ML20128E807
| ML20128E807 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1993 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9302110083 | |
| Download: ML20128E807 (114) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION TI$*.
BRIEFING ON IMPLEMENTING GUIDANCE FOR THE MAINTENANCE RULE AND INDUSTRY VERIFICATION-AND VALIDATION EFFORT Location:
ROCxvzLLE, MARYLAND b3I6 JANUARY 29, 1993 h&Q63.
89 PAGES NEALR.GROSSANDCO.,INC.
COURT REPORTER $ AND TRANSCRISERS 1323 Rhode Island Avenue, Northwest Washington, D.C.
20005 (202) 234-4433 e=
DISCLAIMER This is an unofficial transcript of.,a meeting of the United States Nuclear Regulatory Commission held on January 29, 1993 in the Commission's office at one White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CPR 9.103,- it is not part of the formal or informal 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 the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, i
except as the Commission may authorize.
-9 HEAL R. GROSS COURT RepostTER$ AND TRAM 5CatstR$
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1 1
UNITED STATES OF AMERICA 2
NUCLEAR' REGULATORY COMMISSION 3
4 BRIEFINu ON IMPLEMENTING GUIDANCE FOR THE 5
MAINTENANCE RULE AND INDUSTRY VERIFICATION 6
AND VALIDATION EFFORT
.P 7
8 PUBLIC MEETING 9
10 Nuclear Regulatory Commission-11 One White Flint North-12 Rockville, Maryland 13 14 Friday 15 January 29, 1993--
16 17 The Commission met in open session, pursuant to 18 notice, at 10:00- a.m., the Honorable IVAN SELIN, Chairman 19 of the commission, presiding.
20 COMMISSIONERS PRESENT:
21 IVAN SELIN, Chairman of the Commission 22 KENNETH C. ROGERS, Member of the Commission 23 JAMES R. CURTISS, Member of the Commission; 24 FORREST J. REMICK, Member of the. commission.
25 E. GAIL de PLANQUE, Member of the Commission NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W, (202) 234 4433 WASHINGTON. D.C. 200051
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STAFF AND PRESENTERS SEATED AT THE CO}O(ISSION TABLE:
2 SAMUEL J. CHILK, Secretary 3
WILLIAM C. PARLER, General Counsel JAMES TAYLOR, Executive Director for Operations 4
5 JAMES SNIEZEK, Deputy Executive - Director for 6
Operations ROBERT BAER, Chief, Engineering Issues Branch, 7
8 RES 9
RICHARD CORREIA, Security Chairman, NRR WILLIAM RUSSELL, Associate Director, Inspection 10 11
& Technical Assessment, NRR 12 OWEN ROTHBERG, Engineering Issues Branch, RES 13 TOM TIPTON, Vice President, NUMARC 14 CORBIN McNEILL, President & COO, Philadelphia 15 Electric Company 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS
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1 P R O C E E_D I N G_S 2
(10 JO a.m.)
3 CHAIRMAN SELIN Good morning, ladies and 4
gentlemen.
We are pleased to welcome the staff and 5
representatives f rom NUMARC, Nuclear Management Resources 6
Council, to brief the Commission on progress and future 7
plans for implementing the Maintenance Rule,10 CFR 50.65.
8 The Commission considers this rule and implementation of 9
it to be important to plant safety and, therefore, of 10 course, important to public health and safety.
11 In July,
- 1991, the Commission amended its 12 regulations effective July 10, 1996, to add 10 CFR 50.65 13 monitoring the effectiveness of maintenance in nuclear 14 power plants.
This rule requires nuclear power plant 15 licensees to monitor the offectiveness of maintenance 16 activities in order to reduce the likelihood of failures 17 caused by the lack of adequate maintenance.
18 Since the rule was promulgated, the staff has 19 expended a great deal of effort in order to develop 20 guidance for its implementation.
It's been an unusual 21 process.
I'd like to say very c' early that the Commission 22 is mindful of the proper relationship between ourselves 23 and between the nuclear power industry, the community that 24 we regulate.
However, in promulgating thic rule, the 25 Commission recognized the difficulties involved in NEAL R. GROSS COURT BEPORTERS AND TRANSCalBERS 1323 HMODE ISLAND AVEMA N W.
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1 developing detailed guidelines, in part because the 2
technical information necessary to develop the guidelines 3
is beat available from the nuclear industry.
4 The rule was written in broad terms, with the 5
thought that the more refined guidance would be developed 6
within two years as the staff gained more experience in 7
the maintenance arena. To this end, the Commission set up 8
an usual process for interaction with NUMARC in order to 9
facilitate the proper transfer of technical information, 10 which was not established as a privileged relationship 11 between the staff and NUMARC.
We have tried insofar as 12 possible, and I think quite successfully, to make sure 13 that all this transfer occurs in public fora where all 14 parties are invited and can hear what's going on.
15 In July of 1992, the Commission approved the 16 staff's proposal to endorse NUMARC's implementation 17 guidelines and the draft regulatory guide monitoring the 18 effectiveness of maintenance in nuclear power plants, 19 issued in November of last year.
20 The Commission is looking forward to hearing 21 from the staff on progress in developing the guidance and 22 on their plans for resolving the comment and finalizing 23 l
the regulatory guide.
In addition, NUMARC will brief the 24 Commission on lessons learned from its pilot validation 25 and verification program that tested the NUMARC NEAL R. GROSS I
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' implementation guidelines in actual plants.
2 Do any of the Commissioners-have _ opening
-4 3
remarks?
4 (No response.)
5 I gather, Mr. McNeill, that you will start with-6 the NUMARC presentation and then we'll go on to the-staf f 7
presentation?
8 MR. McNEILL:
Yes, sir.
9 CHAIRMAN SELIN:
Good morning.
10 MR. McNEILL:
Good morning, Mr. Chairman and-11 Commissioners. I'm Corbin McNeill.
I'm the President and-12 Chief Operating office of the Philadelphia Electric'.
13 Company. LA major part of my corporate responsibility-is-14 the direction and management of the Limerick and Peach 15 Bottom nuclear generating stations.
16 With me at the table this morning is. Tom Tipton, 17 who is the Vice President of NUMARC Operations, Management'-
18-and Support Services. Division responsible.for issues such 19 as the Maintenance Rule implementat' ion, - this morning's 20 area of discussion.
21 Also with us-in the rear are Warren Hall, Walt 22 Smith, Dat. Rains and Jim Eaton, who are the managers and' 23 project managers within NUMARC -responsible-for the' 24 development of the industry maintenance guideline and the-25 validation and verification - program.
Joe Colvin, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N W.
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1 President and Chief Executive Of ficer of NUMARC, who would 2
normally attend with us today, is on travel and sends his 3
apologies for not being with us today.
4 As a member of the NUMARC Executive Committee 5
and the Board of Directors, I participate with other 6
industry executives in the formation of policy of generic 7
application to the nuclