong commission action and involvement i NEAL H. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

) o 34 j r 1 is needed. The industry alone cannot solve these L 2

problems, nor can NRC

staff, regional offices or 3

resident inspectors solve these problems by 4 themselves. A necessary step is active, systematic [ 5 involvement by the Commission and by senior NRC 6 management. 7 I am mindful, Chairman Carr, that you're 8 not interested in or persuaded by general whining from 9 the industry about regulatory burdens and I agree. We 10 can't ask you to correct a problem we haven't 11 identified. I believe the industry did take your 12 challenge seriously in providing its feedback on the 13 regulatory impact survey and I'd like to provide you / 14 with a few more specifics. 15 Looking again at the list of major issues 10 being addressed by the industry through NUMARC, the 17 sheer number of issues, the resources being expended 18 by both NRC and industry, the. cumulative impact of 19 trying to deal with them all at once is a cause of 20 great concern. NRC's own lists contain many more 21-issues than a NUMARC list which contains only issues 22 that are generic for the entire industry. I don't 23 deny that many of these issues are important to 24 resolve, but unless both industry and NRC manages them 25 judiciously and carefully and in some order of r-- NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

s 35 F I priority it will face significant impacts on our 2 operations, our costs and our striving for excellence 3

and, as the 1981 survey concluded, potentially on 4

safety. It might be nice to tackle all these G issues at once, but it's impossible for the industry 7 and the NRC to do that and do it right. Neither of us 8 has the resources. 9 Another area of concern is the time it 10 takes to resolve issues. For example, in December 11 '87, NUMARC requested that the NRC develop an interim 12 standard for hot particles. The reason was that our 13 personnel were receiving significant and unnecessary 14 whole body radiation exposure, to say nothing of the 15 cost. of more than $1.3 million a month trying to 16 comply with the staff's requirements. NRC agreed that m 17 an interim standard could be developed in a relatively 18 short

time, but not until NCRP issued its 19 recommendations.

NCRp subsequently transmitted its 20 recommendations to the NRC in. June of '88, but it .21 wasn't until August of '90, two years later, that NRC 22-issued its interim guidance in Information Notice 90-23 48, enfo. cement policy for hot particle exposure. 24 The impact of this problem was well 25 documented in. en industry-survey covering over 90 W NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

m o I 36 1 percent of the utilities and discussed with the NRC in 2 June of '89. The results of that survey indicated 3 additional whole body radiation dose occurred of up to 4 20 person rem per reactor per year. A 50 percent 5 decrease in productivity occurred on jobs where hot 6 particles might be present. Seventy-three cases of 7 documented heat stress occurred, at which 43 resulted 8 in medical follow-up due to the requirements for 9 multiple layers of clothing to " protect" the 10 individuals. 11 The technical specification opproval 12 program is another example of an issue that has a long 13 and protracted history. This issue first arose out of 14 ':he TM I accident when NRC published an advanced notice 15 of proposed rulemaking in July of 1980, followed by a 16 proposed rule to split the tech specs in March of '82. 17 The industry became actively involved in March of '85 18 and established a group including all four vendors 19 owners groups to work with the NRC. 20 The NRC's interim policy statement on 21' technical specifications was issued in February of 22 '87. This provided the criteria for the split of the 23 tech specs. Although the guidance for the split was 24 established by the Commission, items continue to be 25 added without technical justification, some that are w -. 1 NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

g- !1 s 37 F I not even in the present standard tech specs. The 2 industry spent over $20 million and expended thousands 3 of manhours in support of this proactive, voluntary 4 effort to achieve these improvements. Today we're 5 unsure that our efforts would produce the results we G. all desire. Significant resources have been expended 7 to keep the program on track und when senior NRC 8 management ge t s. - i nvol ved, the process works.

Thus, 9

it's clear if we're to succeed - continual senior NRC 10 management support is essential. 11 Our focus as an industry, and l's sure you 12 share

this, has been to make the tech specs an 13 operator friendly document, not a licensing document.

14 It's generally agreed that one of the key values of 15 technical specifications in to communicate to

10 operations personnel exactly what the important limits 17 and limiting. conditions are,for safe plant operations.

la With the time and money apent by the industry and the 19 NRC to go back to business an usual, to continue to 20' add a few more items to the technical specifications .21 without~ appropriate technical Justification would be a 22 major step backward on an issue we both spent over ten 23 -years to correct. 24~ .Yet another example of an unnecessarily 25 long closure time is the issue of diesel gene-stor s F NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

v 38 W s'. I reliability that Jack discussed earlier. As he 2 indicated, the intended goal of the generic issue 3 identified in '74 and codified by the station blackout 4 rule in '88, was to a t. h i e v e a reliability for demand 5 of 0.95. Industry performance has not only achieved 6 this

goal, but surpassed it, yet the issue still 7

remains open. 8 Very

simply, we're frustrated at our 9

inability together to reach closure on issues like hot 10 particles, technical specifications, diesel generator 11 reliability and many others on a list in a timely 12 manner. It's discouraging to look at our list over 13 the past three years and see that only a few items I have been closed and quite a few have been added. 14 15 In sum, the growing nature of the problem 1G is inconsistent with our demonstrated performance. 17 Even areas that seem to be working relatively well. . 18' like procurement where the-industry took the 19-initiative and demonstrated that it could respond to a 20 potential problem without requiring prescriptive 21 regulation by the NRC, are still a concern. The staff 22 recently issued SECY-90-304 describing our procurement 23 initiative and the'NRC staff's plan to assessments at 1 24 selected facilities, the implementation of the ~ 25 dedication programs, and ti.e improvements made in the r l u_ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

ya

1. )

i 6

4 i i 39

-t -1 1icensees' comprehensive procunment' program. 2 We understand the need for NRC to assess 3 our-performance in this area e id to take enforcement 4 action when violations of NRC rules occur. But we 5 must all recognize that it takes time to make G-effective changes to programs. In this area and 7 others, we're concerned that individual licensees will 8 feel real or perceived pressure te-conform to, 9-individual NRC inspectors' views of what's needed. g. 10 We're even more concerned that licensees will be i . 1 11 , subjected .t o regulatory penalties as they work to 12:

implement the- 'procuremen t initiative and others like

^ 13 it.. That-would

quickly-choke off

. licensees' a 14' willingness to seize the initiative and:r.olve, problems -15' on their own. j 16 I~ hope-senior NRC manngement-and the. -l -j ,17-industry can work together to assure that this doesn't- ..c, ,1 u8' happen. T'm -told that -NRC senior management. K, N" - 19 recognizes.oti concerns and is.willing $o work with us 20 'to make-this program. beneficial. But to be 21

successful, it requires tha t.. seni'or. management stays-

'i j 22 involved-j,,< M 23 We've been encouraged by the Commission s 24 efforts to undertake-the. regulatory in. pact survey. 25 The sur.ey identified many problems. For example, the g,, - OF' I, NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202)-234-4433 l

6= 4 s i f -' I 40 1 -. = impact.on our operations and on our managers and 2 supervisors from NRC inspections; the number and 3 frequency o f. generic communications and the way 4 they're-used inappropriately to impose requirements on 5 licensees;- lack of prioritization by NRC of pending -G regulations,- generic communications and other J 7 guidance; the cumulative effect of generic 8 communications; the impact of SALP on our operations m u 9' -and-so on. 10-Correction of each of these, in our. view, i 11 calls-for the attention and continuing involvement.of 12; senior :NRC management. Let me assure you that our l 13 tindustry shares with you the goal or a nafe nuclear

• k 14

' plant operation. We're not interested in dodging this - 15' res ponis ib i lit y. - The industry. has a big stake-in .a 16 strong and tough and credible NRC which enjoys: the Ll? confidence. ~of the public. We're committed to doing E

18 the-things that ' are necessary and doing them: right.

m 19-That's the. cnly way we'll: continue our. improving y 4 L20 performance trends and achieve safe.. efficient, ~ ,j pp ' 21 reliable operatio'n of our plants. ,l[ m '22' We've gone to great lengths to create-v .23 institutions and networks, like the Institution-of f, q [ E-24 Nuclear Power Operations, the National Academy of s 25 Nuclear

Training, and NUMARC, to help all - nuclear.

i + NRAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 l

== 1

o u'6; s

l1 43

p

-l utili ties, achieve those objectives. I don't need to pp 2' remind you that some of.thoce institutions' -have 3 3' significant powers of persuasion that can be and are t 4-employed to focus the attention of any member that L 5 loses sight of the industry's mission. 6 The steady impr( /ement of performance 7 indicators during the '80s stands as evidence of.our 8 ear nest. intent to improve our operations. We offer { 9 our. observations on the impact-of the existing 10 regulatory environment and the expectation that you'11' 11 take them. constructively. We think'it's. crucial that ~12 the underlyin'g root causes of the< concerns and issues 4. l i l3 ' facing us are resolved and stay resolved.~ [ 14-We're anxious to respond to the staff's ] I* '15 plan :to correct the-problems ide: _ified by the 16: .regul'atory impact = survey,' but our' views. can be 7.g I ,117. , considered'by you as you' proceed. @e As: .an. industry,- one of the most signifi-

18 4,

YL 19 cant lessons we've

learned, with your help, is. the t

l-if p N '20 absolute need. for senior management isolvement and- 'J ' pj 4 21: attention.in all areas 1of our. operations. Similarly, 'l g s y g, 22 we think it's essential ' fo' r ;NRC senior management-to'- .1 t .o

become ' intimately. involved. with the ' details o fs the j

23 m i ? 24 reguletory: process where attention is needed, whether' I w ~25 it's sitting in on-meetings of-SALp boards or i r- .t 'NBAL-R. GROSS 1323 Rhode Island Avenue, N.W. . Washington, D.C. 20005 (202) 234-4433 y

o .i 42 3. .. s ,1 enforcement - conferences, participating on inspection 2 teams or reviewing the interpretation of regulations. 3 Regulatory

agencies, no less than 4

' corporations, require careful involved management. 5 Without that, I fear regulatory impact survey in the G . year 2000 would echo the one done this year and the .i 7 one done now ten years ago. A stable regulatory 1 8 process is vital to the success of this industry's 9-self-imposed obligation to achieve excellence in its n 10 nuclear operations and thus to the future of nuclear 11-

power in our country.

12. 'A stable process is one in-which f 13 requirements are . applied uniformly, in which j.__ ; 14 interpretations do not vary from plant to plant and j;' 151

region t o'

region, in which regulatory.. changes are t;

16. Learefully. screened for real' benefit. W, N .17-A' stable regulatory process is. flexible.

"i

.151 It ~ sets' priorities' among ~ issues Jand requirements and i m [ 19-allows licensees time and latitude ' to make necessary j t.,

20;

' improvements in areas like . maintenance and N.l 21 procurement.- This deman3s continu'al senior regulatory ((. w l 22 mar.agement = invol vemen t. j

j 23 Perhaps most import ant,

-a stable process ll)f ' '24 is interactive and requires-an honest, professional 25 and open' arms-length relationship between' the. t NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Wushington, D.C. 20005 (202) 234-4433

s- _ s; (j, i 4 43 i I 11 regulator-and--the regulated. 2. Specifically in the areas of maintenance, t 3: procursment and operator requalification, we think ^ we've'made real progress in that matter. I hope and ,4 A 5' believe we can apply those lessons to the many other 6' important issues we face. .e. w 7 Thank you for the opportunity to speak e 8 candidly with you.today. We'll, of course, be glad to 19-answer'any questions you might have. -10 Thank you.

t

. t .= l'l = CHAIRMAN.CARR: Thank you. A 1. ~12 Questions, Commirc'oner Remick? y. ..(# COM'ISSIONER REMICK: Roughly a handful, I.

13-M

'p?: 1.4 s guess, of questions and observations. But first,-I do 1 [ 415) 'want t ot say th'at. .I do appreciate -the candid 16 discussion. One of.the things that somewhat-surprised f 4 .m.. m e" ' a s 'n Commissioner'is sometimes wha't I hear. out in 217- -i,t l18- .the-field is' not-what'.I henr at this table.- I think j a' liR s 'you've been very straightforward this morning and I r. 19( ( + a. ~ l 1 ?20' certainiy-appreciate your comments. L, ,. o : s 21. I have a couple questions. You indicate, n m22 and 1 know from our staff information, that based on W 1 v ,d< E$3 tlE ? maintenance team inspection so far,- and I think s 0 + q ifb;

g., F

~ {.. "24.1 about three-quarters of them have been conducted,

25) there are three have. been graded poorly, two have

@@ 7 g-7,' f+t ( t h

t

NEAL R. GROSS VU 1323 Rhode' Island Avenue, N.W.  ? !U Washington, D.C. 20005 (202) 234-4433 qf 7 n.m w C Ojy y,l; ai,

g. e t. a-4 l.. + 4 44 'rd-T M -1= programs but not implementing and one they didn't have ar 2 a program. Without speaking specific about those 3

plants, but in general, what is industry doing to 4

address what I would call outliers in that area? Wy 5. MR. BRONS:

Well, as I

mentioned, 6 Commissioner Remick, the 12 stations that the industry - 7 felt were in: most need of additional help have been \\ h 8 nthe subject ~of special assist visits from INPO dealing i

9 with that..

In addition, we've made.a concerted effort l l' 0 - .to involve the folks at those stations as peer a g ai '11~' evaluators, thereby taking'them out of those stations 12 and ' tnking them-to other stations to see maintenance

13 -

programs? in action. that are functioning well.-

To o

9 4 bl4!

date, 11 of those 12 stations have provided a

n L15 o maintenance peers and the -one remaining station is + a n N[,;9 !16: < scheduled to do so,before the year isLout. Y' . $173 .So, that's the primary. focus that we have Or t V 1181 to improve -- r. n L '{m (19 COMMISSIONER REMICK: So, assist visits-- t 1 y - ' l20 through assist-visits? $H We,. 9 :. 1 <V J

j. 21 MR.

BRONS: 'Yes. I might mention that' y 7 1 t + '22 they're a v rather. di f f e ren t ly.- craf ted i ssist visits in-l 'E ' j p W 23: that. they-not - only. involve INPO: st aff, peers from e + p; 24-other stations, but in.these visits they also include -25 as a member o f-the evaluation team people from the 3.3.:a - 7 ;& _ NEAI. R. GROSS 1323 Rhode Island Avenue, N.W. Washington,,D.C'. 20005 (202) 234-4433 I )

= ---.--wum 45 "I-1 utility being evaluated, which is designed to help in 2 , the buy-in process. So, they become involved in 3 - seeing the problems and become a part of the 4 resolution. 5 COMMISSIONER REMICK: I assume because G -they are general ~ly assist visits that they are (' P 7 requested by the outlier utility, outlier plant? 8 MR. BRONS: These were -- I suppose that 9 you could say that. It's sort of a euphesism,.but -- 10 MR. CLARK: They were agreed upon. 11 COMMISSIONER REMICK: Okay. All right. = 12 ,0kay. 13 MR. McGRATH: The other thing that's very a 14 helpful. in-the maintenance area is when maintenance ~ l5 people -go-to other plants where it's done -well. w s, 16 They're doing a lot;more of that. It's very helpful. 1 17.. Many-of: ou r..-m ai n t e n an c e supervisors don' t believe it = 18' .because:this is the way'it's-a' .vs been done. That's -19 'been very helpful. 204 COMMISSIONER REMICK: Well, _those are 1 4 + 21; always very; helpful, yes. f 22 'MR.. CLARK: I think also, and Jack'I think 1 23 'maybe-addressed' in his earlier

remarks, the INPO t,n process now, at-every plant for the last QA,,

evaluation ~ 24 4 O= 25 I'll say year or more, has had increased focus on. E b -I til NEAL R. GROSS y, i 1323 Rhode Island Avenue, N.W. .. s.i - Washington, D.C. 20006 f.[ (202) 234-4433 y,

p-li.. l._ 46 t 1 maintenance, additional people looking at maintenance 2 and has picked up new techniques. For example, before 3 INPO goes to a plant, they look at the NPRDS data, 4 identify what. equipment at those plants may have lower 5 reliability than average and so they use that when 6 they go to the plant to focus on those particular V .7 problems and then pull the thread back to wherever the 2 8 cause might be,' including maintenance. So, the assist 9 visit was a one time 12 plant. The evaluations are a \\ 10 continuing, much broader and 1 think better focused I .11 look at'every plant in each evaluation. - 12. COMMISSIONER REMICK: You introduced my next ' question and that is on the.INPO developed .t 14 mnintenance standard that you proposed to and =' 15 , indicate the staff hasn't responded yet. Ilow do you 16 plansto'use that or ho'w: are you'using it? I imagine 17e ett'would b e - i n ; y'ou r evaluation. visits, much like you i 18 use similar standards in . training .in corporate 19 evaluatinn. Am I correct or wrong?- 20 MR. BRONS: That's correct. '21 COMMISSIONER REMICK: Mainly are you using i-it now or not? i ' 23 MR. BRONS: It isLbeing used now, y 24 COMMISSIONER LREMICK: It is. Has it-i . 2 5 '- demonstrated; to be effective based on those L -, ment NEAL R. GROSS '1323 Rhode Island Avenue, N.W. Washington,,D.C. 20005 -(202) 234-4433 ^

,4 =- 47 F~~ '1 evaluations? 2 MR. BRONS: It's used in two ways really. It's used by the utilities in their own self-4 assessment and identifying areas where -they need to ' mprove and then it is used as a part of the INPO 5 i G evaluation-to provide a candid and subjective [ 7 evaluation of how well they've achieved those 8 individun: criteria. 9 (,0MMI S S ION E R REMICK: So that's how you 10 would implement or are implementing the standard is 11' through evaluation and self-assessments? Okay. 12, Inf~rvo* ion provided to us was that as ~ 13 - part of the ptoject on maintenance performance p: 1 14 indicator that -there was a difference between the i 15 industry and the NRC on where-there were failures op 16- .whether one attributes - that to maintenance or not. 17 That does not necessarily. ' surprise me. In fact, it's 18-one reasoni that 'I was personally not in favor of an 2 19 enforcement' escalation when you had a maintenance root J h,, l20 cause,because I think. people see different maintenance 21 differently.: What we call maintenance. we think we 22 _ agree, but when it comes.- down to it, we don't. It's ah, '23. like what's operations, what's -training, what's -24. engineering. We think we know until we start talking l "26 about.it and find we have differences. -c 'I i _ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 W, (202) 234-4433

r e '4 .C.. l . J. 4g j r-l. My question is has industry tried to 2 uniformly defined what you'mean by maintenance? Is it 3 3 possible? 4 MR. McGRATH: Very difficult in the fossil S area. We have a number of fossil plants that have G - identical equipment. In some plants the equipment 7 runs better ' than in other plants and it takes the 1 the maintenance is done centrally. It~ -8 maintenance 9- - kind of takes the maintenance out of the picture. So 10-you really need to look at the root cause. In another -11

case, because maintenance hasn't maintained the

~ 12 automatic controls _and L-operators got too many things 13~ oni: man u al, too much challenge and he makes a mistake, 1 N- .14 .'is that;an operati'; error or a maintenance error? 15-I think it's very difficult, in all cases, c' and.. many times-t N

16 :

tol pin.i t-down to ' one specific cause 17: it'sla:' combination of things, m ,18' MR. CLARK:- I'm not aware of any. industry 19 effort..to develop a common definition, i r.i. 20: MR. LEE: I guess 7' would'.say that the 4 } 21~ '- INPO guide in a sense is : - ' I don't know if it's a ( [:. 22 definition.or if it attempts to embrace the areas that ..a I 23 are ' involved and important to maintenance. I ' think 1 24 maintenance.in the industry's mind hcs been: in the l '25 fact'- 'and I-think that was the-difference-that came

1. ~

4 4_, NEAL R. GROSS w '1323 Rhode-Island Avenue, N.W. Washington, D.C. 20005 p (202) 234-4433 7 w y. 5 NE

,Y ME 4 tp r g 49 h.1r-- z t_; _1 out in the defini' ion of the discussions with the that industry looked at 2 staff on the indicator ? maintenance pretty much as the hands-oi, physical 4 repair work and what have you. I think that's -5 broadening considerably in the

past, but that 6

guideline takes in other facets. I think as Jack 7 indicated, it's pretty consistent with what the NRC 8- ,has suggested in the-policy. 4 9 MR. ~ CLARK: I'm not-sure myself that a 10 common definition would be that useful as compared to L 11. working on making all aspects.of the thing better. 12' COMMISSIONER REMICK: I don't-know if one-13 could do it either.. I ' m.: not suggesting that. I'm 14' just wondering if-there has been an-effort to define-15. what you.mean-when you mean maintenance und if-ee've 1,6 done it when we've'ta'lked about maintenance. J171 MR. DRONS:

1. !think-we.do 'tLwithin-the i

4 18-. individual-utilities, Commissioner, Remick',- because m -19s most of.us

track, for-instance, preventative.to 20~

corrective maint'enance ratio, a thing that=is actually m'O# _21' satisfying and turns out -not to work on en inter- .22 utility. comparative basis but is'u'seful'as'a tool. In s e, 'W l23 order to do 'that. we' ve had to, define within-our. own g pj <24-organizations where we draw those. lines so'that the q 25 - data can be. binned to give us eomething that' we use. 7r--1 J,j l 6',x .'~ .NEAL R. GROSS e*, i 1323.Rhode IslandcAvenue. N.F. Wa s h i n g t c.n,.D.C. 20005 W [ g g; I , \\\\. (202) 334-4433 m' d i .Ws n.

_f 3 50 . T r- -1 But collectively, the same problem and the very v_ i 2 problem that -you referred to, that we're not all '3 viewing it identically. + 4 I think we've also concluded that there i 6 doesn't appear to be any great benefit from forcing a O. collective-definition. o 7 CC+! MIS S ICNE R REMICK:

Well, one of the 8

problems 1.' v e a l w a y s had is I think you can have a 9 very. good maintenance programs, but things will fail. 10: Maybe they weren't designed. properly with strength or 6 11' the proper materials or-in' manufacture and things like .12 -J -that. Now,-one can relate that to maintenance, but n somecpeople might not relate.it to maintenance. So, 613 e + L- '14 J that 's - a problem I always see, that yo could have ~ m l16; good maintenance and you're <. t i l l going to have [ failures.- I-try:to: maintain my car, but-unfortunately 16

17. -

fthings still break-on.it, d

18 -

MR.. COLEMAN:' 'Mr. Commissioner,- I was , 19 [, goingsto comment'that in the maintenance effectiveness' i ~. 2 01 'indictorfreport;done by the industry,'we have. defined M, maintenance'in the: sense.of the way that: we evaluated 21 g -(22 y .i t, whi ch was consistent, with' the' -definition within W c lA ' ,M23;,' -the

• nuclear plant reliability data: system defined.by-r

+ 245 iNp0- so' that we ' had a -consistent-definition. I 251 ' believe that 'that definition, for the most part, is (

7

.&^ v,+ ', i NEAL R.-GROSS. ii-li: 1323 Rhode Island Avenue, N.W.

?

Washington, D._ C. 20005 '; M. y l:? -'(jL (202) 234-4433 W-o l -Q* y

y c. 51 -s I agreed to by the staff. It's when you go to take the 2 next -step to actually place a component or evaluate 3, it., as was indicated, that that becomes an 4 interpretive issue. 5 I might mention that in that report, to 6 follow up on your last point, we did identify through 7 a very detailed review of component

failures, the 8

percentages attributable to the various categories. 9 If you take 100 percent, and I forget the exact number 10 of component failures we evaluated, but it was a very 11 large number, that 13 percent were attriLutable to 12-maintenance, 35 percent to the original design, 25 i-13 percent to manufacturing, and about.8 percent to other r t G M 14: factors such as operational factors like Mr. McGrath .15 ~inificated, and then about a 19 percent category where '16 we weren't sure because-from the failure reports from ' i 17 L the data,- even going back- ~and talking to the '~ 18 individual' plants and the maintenance supervisors and L 19 mechanics',. we. couldn't reconstruct that-type of o 20, information.= So there was that uncertainty in there. o 21 But we did share that information with the 1 ' 22 -staff in great

detail, including these subsequent i

23 follow-up_ evaluations. 24 COMMISSIONEk REMICK: I think that's the 25 data that we evaluated and 75 percent were maintenance n NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 i (202) 234-4433 I

g.

o- .u ; 52 'i .[. I

related, p.

2 MR, COLEMAN:

Yes, sir.

That was the ~3-starting point. Q( 4 COMMISSIONER REMICK: So it's obvious we 5 have differences in definition. G Moving

along, you mentioned that the 7

diesel generator reil i ab i l i t y was greater than 0.98. 8 Was that for all plants or was that a median or 9 avarage or -- 10 MR. BRONS: That's average. 11 COMMISSIONER REMICK: So, were there some plants-below.95? 12 13 MR. BRONS: No, sir. ,3 i t-14~ . COMMISSIONER REMICK: All above -- J 15 MR. BRONS:- If there are any, I'm not k 16 aware of it because all of'un~have made a commitment c = 17-and,the lowest. commitment that was ' tolerated in the t 18' station blac.kout rule,wes 0.95 and I'm not aware that t anybody has fallen below :that. '205 COMMISSIONER REMICE: Mr.

McGrath, you m.M y 21 suggested we should have a priority' system, but that's s

}[ 22 -not very specific. Did you have'anything in-mind.on .one system of priority, first 23 how we-establish S be somebody's g, 124 come, is 'what you consider.- That can . r. '25 priority system. Is it risked based, is it judgment 4 -t_ NEAL R. GROSS P, 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

i e 1 53 r-I based? Do you have anything specific in mind when you 2 suggest that we should have a priority system? 3 MR. McG R ATil: As managers, we all.have to l 4 prioritize our work. I think what concerns us is we [ 5 have this list of 57 issues that could be called .l 1 6- " priorities." But there's too many of them to focus .i i 7 on and prioritize. I think what we need to do is 8 agree neutrally that these are the issues to work on J 9: and have some kind of a plan to bring them to closure. ~ 10 What happens -is when we go carry these things 'll along, there'a:someone in-the plant or someone in the '12 company or some group of people in the company that l 13 are continuing to keep up to date on these issues and ] ) 14 monitor them and'whatever. That distracts, it seems ( '15 to me, from better uses of=their time. 16 ' COMMISSIONER REMICK: I understand that,- .i n ] ~17 but I wondered =if you had a specific suggestion when .i on what it' 18 you suggest we have in priority system,.

q

1. fe.

19 ! should be based on. o 20 MR. McGRATH:

Well, some of these items.

O 21 are.on the list'and we.' call them our priorities.

But, g,;p q

l 22. we think-they would need-to-be closed. I would guess q 0 23 maybe:25. percent or maybe more, Byron, of that list? s q 24i MR. LEE: Hight. h y ,i y 25-MR. McGRATH: And that would allow us to g q g r-~ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. ~ Washington, D.C. 20005 c (202) 234-4433

m j c i I 54 v. I fre-up some resources, focus on the others and get 2 those done. I think tha t. 's ' pa r t of what we ought to i 3 get.toget her on, what's a good priority system. And 4 once we agree on that, work to get it done. 6 COMMISSIONER REMICK: Okay. One final G comment, the discussion on tech specs. Commissioner 7 Curtiss and I~were just earlier.this week talking. a -8 little bit and I was relating some of my past history, i When tech' specs were first being developed, I was in 9 10 charge of a test facility and Marvin Mann-at the NRC 11 was the one handling that effort. I remember in those 12 discussions I know we visualized tech specs as being- ' 13 ~ six or seven pages of very important measurable 14 parameters that-an operator would be able to measure 15 and observe a n d -- s a y, well, we're within tech specs or 16 not. 17 .Now, I' realize thatlthat was somewhat of a 18 very - naive approach, : but i n' t h e early_ ' days. when we i - 10 ' talked about tech - ' specs, that's.what. people had. in 20 . mind, at least-operators had.in mind,with tech specs. 21; Later-on, when I did operator licensing

exams, 22 especially-for SRos and got into tech specs, I.became

.23 -aware that they are not comprehensible, understandable 24 to operators. They're very operator incomprehensible. 25 So, I-appreciate-what you're-saying.. I realize-that

U 2_

NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 -(202) 234-4433 4

2

.,is q -/1 55 P F l' my, na I say, early approach to tech specs is pretty 2 naive,.but I agree that it is something that we should 3-continue to work on because from an operator .4 . perspective, especially in time of any kind of 5 immediacy, t rying ' to figure out where in the tech G specs it's covered and is it only covered once and 7 what's the information, that's extremely difficult. 8 So, I certainly agree with your sense of that needs x; 9-continuing attention. 10 Thank you, Mr. Chairman. 11 MR. CLARK: Could I comment just a r . 12-minute -- l ' h 13 COMMISSIONER REMICK: Yes. Yes. g on your priority question? +- . 14 MR. CLARK: IS' 1 may be speaking only for myself. First, I think the t n industry has reached'.the point where it is very 16-il7) unlikely < that.a. newly emerging issue is: of imminent 18 s a f e t'y significance.and n'eeds to be on the-list and i f1" .uoing worked on'right now. .One way to get at-this is i i, 120 .to-focus on the things already.on the list and close. .? l21-them out ' because each time we ad'd one - to the list, a J 22-somebody starts working on it and maybe that's an j. 1 m, a e --! 1 23 aspect of not closing out the older ones. w; x 24

Now,

.i f: you truly came up with a new l 25 reveletion threatening to se#-ty, obviously everybody NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o. . e i \\.- 56

r--

1 dives on it. But the industry at the stage it's at, I 2 don't believe there are many of those. So, maybe we 3 could help ourselves if we put priority on closing out 4 existing issues, accumulate the others, but not start 6' putting effort on them until we get the old ones G-closed out. 7 COMMISSIONER REMICK: Thank

you, Mr.

8 Chairman. 9 CHAIRMAN CARR: Commissioner Curtiss? 10 ~ COMMISSIONER CURTISS: I have a handful of 11 questions as. well. Let me pick up on a couple of -12 ' points that Forrest raised. 13 = First on the priorities question, and I do u- '14-think that's an important question fer us as an 15 agency. It's been identified in the regulatory survey 16 that we've recently conducted. The initiatives: that 17; the! staff.has proposed to - address that

concern, I

18

think, involve some' very positive efforts.that I

l19 : encourage you to comment on, particularly what's U 20' referred' to: as the .IRRIS effort to integrate = 21' 'requirem'ents.- gg. 22 1 ' guess. I' ve been-disappointed over the m 23) years. t hat. some, of the programs that we've had in 24 place, such as ISAp and integrated schedules and-so 1 -25, forth, haven't'seemed to provide the proper vehicle or

~

N r- 'L, NEAL R. GROSS 1323 Rhode Island Avenue, N.W. [/ Washington, D.C. 20005 (202) 234-4433' + ~

o a 57 I 1 .an acceptable vehicle for getting after this question. So, I urge you as an industry and the individual 3 licensees to comment on that survey when it is 4 published here soon, because 1 do think that's one of 5 the areas that we could focus some attention on. 6 Let me ask you, on your list here, I see 7 you've alphabetized your priorities here, 57 of them. 8 Let me ask you to name what you think are the-top 9 three priorities on this list. 10 MR. BRONS: Okay. We actually went over 11' this this morning a little bit. 12 Joe, why don't you.run through that list. 13 MR. COLEMAN: All' right, sir. Maybe by r -14: wny of not answering your question initially but 15 coming to the final answer, let-me indicate-that this 4 '16 ' list' is a combined list of twa groupings that we 17-utilized to try to get at where to focus the resources ~ 18 - of not only the NUMARC 't.aff but-where the industry's 19 resources need to be forased. The criteria that we 20' used-to evaluate where an-issue falls' includes items 21 such as its importance to the industry its importance p, 22 to safety, obviously, reliability, economics. But [, ~23-Lalso there's an - element of -':two other elements that 4t, 24' are important, one -being whether'or not these issues 25' can be closed out by the involvement of.the senior L . - t-NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 l (202) 234-4433

[ y 58 i 1 . management within the industry. That's an involvement s_ 2 area that I believe we've provided these examples to 3 you previously in this discussion of the 4 prioritization system. 6 The other one has to do with

timing, G-whether or not this issue needs the active and 7

resources of the industry being applied to it 8 currently. So, what we have is a lot of movement i 9 between four levels of priority of generic issues that 10 we are addressing that trenegresses this, transgresses y 11 the-various lis'ts, depending upon the point in time'of 12 closure. 13-So, maybe by way of

example, station

_m 14 blackout was on the top of the list. We're expending 15 significant. resources on that.= It's on this list, but 10 if you really looked at our specific detail list you'd t -17 finil -it's at the.second level -down. of monitoring s 11 8 because we've completed the interactive at work with 19 the-ataff and we're not in the process of implementing-1 20 those actions throughout theLindustry. So, just from-21' .that perspective, it's very difficult. to pick the a t 22-top -- 23-MR. BRONS: Joe, why don't you scan'down 24 thet list and just t 4 25 MR. COLEMAN:- If I could give you a couple L-NEAL R. GROSS. 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

e"4 59 {; 7 1 of examples, perhaps. Access authorization is an 2 issue which we believe was closed out by the industry 3 in 1986 and we're still awaiting action by the 4 Commission. 5 CHAIRMAN CARR: How can you list it as a 6 major issue if you think it's been closed out? n 7 MR. COLEMAN: Because within the industry, 8 Chairman Carr, it is still causing uncertainty across 9 the industry -- i '10 CHAIRMAN CARR: Uncertainty and a major 11 issue are two different things. f 12 MR. COLEMAN: But it's still requiring a 13 dedicated amount of resources, interaction with the 14. staff. We continue to expend significant industry 15 resources on trying to define what access requirements .16 ' are acceptable for entry into ' unescorted access of .17 nuclear power plants.

We still have that issue as a 18 major issue effecting the industry' that requires 19' closure.

o j .20 MR. LEE: And it. creates a problem for the 21 industry in. individual utilities in what their program ' 22' really should be. 23 CHAIRMAN CARR: Problems and major issues ( L24 are two different' things, in my opinion. 25 MR. LEE: Major issues would be safety i NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202)'234-4433

o 60

r-:

1 . types of issues in your opinion? s-2 CHAIRMAN CARR: It was his question. I'll 3 give you the' major issues on that list if you want my 4 opinion. 5 COMMISSIONER CURTISS: I see you have the G same difficulty explaining how you set priorities that 7 we sometimes do within the Agency. Let me ask it 8 . differently though. If yc u were to suggest which 9 three issues on-this list we as a Commission ought to 10 spend our time on and focus our effort on and provide b ~ 11, the top down and the emphasin'that you've talked about 12 here in a number of earmarks. I can-give you my ,,4' 13 three, bst I want to hear your three. I know what' 14 we're spendir.;; our time on. 15-CHAIRMAN CARR: Well, I want to see if we 16 can agree on three. '17 COMMISSIONER CURTISS: Right. .( 18' MR. COLEMAN: The issue.that I would say-19 is,the first and foremost issue for the Commission to 20 address is the one on the second page entitled. 21 " Regulatory Environment and ' Impact. " That was the 22; focus of most of the comments and'that's..the area:that L23 'I believe we are expending most.our energy and. efforts. m ri 4 '24 within the industry. The issue of standardization, o 25 licensing reform, I would consider it also at the top -r, L. i s, NEAL R. GROSS v-y m T 1323 Rhode Island Avenue, N.W. "/.. Washington, D.C. 20005 (202) 234-4433 U,

0 lic,

s,

x 61 . i= 1 of the list; The third issue would be that of license -2 renewal from an overall industry and national 3 perspective'-- 4 CHAIRMAN CARR: You got three of my four 5 anyway. + 6 COMMISSIONER CURTISS: You had two of my 7 three. 8 MR. COLEMAN: Okay. 9-COMMISSIONER CURTISS:

Well, that's 10 helpful to know.

I realize that this -- I know how 11 these-lists get made-up when organizations get 12 together and everybody puts their own issues on the 13, listthat they're working on or of ' concern to them 11 4 without perhaps the same. prioritization within each 15; organizations. But it's helpful, I think, to know. .i a 16 As 1 say. I would.have listed-advanced

reactors,

=17 . license renewal as two of the three issues on the 1 18; -list.- There'.are others-here that are obviously taking g 1

19 fa good deal' of our time.as-well, but it's helpful to

.3 20 know-from your. perspective what you think the top two 21 'or three. issues are of these 57. i iMR. LEE: Commissioner, let me make ~ a 22 3 23 point t hough.' t hat Phil was making, that those are p. 24 maybe f r o m '. a broad general industry perspective, the ' 25' issues. But I think from the impact on the. operations ~ NEAL R. GROSS .1323: Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 s o,

v. p G2 1 i r e _ 1 and the day by day of the plants and.what have you, I-2 think phil_'s point was some of these issues that have l 3 been around a long time need to come to closure. I 4 would put the tech spec program we were talking about 5 in that. I think another -- a i G t' R. CLARK: How about Commission detailed .i 7 involvement, maybe some kind of agreement that l 4 8 looks -- set a goal of shortening the list? 9 CHAIRMAN CARR:

Well, the tech spec 3

10 improvement program, we've all waited a long time for 11 -the you know who to come in and now we've got to get' ~12-it back:out..It isn't as if we've been ignoring that. i .13. As you've

said, it takes time to make effective l

'14 changes to programs. Your schedules that you come in 15-withton what you're-going to do over a long period of ) 4,g IG'

time, to'me,_I' don't see why they should take three or

'17 four : out ages, but I don't argue about it. It seems ~' 7;g ' 18 - 'like'a long time. I'm sure it.seems like'along time. j c 19 for us to do what you want to.- Tech :spe s haven't 1 o 20. been: where. we could change

them, in my opinion.

f 21 They're there_now, but I'm'not'sure --- .t 22 JMR. BRONS: Chairman Carr, if21 might' add- .j 44 M. .23 'though, I understand the point. that you made - a',o u t j ym y j[ ' 24 major : issues and ' problems. But I would add. Just this g 'S access authorization thing, it's been hanginc o,>en for-r---

t. ;-

NEAL R. GROSS l 1323 Rhode Island Avenue, N.W. Washington, D.C. '20005 (202) 234-4433

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f 63 I I a long time. It is not a significant safety issue, 2 but when our station manager has to get involved in 3 determining who or who cannot gain access to the 4 station, his attention is being diverted from the safe 5 operation of the reactor and it's an issue that abould 6 he closed. We need to deal with it one way or another 7 and then get on with it. 9 MR. McGRATH: It's not something that's 9' benefiting fron' more time. i 10 CHAIRMAN CARR: You can separate out of 11 that list those issues that you think should be 12 closed, then I have no problem with that. But those 13 issues certainly -- if you think it should be closed 14

already, you're not putting much

" massive utility 15 effort" into it. The effort that's putting into it is 16' NUMARC's leaning on us to close it probably. It -17 causen, you some problems at your plant. Okay. I 18 ocknewledge that. But -- 19-MR. BRONS: That's the one place we don't 20 want to have problems occurring. 21 MR. MeuRATH: .That's an important place. 22 It comes down to the plant manager and all of these 23 things funnel through the hourglass into his head. If 24 he spends ten seconds on this, it's more than I think 25-he ought to spend on it. He ought to be spending more i NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

F-64 1 time in watching the operation. If you add these all 2 up, it comes out to significant time. 3 COMMISSIONER CURTISS: The second comment 4 that Commissioner Remick had that I'd like to pick up 5 on is this question of how you define maintenance. Of 6 course, I've taken a look at the industry's comments 7 on +. e maintenance effectiveness indicator and the 8 dira.reement between 13 percent and 70 percent or 9. whatever the numbers are. I don't want to pursue that 10 in a lot of detail, but I guess I'd just toss out for 11 your comments. It does seea to me that the discussion 12 that we're going through right now on the so-called 13 big M, little M question rings very similar to the _14 kind of discussion we went through-on QA a number of 15 years ago when the early focus on QA tended to be very 16 localized and compartmentalized and when it led to 17 what I think were a number of problems as a result of -18 the narrow focus on what one considered to be OA. Of 19 course, we all know how QA has evolved over'the years 20 and become an integrated part of everybody's 21 department and responsibility within the plant. 22 Is it, in the case of maintenance, a 23. comparable situation where we are perhaps at an 24 earlier stage of a compartmentalized focus on 25 maintenance that is evolving into a broader r-- a NEAL R. GROSS 1323 Phode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

.0, G5 T~ .= 1 appreciation that maintenance is everybody's 2 responsibility in the plant? 3 MR. DRONS: Absolutely. We have for some 4 years seer the very important role that chemistry 5 plays in maintenance. Maintenance

issues, the 6

criteria deal with the radiological impacts of 7 maintenance, the engineering involvement of it. So, 8 it's precisely as you define. Everybody sees 9 maintenance-as a part of their responsibility. That's 10 the way the programmatic efforts are going. The 11 individual programs that some of our initiatives deal 12 with, things as small as what kind of material is used 13 'in 0-rings to improve reliability, but the total scope 14 is to bring all these departmental activities together 15 and

say, "We unt,atand we're all in maintenance 16 together."

17 MR. CLARK: I would suggest that calling 18 it maintenance may not be helpful and that if we all 19 thought about equipment reliability, which depends on 20 chemistry,

design, how it's operated and how it's 21 maintained, that that might-help the broader focus.

22 COMMISSIONER CURTISS: I do. I n-

fact, 23 that was the next question I was going to ask on 24 maintenance.

I do appreciate the time that you spent 25 talking-about what you're doing on the reliability I NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o 1 i 66 [_ 1 front. I happen to concur in the remarks and the 2 emphasis that you've given that, that to the extent 3 that you're talking about a results oriented 4 reliability based approach where we look at the end 5 products, citing the diesel generator for example as G one instance, has a lot of merit in this area. 7 I will say that as I've gone around the r 8 country 1.'ve been to plants that give me a puzzled 9 look when I ask them what kind of RCM program they 5 10 have, not knowing what the acronym stands for. I do 11 think there's a great deal of variability within the 12 industry. Some plants, including the two that you 13 mentioned, San'Onofre and Ginna, have been very active 14 and up front in terms of participating and I'm pleased 15 to see the ef fort on that front that is beginning to 16 come about. 17 The one area I guess where I did have a s 18 question really focuses on the' key -- what I-consider r l 19 to be one of.the key elements of an approach like that 20 and that's the ability to gather all of the data on 21 your systems and components. The question has to do 22 with what you're doing on NPRDS. You talked about a 23 couple of things that you're doing to improve 24 activities, including the extension to balance of 25 plant for the 80 or so components, I think you said, I

6. -

NEAL H. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

p.: ;= i,0 ; (4 O G7 It l I I which-I think-is a very positive move. I'm pleased to 2 see that. j 3 In staff's annual look at that program, I 4 think they identified what I recall were three areas 5 of potential for improvement. There continues to be, 6 I

think,

-a wide variability in the reporting from 7 utility to utility, first. Secondly, they indicated 8 about'60 to 70 percent o" the component failures are 9 being reported, so there's not a complete reporting of 10 component failures. Then

third, the timeliness 11 question, the question of whether information comes in i

12 immediately or sometime after the guidelinen. Can you .13 say a 'little bit more on what you're doing in those g 14 particular areas? 15 'MR. BRONS: Yes, sir. Let me address all 16-of those areas. , v '17 As you

recited, we have extended it

'I' 8 further into balance of plant. That was based upon

v..

19. cumulative outage time in.the industry over the last 20 six years or components that caused 12 or more outage A ' 21. . events. I think it was 12 or more outage events in 4. 22 the same period of time. There is another revision of 23 the NPRDS guidelines that are directed specifically 24 towards improving-the reportability and tightening the E 25 definitions of what were reported. So, INPO issued r-l NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

'g a 68 '1 1 'early this year revised guidelines which all the r_ the whole industry is now - committed to 2 industry 3 implement. I think the implementation is due to be 4 completed-in April of '91 or thereabouts. I think we S have the date. What that is is really simplified G schematics broken up by the four NSSS vendors that 7 identify which relays and. components and so on that 8 we're looking at, so that we're reporting on the same 9 kinds of equipment. So, that's being done. 10 Relative to the totality of reporting, that and really the timeliness have-11 that's been a 12 been a focus of specific INp0 looks in their normal 13 evaluation process. Now, industry has been asked to 14 commit to get the timeliness down to under 60 days for 15 any report. That commitment-has been made and I think 16 it's due to be in place by December of this year, and 17 INPO is checking that. I can attest to the fact that 18, they're checking that when _ they come. They're also 19 checking on the completeness ' of reporting as part of 20 their-normal evaluation process. But we've been 21 advised by INPO that that needs to be improved. 22 So, those three specific. areas, I think, 23 address your -- 24 COMMISSIONER CURTISS: Well, I'd encourage 25 you to -- that's a key system. In fact, as I looked i l NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

v .e 69 1. 1 -at the maintenance effectiveness indicator, it seemed 2 to me that the principal reason that our staff 3 concluded that it couldn't be used effectively was 4 that the ability to make plant-to-plant comparisons 5 was impaired by the fact that the reporting isn't 6 consistent and it isn't complete. It may be a 7 database problem as much as it is an inherent problem 8-with the indicator itself. 9 Two other quick areas I guess I'd like-- 10 go ahead, Joe. 'll MR. COLEMAN: Might I comment on that? I 12 think that the -- at least from my view, the major 13. area of disagreement and the reason that the NPRDS 14 database could not be used had.to do more with the 15 fact that>the database would require major revisions 16 to the way the causing coding was done and the in-17 depth root cause analysis prior to reporting that 18-would have to be accomplished to make it an effective 19. use. as an effective indicator. As-a result, the 20 concern that we have, and I believe that's shared by 21 the staff, would be that - that would then affect the -22 actual reporting to NPRDS. So, there's a cause and 23 effect relationship that we think is inappropriate -- ~ 24 CHAIRMAN CARR: Let me piggyback on that 25 .for a second. When you say that you'came out with 80 i g I NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

e-e \\ 70 i 1 percent where design manufacturing are unknown, you 2 didn't go by these guidelines. All those that are in 3 here is maintenance related. 4 MR. COLEMAN: Wel 1,

yes, nir.

1 think 5 that's the definition of -- whon we wert back, what we 6 did to define it 7-CHAIRMAN CARR: These guidelines and our 8 policy statement are pret4y much in agreement. What 9 you guys came out with in the results of the 10 effectiveness indicators is completely different than i 11 that. 12 MR. BRONS: But. Chairman carr, I guess l 13 we're going again to are we working on a problem that l 14 we can solve with station forces that really promotes -15 the reliability and effectiveness of maintenance at 1 16 the station. Design is a. maintenance related problem. 17 There's no question about it. Wear out is a 18 maintenance -- if the light bulb goes to failure, i 19 that's a maintenance problem and most of us decide to 20 let light. bulbs fail rather than replace them before i 21 they fail. But we wanted to categorize --I think we in 22 the industry are trying to focus on thnsc things that 23 we with our station forces and the resources that we 24 have at hand can make an impact on the ultimate L 25 reliability of the equipment. i u-NEAL R. GROSS 4 1323 Rhode Island Avenue, N.W. l Washington, D.C. 20005 o (202) 234-4433 L

.c 71 F-1 CHAIRMAN CARR:

Yes, but that's 2

reliability centered maintenance, which is not a new n 3 term. You all have been playing with this I mean 4-you've had the records for 30 years and nobody has 5 focused on reliability centered maintenance until G recently. 7 MR. BRONS: I really think that's not 8-correct. he have. There is a tendency on the part of 9 many people to assume that ali industry hasn't focused 10 on something unless there is a very well documented 11-program. It's, I suppose, a philosophical question. 12 If you have supervisors that have been running the 13 program for a number of years and they are gearing 14 their maintenance -- where we have latitude to gear 15 our maintenance frequency and so on -- to the things 16 that they have known to fail with some routine and 17 they're keeping up with that. That's reliability-18 centered maintenance. 19

Now, if an inspector, whether it be an-

-20 industry inspector or a management -inspector or a '21' regulatory inspector, comes in and says, "How do you 22 know that?" and he says, "I know that, because I've 23 been working here for 15 years," that may -- it's not 24 always an acceptable answer because you don't have the l 25 engineering background and so forth. So, I really l l I 1 NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o 72 -I e _ 1 think there's been more of that going on. 2 CHAIRMAN CARR: All he needs is to produce 3 the machinery history to show that. 4 MR. BRONS: Well, I think most utilities 5 have had machinery histories. = 6 CHAIRMAN CARR: Whether it shows that or 7 not. 8 MR. BRONS: They were hand-held or hand-m- 9 written and they had all the flaws that those kinds of 10 things had. I also think that most utilities now are 11 moving to computer-based records systems which will 12 improve the visibility behind those decisions. 13 COMMISSIONER CURTISS: Two other -. m l 14 _ questions. Can you tell me you're going to 15 establish your indicator goals for 1995. One 16 particular that I guese I had a question, can you tell 17 me how you're merging what you're doing in that area 18 with the WANO indicators that you referred to? a 19 MR. CLARK: The indicators are the same. 20 I think there's now agreement that INPO and WANO will E 21 _use the same set of indicators, and the process is -22 that they were all given those indicators six months 23 ago and asked to submit our_ '95 goals. We did that. 24 INPO in many cases kind of averaged them out to get an 25 industry indicator, in two or three cases thought that u -. NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 .l l

a 73 I I they ought to adjust it. Those are back to us all now 2 for comment and to reassess our own goals. 3 So, the indicators are defined. They're 4 common. And, within I think the next month there's 5. going to be a setting by INPO based on all the input G they got from the industry. It's the same process -- 7 COMMISSIONER CURTISS: The goals will be 8 domestic. Will there be any world-wide goals, or is 9 it going to be country-specific? 10-MR. CLARK: Not that I'm aware of. 11-MR. BRONS: I'm not aware of any world-J 12 wide goals. We do get reported to us world-wide 13 information. Some-of it's limited.

Really, the F

14 indicators will stay the same, but there have been 15 some subtle changes in the definition, how the 16 statistica are compiled in order to satisfactorily 17 merge with I think it's the UNIPED system of 18 indicators that was in place in Europe. And, there's 19 been world-wide agreement on that now, - which - caused 20 some-give and take on both sides in the definitions, 21 but I think in the long-term you'll look at them and 22 view them as portraying exactly the same information. 23 COMMISSIONER CURTISS: Okay. 24 MR. COLEMAN: I think you saw from the i-25 iemonstration of performance improvements, the two I NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 li (202) 234-4433

o 74 I graphs that Jack Brons indicated; one, the equivalent 2 availability factor, which was domestic; and when we 3 had to compare ourselves internationally we had to use 4 capacity factor because we didn't have equivalint 5 availability factor data. It was not being kept 6 internationally. So, I think from 19 -- starting next 7 year from this point forward with this agreement 8 through WANO and INPO and UNIPED that we will now be 9 able to be able to compare world-wide. 10 COMMISSIONER CURTISS: One final question, 11 I recall two or three years ago there was some 12 discussion within the context of NUMARC about how you 13 all go about verifying utility compliance or 14 conformance with various NUMARC initiatives. In an 15 area like procurement where NUMARC is laying out some 16 steps that it would like to see the utilities take, 17' can you. expand upon-what sort of. verification process a 18 you nse to track utility conforman.w with the-various 19 industry initiatives? 20 MR. LEE: -Well, on a-of the things, at l' 21 NUMARC we do not have any enfercement or compliance 22 authority as s u c 's. But, what we've done in most cases 23 is through surveying ask a survey of the individual 24 company as to what their status is on implementation 25 of initiatives or on particular aspects of it. Many l NEAL R. GROSS 1323 Rhode Island Aveaue, N.W. Washington, D.C. 20005 (202) 234-4433

75 1-1 of the activities eventually end up a part of the INp0 2 evaluation program, although they don't specifically 3 evaluate the NUMARC initiatives. 4 And, in many cases, I guess the feedback 5 is through the NRC inspection programs on the 6 implementation, and I think in the long

run, 7

Commissioner, that's the mechanism that we need to 8 create between ourselves, not to evaluate or inspect 9 by the NRC our initiatives as such, but to evaluate 10 and assess, as I believe you're going to be doing in 11 the procurement area, to assess whether the changes 12 that have been made as a result of our initiative are 13 .in fact improving the programs to satisfy your 14 requirements. 15 COMMISSIONER CURTISS: Okay. (G MR. CLARK: . Essentially, I get a letter 17 from NUMARC saying, "Have you implemented?" and then I 18 write back and say whether I have or have not, and if 19-I'have.not, when I will. So, there is a reliance on 20 the. utility management for the data. At the same 21

time, I

think there's good understanding in the 22 industry that i f we don't implement we're undercutting 23 the whole industry and NUMARC as well, so I think the 24 replies by the utilities are taken seriously. I know-25 we do and I'm sure everyone else here does, r ---- NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o o. 76 1 COMMISSIONER CURTISS: Okay. Thank you. 2 CHAIRMAN CARR: Commicsioner Rogers? 3 COMMISSIONER ROGERS: Yes. Coming back to 4 your major issues

list, lists like this are 5

interesting but not very useful as they stand. 6

First, it's an apples and oranges 7

collection of items. You know, when you were asked ~ 8 what do you think are most important, at least Joe 9 thought regulatory environment and impact. Maybe you 10 could put that at the top of the list and everything 11 else as a subtopic under it. 12 And, I don't know what FEMA guidance and 13 FEMA user fees have to do with NRC. I mean, maybe 14 they do have something to do. I don't know what they 15 have to do with us. 16 So, I would say that it's an interesting 17 list because it reveals the kinds of things that-are 18 irritants, the kinds of things that are major and the 19 kind of things that you want to call to our attention 20 in'some way, but it's not very useful as it stands, 21 -because what do you do with it? l-22 And, it would seem to me that we ought to 23 try to'look at a way of acting on these things in some 24 sensible way-and prepare from this list, develop some 25 mechanism for preparing from this list, first, some u_ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 i (202) 234-4433

__=....... e o .. f L i I categories that subsume some of these things or put 2 them together and then to try to get a prioritization 3 once you have some sensible categorization, because 4. this is just a scatter gun here of all kinds of 5 things, some that are big, some that are swall, some G that will never disappear. Human factors is always 7 going to be an issue of some sort. We'll never close 8 that one out entirely, in my opinion, as long as we 9 have people around. 10 So, some can be closed. Some are open 11 issues.- You know, in a certain sense I think that 12 it's not very useful as it

stands, although it's 13 interesting to see it, but why not try to come up with 14 some way of dealing with these things and getting them 15 closed out?

16 It's very interesting for us to hear about 17 some.of these things like access authorization. I 18 don't think we ought to be dealing with that at a 19 . Commission level.

Frankly, it seems to me that's 20-something staff ought to be able to handle,-but if it 21 isn't being dealt with then we ought to know that it 22 isn't.being dealt with and that there are issues that 23 aren't being dealt with that could be.

24 So, my comment here is that it would seem 25 to me that some mechanism ought to emerge in which you i NEAL R. GRoo8 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

a n. 78 i 1 and our staff get together and categorize such a list 2 as this into some sensible categories and then within 3 those cat egories. begin to set priorities, because as 4 it is the priorities I don't think can be sensibly set 5 within this list. I think that one has to first do G some more work with it. 7 MR. COLEMAN: Mr. Commissioner, if I might 8 comment on that, I fully agree with you. And, I might 9 add that the list was not intended to give you a sense 10 of what issue is a higher priority than another issue. 11 It was more intended to give you a feeling of the 12 scope and depth of the industry effort to try to close 13 out these issues, and the other aspect or comment on 4-- 14 the-list is that it does go beyond NRC. It includes 15 EPA and FEMA issues which are having a major impact on 16 the nuclear industry. 17 The real focus of this

list, however, 18 comes five or six times a year when we have'our NUMARC 19 issues management committee, which is about 17 senior 20 executives in the industry along with the 21 representatives from the NSSS and-the vendors and the 22-owners groups -as well as INPO and EPRI, to try and 23 come together to develop a strategy to figure out how 24 we can bring these issues to closure, and that is a 25 continuing effort that we have been utilizing from the 1

1 NEAL R. GROSS 1323 Rhode Island Avenue, N.N. Washington, D.C. 20005 (202) 234-4433

o 79 I I carly days of NUMARC both as a committee and as a 2 council. 3

And, I agree with you.

We need to get 4 together with the staff and identify those issues that 5 we can in fact bring to closure. We have been G attempting to do that. We've had significant 7 interactions on many of those issues and we have still 8 yet to be able to bring them to closure, so we will at 9 least from my perspective work to try to attack those 10. in a way that we can bring them to an end. 11 COMMISSIONER ROGERS: Well, the next time 12 we-hear from you I'd like to know what happened to 13 this list -- 14 MR. COLEMAN: Yes, sir. 15 COMMISSIONER ROGERS: -- and what you've 16 tried to do and what we've tried to do. 17 CHAIRMAN CARR: They won't bring it up 18-again. 19 COMMISSIONER ROGERS: No, no. I'll bring 20 it up again. 21-MR. COLEMAN: We will. 22 "D. ' CLARK: Given that request,- we 23 certainly will. 24-COMMISSIONER ROGERS: I think that it 25 ought to be able to close some of these things out, i NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

80 ![ _ 1 and if they can't be closed out then there's got to be 2 some kind of sticking point that maybe we ought to 3-understand better what that sticking point is, whether 4 lt's a lack of resources, whether there's a technical 5 issue that simply can't get resolved or whether i G there's a real difference in point of view that we b 7 can't seem to bring it to a closure. So, at any rate. 8 I would hope we could deal with many of the items on 9 this-list and get them closed out, but some of them i 10 will never be closed out. 11 The other comment or quest. ion that I have, 12 Mr.

Brons, in your presentation you made the point 13 that it's not possible to quantitatively measure the i

14 quality of maintenance

itself, so I was trying to 15 understand what your thinking is,

then, on this 16

project, this EPHI project that's listed in your 17 industry action plan that you updated on September 18 lat.

19 In support of maintenance efforts, EpHI is 20 currently developing a method that utilities can use 21 in the application of quantitative maintenance 22 monitoring techniques. The method will be evaluated 23 at two host utilities to assess its effectiveness and 24 usefulness, and then that is item 4(a)(3), provide a 25 tent and test a method for the application of r-- u_ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. I [ Washington, D.C. 20005 (202) 234-4433

O 81 I 1 quantitative maintenance monitoring techniques for a 2 one year period that EPRI has responsibility for. 3 Can you say something to that? How do 4 these two fit together? 5 MR. BRONS: Well, sir, as I indicated to 6 you in my remarks, we haven't given up on trying. 7 We've run into a stone wall at every turn, but indeed 8 we're looking still at preventative maintenance, 9 amount of rework, repetitive failures, availability of 10 spare

parts, outage durations, post-maintenance 11 testing issues, supervisory involvement, productivity, 12 all of those areas to find out if we can make some 13 uniform measurement.

r_ 14 I mentioned that all the utilities were 15 asked for the things that they use both analytical and 16 anecdotal to evaluate maintenance. We've submitted 17 that to INPO. INPO has collated it. I think I 18 -indicated that the guidance would follow. They have-19 distributed it back to the industry and said, "He're's 20 what you all have told us, but we're still working 21 over it. Is there something there that we can use 22 uniformly to do that?" And, EPHI is working on.that 23 as well. So, what that represents, I think most 24 fairly said, is a continuing effort to try and do it, 25 but we haven't found a magic answer yet. l NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

Q i 82 r 1-MR. CLARK: I think there might also be a s 2 difference between an indicator which, when you watch, 3 is it up, down, or level, causes you to go look into 4 it and see what's happening. I think we believe -- at 5 least I do and I think many others -- that you can 6 define indicators which will cause you to go look, and 7 you try to find one or a few which will tell you is it 8

good, bad, or indifferent or which give you the 9

answer.- I think that's where there's been no real 10 success and some people feel there won't be. And, so, 11 I think EPHI is aimed at the first part of that, which 12 is some things you can keep and eye on and help you 13 focus where you look to see what's going on. 14 MR. COLEMAN: Mr. Commissioner, as 1 15 understand it, the main focus also of the EPHI effort 16 is to identify ways to measure maintenance 17 quantitatively, but with a focus on use by individual 18 stations or by companies, not to try to go the next 19 step beyond that which is to see if we can compare the 20 same types of quantitative methods between utilities 21 or across the industry. That may fall out of that 22 process, but-the main focus of it has been to provide 23 assistance to the individual utilities as, I believe, 24 is the INPO -- 25 MR. BRONS: Let me give you a concrete l- - L.. J NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

j E o 6 83 I 1 example of that. One of the things that's come out of 2 the INPO study that's being worked on by EPRI as a 3 technique to manage maintenance on a station is to 4 look at the items which have had the most repeat 5 failures at that station.

Now, if the maintenance i

G process works well, those things will work their way l l 7 off the list and not reappear, but you're always going 8 to be having a list of things that have the highest 9 repetitive failures. It doesn't lend itself to any 1 10 inter-utility comparison, but it does help the 11' utility, rather than have that information be buried 12 away, bring it up to a level where management can say, 13 "What are we doing? Why is such and such a heat l 14 exchanger developing leaks once a quarter?" or 15 whatever and bring those things to resolution at a 1 y 16 station. 17 COMMISSIONER RCGERS: I see. So, your 18 thought is that this might be something that would be 19. applied differently in different stations? 20 -MR. BRONS:

Yes, because they'll be 21' dealing with what their problems are.

22 COMMISSIONER ROGERS: Well, it seems to me 23 that's a very useful approach. My own feeling on 24 maintenance always has been that it is very plant-25 specific because of the very large differences in ~ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 .l (P.02) 234-4433 a

e c 84 1 I designs and equipment that the plants have, that it's 2 very difficult to have the same kind of snap-shot look 3 at every plant for comparisens that would make sense 4 but you can look within individual plants. 5 Returning to this question, I think we've G got a real serious problem here in this question of 7 definition of maintenance, because the maintenance 8 policy statement that the NRC put together a year or 9 so ago and the documents that INp0 have come out with 10 on maintenance have not been very different at all. 11 We've all seen that. We've seen that most people say, 12 "Well, they're basically identical. There's very 13 little difference between them." Yet, when groups of 14 NRC staff and groups of industry people get together 15 to try to look at issues like an indicator or so on, 16 suddenly the difference in definition of maintenance 17 becomes very, very apparent, very big difference. 18 So, you know, at this level, our sitting 19 around this table level, we can seem to agree on what 20 we're talking about when we come to maintenance. When 21 we start to work it down to the working level in some 22

way, we get into other problems.

Something is not 23 maintenance because it's not defined to be maintenance 24 within the organizational chart and therefore it's not l 25 attributable to the. maintenance people and therefore 1 i u._ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 l

o, e, : o 85 i I they can't be held responsible. Well, that's an issue 2 that, as far as I'm concerned, we shouldn't be arguing 3 about. That's something within the organization. You 4 have to decide who's going to deal with these things. 5 Is the overall performance good or not? G And, the kinds of looks at it and concerns 7 that we expressed here are very broad. They involve 8 all of the organization. They involve the engineering 9 department. They involve almost all aspects of the 10 organization. That's been partly a concern of the 11 industry that it's such a broad approach. 12 Yet, we recognize that there are so many 13 elements involved in actually keeping the plant in a 14 good condition thet .2, nat have a maintenance label 15 ~ on them -- that's the big M,'little m distinction.that 16 Commissioner Curtiss was referring to that we '17 'really need to talk and understand this.a little: bit .18 '-

better, because I can see impasses developing over 19.-

really a fundamental dif ference' in wha'i we're calling 20 maintenance and what we're not calling maintenance. .21 But, we want the same thing in the end, good reliable. 22 performance. 23, And, Mr. Clark suggested, well, maybe.we .24 .shouldn't be calling it maintenance.

Well, maybe 25 that's part of the-way around what looks to me to be--

i NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

86 I 1 1 wouldn't exactly call it a semantic roadblock. It's 2 more fundamental than that. But, it's an approach to 4 3 getting to the end, which is a very reliable system 4 that the operator can rely on. To me, maintenance is 5 everything that takes place in the plant such that 5 when the operator calls on the equipment it behaves 7 the way it's supposed to behave. That's a little 8 simplistic. l 9 MR. CLARK: You're fighting a hundred l 10 years of power plant experience and probably Navy and the term 11 everywhere else where maintenance is not 12-isn't used that broadly. 13- . COMMISSIONER ROGERS: If we can give it a 14 new name and get around that hundred years of 15 experience on what you call maintenance and what you 16 don't call maintenance, if that's the impediment, then -17 I think we _ ought to look for a solution that gets l 18 around this because-it seems to me'where there's blood 19 on the floor here on this -issue of what's maintenance 20 and what--isn't maintenance and that's not the issue. 21 MR. BRONS: Commissioner, I would suggest 22 that, no matter what we call it, one of the points trying to make'is why are we concerned, 23 that I was 24 whatever label we give it. '25 Looking at the overall indicators, u -.- NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

e - 0-87 -t I availability is up. The industry projects that it j 2 will meet its scram reduction goal of one and a half 3 scrams a year. Radiation exposure goals for '90 were 4 met a couple of years ago. Had waste goals have been 5 met for both boiling water and pressurized water G reactors. Indeed, seven of the ten long-term goals 7 set by the industry which measure overall performance 8 in 1985 are going to be met in 1990. 9 CHAIRMAN CARR: Well, but your equivalent 10 availability factor doesn't look like it's going to be 11 met. 12 MR. "h0NS: No, sir, bu t -- 1 13 CHAIRMAN CARR: Which we all recognize is j' 14 a real indicator of maintenance. there I point out that the 15 MR.. BRONS: 16 industry's achievement, which I recognize has fallen - i it'was a very aggressive goal. 17 short of the goal 18-What we have done is come into consistency with the 19 best in the world, and we need to understand where the 20 limits are and where the goals should be properly set. 4 -21 Five years ago, thaf was-not the case. There's been L ~22 significant progress made in that area, although it v n 23 fell'short of the goal. g 'Just 24 COMMISSIONER ROGERS:

Well, let me 25 say something to that.

We've seen in this industry -l 4 NEAL R. GROSS i 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

.4 g 88 k_ l~ that, within - something like a five year period or a 2 little bit more, very good performers can stumble and 3 become poor performers. I'm not talking about just 4 maintenance. We've seen it happen. 5 And, I think the concern that I have with 6 respect to maintenance is yes, all the trends look 'l good. What's going to guarantee that they'll stay 8 good? You cen say, well, time will demonstrate that. 9 I then say, well, all right, that's something, but 10 what will tell us that we're starting to go off, that .11 we're starting to slip before you see it in the gross 12 indicators of capacity factor? Once you see it there, 13 it's going to take a long time to get fixed. Once you 14 see the impact of 'a poor maintenance program on 15 capacity factor, I think you're going to have some 16 very serious problems that will have to-be dealt with i '17 and it won't be easy to fix'them. It will take a long '18 time. 19 So, the quest has been for'something that 20 tells us that the system is beginning to slip, go'and 21

look, the kinds of things you were telling me t '.i i s 22 EPRI program is. searching for.

I would like to have i 23 - some confidence that _that kind of activity is in 24 place, not just that-the overall gross performance is 25 going up because it's taken a long time to get it to r-L _. NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

g 89 I I come up and it may take a long time for it to fall 2 off, even though rot is setting in in some places. these are the things that 3 So, I would 4

give us a concern and these are the things that -- in 5

answer to your question why is the Commission 6 concerned about

this, those are the reasons I'm 7

concerned about. Yes, it looks pretty good, but how 8 do we know when it's going to start to slip t, f f and 9 what will be the mechanisms that keep anybody from 10 slipping too far away from a good performance as we 11 all seem to agree we're heading. towards a good 12-performance now? 13 MR. BRONS: I think in my own instance, I 14 can only answer that_ specific question one

way, 15 Commissioner Rogers.

We as a company have an enormous 16 investment in.the plant and I feel like I'm-a personal 17' part of_that-investment. One of my objectives is to 18 ' turn a-plant o r --- p l a n t s over to my successor that are 19 in. as good or better shape than those that I l20 inherited. We would like to have a plant that is in 21 condition that you and 1 can both agree on when-it c2E comes time to renew its license, that it is renewable 23 -an'd that it will continue to serve the public that-we '24 serve well. 25 CHAIRMAN CARR: Let me focus that question F NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

/, D !!:p y 'l 90 ,;t. I a little bit. How are you going to institutionalize gjs 2 the maintenance and the malatenance program? That's 3-my concern about maintenance. I t. always has been. 4 There's nothing that says when 1 go and quit harping I realize everybody's going to 5 on it, it won't go 6 try to do it

right, but there's nothing 7

institutionalized that says this is what you've got to 8 do and therefore if you don't do it, I'll rap you. 9 What's 10 MR. LEE: I think that's what Jack was E 11 referring to in the whole TNPO program which is the 12 initial part of it. The special and assist visits, I 13 think as commissioner Remick asked the question, those . L-14 were focused on those that appeared to the industry to S 15 be problems. I think they will continue in the 16 future. 17 CHAIRMAN CARR:

Well, they've all 18 committed to the maintenance

standard, is that g

19 correct? j 20 MR. LEE: Hight. 21 CHAIRMAN CARR: How did they commit? 22 MR. LEE: By becoming members and m f, 23 maintaining their membership in INp0. 24 CHAIRMAN CARR: But what does that 25 commitment mean? =i_ NE/L R. CROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433'

~ O 91 I 1 MR. CLARK: 1 think what it means is that 2 INp0 in its assessments 1a going to be 1noking ut how 3 we're doing. If they don't think we're doing okay, 4 they're going t r. be applying the p r e s s. u r e INp0 can 5 apply, which is -- G CHAlHMAN CARR: And that's sufficient to 7 inststutionalize it as far as I should be c o n c e r n e d 8 1s that your q u e s t i o n Okny 9 COMMISSIONER ROGERS: It's a question like 10 that, yes. 11 MR. CLARK: I think in terms of how do you 12 know it's slipping and how do you know it's slipping 13 before it's so bad that you're really in trouble, the l 14 most likely thing that I see is if we can start really 15 looking at equipment relinbility data. Whatever 16 you're

doing, whatever the

program, if you're 17 equipment relinbi1ity is changing in other ihan an 18 individual component thing that you jump on, it seems 19 to me that that maybe would be the best indicator.

20 CilAIRMAN CARR: Well, it would he lp if we 21 had similar kinds of equipments, but 22 COMMISSIONER ROGERS: Yes.

Well, 23 that's --

24 CllAIRMAN CARH: Next generntion. 25 MR. CLARK: At a given plant, you can see i NEAl. R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o -O 92 r-1 is it changing or are there certain types of equipment 2 in the industry where reliability is going down. So, 3 l's not sure everybody would agree with me or that 4 that's even right, but I think that may be the best 5 possibility that I've seen. G COMMISSIONER ROGERS: Well, if out of this 7 EpHI program or some other way you come up with some 8 things that give some reasonabic assurance that 9 they'll start to detect a fall off in maintenance 10

quality, and maintenance with a

big M, the broad 11 approach that involves all the people in the place, 12 the engineering staff and everyone else, I think that 13 gives you more credibility in your statement that 14 you're watching these things yourselves if you have 15 some way to detect something other than the gross l 16 performance which I feel is not satisfactory because I 17 think it may take too long for those to begin to show 18 up. 19 MR. CLARK: I'm not sure that we're any 20 worse off in maintenance than we are in operations or 21 pick any other area. Ilow do you know if things are 22 beginning to slip? I worry about that a lot and I'm 23 sure all these other guys worry about it a lot. INp0 24 worries about it. We thought to ourselves, how can 25 you foresee a plant is going down co it won't end up NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

t. <O l i 93 p i 1 in a lower category. There's a lot of thought to it 2 and so far no -- 3. MR. McGRATH: There's a risk to try to 4 come up with the ten numbers that say, "If you do i 5 these ten things

right, everything is going to be 6

wonderful," because our people are very good at making 7 those ten numbers work. I, for

one, am not 8

comfortable with any ten numbers that could

say, 7

t!- 9 "Okay, this is the answer." We're

dealing, as L

10 Commissioner Curtiss

says, with very

complex, 11 interrelated management process and it almost defies 12 compartmentalization or coming up with the ten 13 indicators or whatever.

14 COMMISSIONER ROGERS: We know it's 15-complex. If it wasn't a-complex problem, it probably 16 would have been solved a long time ago, in a sense. 17 But it's got mat.y facets to it. No question about it. 18 CHAIRMAN CARR: In spite of that you say, 19 1_ don't believe people are out there manipulating the 20 numbers. I' hope they're not. 21-MR. McGRATH: No, they're not. They're if 22 not manipulating the numbers, but they can make 23 you come up with five numbers and say, "Okay, this is 24 what your future depends on, this is what your raise 25 depends on," they'll make those -five numbers work. f~ NEAl. R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

s p-94 t-1 I'm not comfortable if they do that. 2 COMMISSIONER ROGERS: In doing that, 1et's 3 look at that for a moment. If they are driven to do 4 that, maybe their motivation isn't the right one, it's 5 to make the number right rather than to make the G system right. But could they do that and not do a 7 good job otherwise? 8 MR. McGRATH: I'm afraid that's possible. 9 COMMISSIONER ROGERS:

Well, yes, I know 10 it's a worry.

But 1 think you have to look at it 11 pretty carefully because that's the argument, that's 12 the fundamental argument here, that attention will be 13 diverted from doing the job. But look at that u-- 14 question very carefully because in getting those 15 indicators right, how are they going to do it and can 16 they avoid doing their job properly while they're 17 getting the indicators right? Do they have to go out la of their way to not do their job to get the indientors 19 right? 20 MR. CLARK: I would suggest the answer is 21 yes, they can for a short time. 22 MR. McGRATH: Short-term. 23 MR. CLARK: I'll give you two examples. 24 l've been focused at one of the plants of reducing the 25 person rem. A serious recommendation by part of the i u __ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 l

c I 95 r-I staff was to delete from the next outage some high 2 person rem jobs. 3 COMMISSIONER ROGERS: Yes. Sure.

But, 4

you see, that 5 MR. CLARK: So, you could -- G MR. BRONS: Another example is the i 7 operator not making rounds. if you picked 8 COMMISSIONER ROGERS: 9 those indicators the right way so that they cross, 10 they interleave within your system, that you can't do 11 it. I mean, you can't just not do the job.

Because, 12 if you get all the indicators up, you --

13-MR. CLARK: I could do it. Another 14 indicator would catch me three years later. That's 15 what I was saying to you. I believe you could -- 16 MR. BRONS: There's always delay. manipulate _them or, you 17 MR. CLARK: 18

know, you could manage them.

" Manipulate" suggests 19 cvil motive. You could manage them in a way that 20 would not show up for a while. 21 COMMISSIONER ROGERS: Well, all right, but 22 then you haven't got the right combination of 23 indicators or something. What I'm saying is that I'm 24 with the Chairman in the sense that he doesn't think 25 that people are manipulating those out there. I don't

r-NEAL R.

GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

t g, 96 [ I think they're manipulating them consciously. and even if one 2 The question is 3 individual tried to, how far could they get when all l 4 is said and done in driving a set of indicators to all 5 look good and still have a lousy maintenance program? G You know, I think you really have to analyze that 7 question. We can't debate it today, but I think it's 8 not so simple to just simply say, well, you drive all 9 those indicators and-you can atill have a poor 10 program. I think you'd be bending the whole system 11. out of shape to do that. I think it would show up 12 very clearly if anybody was doing

that, that it 13 wouldn't be something you could keep hidden, that you 14 get all the indicators right and yet the system is at I

15 its center not very good a t' all., I don't think you 16 could do it. 1 17 So, you know, that's just my opinion, but t 18 I think.it's not~a simple matter. 19-MR. CLARK: I. agree. You couldn't do it '20 for long. ( 21 COMMISSIONER ROGERS: Okay. I think it -22 would be very. obvious if that was happening, very 23 obvious. 24 Yes? 25 MR. COLEMAN: Perhaps a comment on-4 i. ' L.. - NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202).234-4433 i

oi ,6., 'i p 97 [ r-l' Chairman Carr's concern about the institutionalization 2 of the program. I think that perhaps what we could do 3 is to go back and look at the area of maintenance or 4 whatever we're going to call it and look at the 5 institutional parameters or elements that control that 6 currently or look at those that control operations or 7

training, and I

think we'd find many of the same ? 8 controls. j .9 Prom the NRC's perspective, you have -10 resident inspectors at each one of our units. They're 11 there almost all the time. You have regional-based 12 and Headquarters-based inspections. We have INPO 13 guidance. We have ANI teams. We talked about 25 "r 14 percent of our supervisors' and managers' times are .15 spent addressing outside inspections. Half or so is 16 the NRC and h'alf everyone else. We've got a lot of 17 indicators and a lot of. feed-back 'and we've got the 18 ability. on the institutional side to hold a utility 19 inspectable, enforceable to their maintenance program -20 procedures and documents that are. looked at. 21-CHAIRMAN CARR: -You can't inspect-in a 22 good program. 23 MR. COLEMAN: I agree. The -key to that 24: seems to be management. We're really talking back to l. - 2 5' the overall process of how people manage their i NEAL R. GROSS 1323 Rhode Island Avende, N.W. Washington, C.C. 20005 (202) 234-4433

o e 98 r-I companies and manage the performance of their units. 2 So, perhapr. that's something we could be looking back 3 to. 4 COMMISSIONER ROGERS: Well, could we just 5 move on?

Because, I know the Chairman is going to G

have questions of his own. 7 Mr.

Clark, in your presentations on the 8

procure.sent activities and matters related to that and 9' the examples that y o r. cited and the costs that were 10 incurred in dealiag with those issues, the pipes and 11 flanges and the breakers, and your conclusion that 12 there's no crisis found, crisis in fraud or safety 13 items now after looking at all this, at the time the 14 issues enme up, do you think that the industry could 15 have come up with an alternative approach that would 10 have given the same kind of assurance that there is 17 not a problem, let's say, the way you found in the 18 . pipes and flanges situation? 19 True, you spent $30 million tracking this 20 down and-when all is said and done you found no safety 21 issues in installed materials, but is there any other 22 way that one could have approached dealing with that 23 issuo than the way that it was approached? 24 MR. CLARK: I think I would divide it in-25 t'wo parts. Initially, each utility rushed off I think I u_ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

o 99 1 T-~ 1 in part because of the time frame set by the bulletin. 2 Each utility instantly rushed off to address the j 3-problem themselves to try to meet that time frame and 4 I think that was very inefficient. And a lot of'the 5 cost when I gave you a number of so many man-years per O month going in initially, that's where a lot of the l 7 cost went. I think we could have avoided that if it 8 had been treated as a less time-urgent issue, in other 9 words if the time frame had allowed a more reasoned 10 start. 11 Once we kind of got ourselves together and 12 NUMARC got in it and we ste.rted sharing the data and 13 saying, "Look, out of this whole population, how do we c_._ V-14 go about it," I don't know that it could have been 15 done after that much more Jefficiently. I guess I'm 16 .not quite close to it. Joe or Byron might went to-- 17 but certainly in.that first phase it was kind of a-- .18 I don't want to use a word that's too extreme, but it 19 was a rushed effort individually and I think we've 20 auffereo from that. 21 MR. BRONS: I think, Commissioner -- 22 COMMISSIONER ROGERS: It's a question of 23 whether we can learn something here from this 24 experience. 25 MR. BRONS: I think one thing was i L._ \\ NEAL R. GROSS l L 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

g h e 100 m I discounted in creating the sense of urgency and that s. 2 is that, at least relative to the application of these 3 components in any safety-related way, I think it's 4 heen many years now where the industry uniformly 5 employs a considerable amount of inspection, post-6 maintenance testing; when you're talking about 7

flanges, hydro-testing after they're installed; 8

testing of circuit breakers after they're installed 9 and safety-related. m 10 So, I think, from my own perspective as an 11 industry manager, I was relatively comfortable that 12 the equipment that I had installed in the plant was 13 not posing a safety issue because it had been tested 14 after it was installed. 15 I will grant you that, for instance, in 2 16 the case of the circuit breakers, it was not tested to 17 failure to determine whether or not the breaker would 18 interrupt under e n o rmous l s; high loads, but then I'm 19 also relying on the overall design of the electrical 20 system which puts another weak link downstream that { 21 may take out more equipment or what-have-you. I think 22 with that in mind, with that knowledge that this 23 equipment is installed and tested prior to being put .24 in service in safety related things, it gives us the 25 time to not treut these things as a crisis and to r L NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

II a I -([> o l i 101 j I approach it in a more reasoned way. i 2 COMMISSIONER ROGERS: But sometimes these 3 crimes are driven by external events coming from 4 certain other parts of the geography around here. ,g t-5 All right. That's all I have. G CHAIRMAN CARR: While we're on that t 7 subject

then, let me the nuclear procurement 8

program improvements leave implementation of a number 9 of. practices as discretionary. Why did you do that 10 and how are we going to ensure that the best efforts 11 are done by the utilities? 12 MR. CLARK: I think we did that because we 13 think it could-have an acceptable total program r__ 14-without necessarily having completely each and every ^ " - - s 15 one of those elements. One element is a little 16 stronger, you put a little more reliance over there or 17 attention over there and' you could still have an i g 18 acceptable program. So, conceptually, I'd say that's q 19 some of the-thinking behind that. 20 In terms of the implementation, each 21 utility,_I expect, is going to be asked to, say, tell' 22 us what you've

done, kind of a

NUMARC follow-up ') 23 process that I tried to describe earlier. That 24 basically is the mechanism and then

INp0, in its 25-inspections, in a general way, will be looking at the l

r-- l-NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

(~ ~ 'l ,7 n; i 102 r-- 1 results achieved. I don't want to suggest that INp0 2 is going to audit against that because that's not the 3 intention. 4 CHAIRMAN CARR: Did all the licensees meet 5 the industry-established milestone on January

1st, G

1990? 7 MR. LEE: On the commercial grade -- 8 CHAIRMAN CARR: On the utilization and 9 commercial grade items. 10 MR. LEE: Yes. 11 CHAIRMAN CARR: They all did? 12 MR. LEE: Yes. 13 CHAIRMAN CARR: Okay. Then there's no 14 5 ason to expect they won't meet the other two then? 15 MR. CLARK: By and

large, our NUMARC 1G initiatives has been very good results.

I think maybe 17 there were a few where a few people slipped beyond the 18 date. Overall, we got very good response. 19 CHAIRMAN CARR: My feeling of this whole 20 thing was we didn't need another rule because we 21 already had Appendix B to Part 50. That was enough to 1 22 tell you you had to do it right and whatever that 23 required. How do you see this relating to the 24 existing requirements in Appendix B? 25 MR. CLARK: I think we believe, and I i u_ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 Li

n O 'o 103 i I tried to say that we think the regulations you need 2 exist and are adequate and there's not a need to 3 augment change, add to the regulations. What's needed 4 is us to go implement the kinds of things we've 5 decided to do. G CHAIRMAN CARR: Okay. I'm still going to 7 make a couple of other comments and quit. I'm still n 8 little uneasy about the institutionalizing the 9 maintenance and the maintenance programs. I'm not 10 under any illusions that the emphasis on maintenance 11 is solely utility-generated. There's no doubt in my 12 mind that the heavy emphasis the NRC has put on 13 maintenance has had a beneficial impact on your 14 programs. 15 I, on the other hand, don't I guess I 16 feel like that the poor programs and the lack of 17 maintenance in the past is behind us. That's a 18 personal feeling of mine. I think that we're past the 19 point where you've heard these O&M numbers are going 20 up tremendously. A lot of that is in the M area and I 21 think we're at the point where it's pay me now or pay-22 se later and I think for a long time we weren't doing 23 enough maintenance _ of the right kinds or carefully 24 enough. I think you ended up having to' upgrade those 25 programs and do a better job. l NEAL R. GROSS l 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

v.

rg .o 104 r--- s: 1 My question really is are we where we want 2 to be yet and how can we stay there? Does anybody 3 remember the forced outage goal for '90? 4 MR. McGRATH: Four and a half or four or 5 five percent, isn't it? G MR. BRONS: I think it's around five or i ? 4.1 and that's a median. 8 CilAIRMAN CARR: 4.17 What's the 9 difference between the equivalent availability and the 10 forced outage summary? Is that refueling? L 11 MR. McGRATH: Planned outages. 12 MR. CLARK: Planned

outages, of which 13 refueling is a big part, but not all.

14 MR. COLEMAN: The equivalent availability 15 f actor' also contains regulatory imposed derates, for 10 example, due to environmental conditions. So,_ things 17 that are beyond the control of the utility or plant i.. 18 basically acts -- 19 CHAIRMAN CARR: Well, you've got the river F i 20 too warm.- I understand that. 21 MR. CLARK: That's in there. 22 MR.-McGRATH: Condenser repairs or you can i 23 shut down part of a unit. 24 CHAIRMAN CARR: Okay. The -- 25 MR. LEE: And it also compensates for l. L-_l NEAL R. GROSS { 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 L 3

.o ? O l t 105 I I deratings in a sense or it tries to take deratings 2 because equipment is out of service. { 3 CHAIRMAN CARR: But the availability 4 factor takes in the fact that you're load sharing, for 5

instance, of Commonwealth Edison a

lot whereas 1 6 capacity factor wouldn't. 7 MR. LEE: And the old number, which was 8 Just a straight availability, whether the unit was 9 running 'or not, masked a lot of these other partial 3 10 deratings and those types -- 11 CHAIRMAN CARR: 1 don't know how much 12 comfort I can take in your steady improvement on 13 performance > indicators because the last piece of paper 14 I think I read from AEOD said they had seen a leveling 15 off -- 10 MR. LEE: That was earlier this year. at performance 17 CHAIRMAN-CARR: 18 improvement this year. So, I'll watch that a little. that's not bad. You've got to level 19 1 don't mean 20. off somewhere. And I would like to make sure you -21 realize,. that we all realize that generic 22 communications don't impose the requirements, which was mentioned here that it - did, but it doesn't. In-l23 24 case you guys are still under the impression it does, 25 it doesn't. NEAL R. GROSS 1323 Rhode Island Avenue, N.W. l Washington, D.C. 20005 I (202) 234-4433 l-

6, 106 i r-- 1 MR. McG R ATil: Who's we all? Everyone at 2 this table? I 3 CHAIRMAN CARR: Everyone in the room, I J 4

hope, 1

5 Any other comments from my fellow 6 Commissioners? i 7

Well, let me thank you for your i

8 presentation. We'll carefully consider the comments i 9 that you've given us here today and I made a list of j 10 things I can do to solve all our problems. 11-When discussing the state of the nuclear 12

industry, it's important-to acknowledge that we've 13 seen sustained or improving trends in virtually every

_g_ u-14 indicator of safety performance that the NRC routinely 15 monitors. + 10 We must recognize, however, that these are 17 gross measures of safety performance and that they 18 remain areas for continued improvement for most plants 19 in areas 'such as maintenance, procurement and '20 operations. Even with an improving safety record, 21 continued industry attention is needed to careful l 22 maintenance, proper training and good plant 23 management. 24 We will continue to monitor the results of 25 your efforts in the maintenance and procurement as l l u __ NEAL R. GROSS 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

O'm y,, l 4 i 107 l s \\ 1" well as other important areas. i j 2 Any.other comments? i o. 3- .If not, we stand adjourned. Thank you t 4 very much. e 5 (Whereupon, at 12:17 p.m., the above-5 6 entitled matter was concluded.) 7 i t 8 s i 4-9 1 i 10 Q= l 12 13, i t _14 a -- i l -15 R-l

16 s

117 i , u 18' l + 1. 19 7.. - 20: ) 21- ) 2 2.- + -- 23 1 1 f < 2 5. -1 ( f i lNEAL R. GROSS '1323 Rhode Island. Avenue, N.W. ~ Washington, D.C., 20005 E (202)-234-4433 i s,-, J.,...

o CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the United States Nucliar.Degulatory Commission entitled: TITLE OF MEETING: BRIEFING Oh NUMARC'S PERSPECTIVE OF THE STATE OF THE NUCLEAR INDUSTRY PLACE OF MEETING: ROCKVILLE. MARYLAND DATE OF MEETING: OCTOBER 26. 1990 were transcribed'by me. I further certify that said transcription is accurate and complete. to the best of my ability, and that the transcript is a true and accurate record of the foregoing events. U A~- u, Reporter's name Peter Lynch l l NEAL R. GROSS l COURT RtPORTER$ AND TRANSCRltlR$ 1323 RHODE IStAND AYINUt. H.W. (202) 234 4433 WASHINGTON. D.C. 20005 (202) 232 6600

O I e l PRESENTATION To THE NRC CoMMISSIoNEP* l sY THE llUCLEAR MANAGEMENT AND RESOURCES W.)#CIL j OCrosER 26, 1990 l l 0 INTRODUCTION AND CLOSING REMARKS l MR. EUGENE R. MCGRATn CNAIRMAN AND CEO CONSOLIDATED EDISON COMPANY OF NEw YORK o UPDATE oN INDUSTRY ACTIoM PLAN FoR CONTINUED IMPROVEMENT IN MAINTENANCE MR. JoNN C. BRoNS 1 EXECUTIVE VICE PRESIDENT - NUCLEAR GENERATIoM NEw YORK POWER AUTNoRITY i o RECENT PROCUREMENT INITIATIVES MR. PHILIP R. CLARK I PRESIDENT AND CHIEF EXECUTIVE OFFICER GPU NUCLEAR CORPORATION i l l 4 i j

m 4,- MAJOR 155UES AFFECTING THE NUCLEAR INDU$TRY Access Authorization Advanced Light Water Reactor Program Backfitting Bolting Integrity Cascading Technical Specifications Check Valve Reliability Control Room Habitability Decommissioning Design Basis Reconstitution Diesel Reliability Electrical Power Reliability lmergency Planning (Emergency Action levels) Emergency Response Data System EPA Protective Action Guidelines EPA Radionuclides Emission Standards Epidemiological Studies External Events FEMA Guidance Memoranda FEMA User fees Fitness for Duty Hot Particle Human factors impact of Lower Worker Dose limit Inservice Inspections / Inservice Testing In-situ Testing of Valves Interfacing System LOCA i Interlocks and LCOs for Class IE Tie Breakers License Amendment Review Process License Renewal Maintentnce Mixed Waste l MOV Performance (NRC Generic Letter)

' cx NRC Rules Jf Practice (Part 2) Nuclear Plant Aging Nuclear Plant Equipment Procurement Operating and Maintenance Costs Operator Professionalism Operator Requalification Operator Training and Qualification j Radiation Protection /10 CFR 20 Rulemaking Reactor Coolant Pump Seal Failures Regulatory Environment and Impact Rosemount Transmitters (Bulletin 90-01) Safety Goals / Cost Benefit Security Seismic Issues Severe Accident Policy Impleme1tation Severe Accident Management Program Shutdown P1 ' "ues Software Quah, surance Source Term Standardization and Licensing Reform l Station Blackout Substandard Electrical Components Technical Specification improvement Temporary Non code Repairs (GL 90-05) 10 CFR 50.59 (Safety Evaluation)

4 m> i I. INPO PLANT EVALUATION AND ASSISTANCE ACTIVITIES 1 j IN AREAS NELATED TO MAINTENANCE.......... 1 2. MONITORI N THE PERFORNANCE AND MAINTAINI N THE REL. LITY { j OF EQUIPMENT......................... 3. TRAININ ACTIVITIES...................... i 4. MONITCRIM ACTIVITIES ,i i A. Management capability to monitor the effectiveness of maintenance-activities................ t { 8. Industry-wide monitoring of plant performance ' l l and establishment of long-range goals.......... t 4 C. NRC indicator pliot project using NPRDS......... l 5. CofftlNICATIONS Afm REGULATORY INTERFACES............ l l i { 6. TOOLS Afm TECiEIIQUES t I I A. Rallability centered maintenance (RCM) demonstration j and use......................... j i 8. Motor operated valve (MDV) related activities...... } C. Check valve related activities j D. Service water assistance program (SWAP) activities l 7. OWNERS GROUPS ACTIVITIES................... l )

,.4 INDUSTRY ACTION PLAN Sup5fARY OF ACTION ITEM STATUS-TOTAL ACTIONS PLAf9 FED 189 TOTAL ACTIONS COMPLETE-TO-DATE 109 22 OPEN ITEMS RESCHEDULED INDUSTRY - 15 7 NRC

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m =, c: m Capacity Factors Year-to-Date U.SJFrance/ Japan i 4 i Capacity Factor (%) 100 l t l i 80 1.. - t er.m .p *~ L _ i X,,: go. i i l 40 20 i O 12 3 6 9 12 3 6 8 12 i als I se I s0 1 Month / Veer 4 i United States France Japan j i ard Ometter sees dote meewetteMe sieo se meet sure.at does j k i

if Distribution of Capacity Factors United States August 1990 so n 25- ~ ~ ~ ^ ne.n-67.43z

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20-r i y 15 - go. =1 5 '- 0 10. 20. 30. 40. 50. 60. 70. 80. 90. 100 Capoelty Footor (%) Total Nussber of Plants - 111

h RESULTS OF NUCLEAR GENERATING STATION MAINTENANCE TEAM INSPECTIONS AUGUST 1990-PROGRAN IMPLEMENTATION GOOD 28 19 SATISFACTORY 24 32 POOR 1 2 COMPLETE 53 53 REMAINING STATIONS 21 21 .....-i-,.s~.-.--. .--p.y-...

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IllDUSTRY ACTIVITIES IN RESP 0llSE TD. BIOLDED CASE CIRCUIT BREAKER ISSUE o OVER-24,000. BREAKERS' PROCURED AS' SAFETY'RELATED. REVIEWED IN RESPONSE TO llRC - BULLETIN 88-10 1 0 . RESULT: LESS THAN~ONE PERCENT TRACEABLE TO SUSPECT SUPPLIERS OVER 36,000 BREAKERS PROCURED AS NON SAFETY RELATED REVIEMED o UNDER INDUSTRY INITIATIVE o RESULT: APPROXIMATELY THREE PERCENT. IDENTIFIED AS SUSPECT ABoVE PERCENTAGES REFLECT SUSp^.CT BREAKERS, NOT DEFECTIVE o BREAKERS

~ ~ ~ ~ + 'C_ 4 ,n' ~ _y. [J-pp ELDEllTS OF IIBUSTRY PROCURDEllT INITIATIVES O DEDICATION OF C0999ERCIAL GRADE-PARTS FOR SAFETY RELATED l APPLICATIONS O PERFORMANCE sASED VENDOR" AUDITS l ~ O ENHANCED RECEIPT TESTING AND INSPECTION 1 0 GUIDELINES FOR FRAUD DETECTION t O INFORMATION-SHARING i I O- .OsSOLESCENCE O GENERAL PROCUREMENT. i ? t t i I l

-- - q l gc.g ~ ~ ) f- .. ? = "A BASIC. CONCERN OF LICENSEES IS THE. NUMBER AND SCOPE OF REQUIREMENTS' IMPOSED BY THE NRC." "A PERSISTENT COBOGENT WAS THAT NRC REQUIREMENTS, ANDLPENDING REQUIREMENTS, ARE POORLY INTEGRATED AS-TO THEIR OVERALL EFFECT ON PLANT OPERATION AND UTILITY-RESOURCES." l " LICENSEES MAKE A STRONG PLEA.FOR NRC TO ESTABLISH A PRIORITY SYSTEM." 'l l " LICENSEES CODG4ENTED....THAT NRC FAILS TO APP?,ECIATE l THAT LICENSEE PREPARATION FOR AND SUPPORT OF NRC INSPECTION ACTIVITIES ~ INVOLVE SEVERAL MAN-YEARS OF LICENSEE EFFORT EACH YEAR." ^

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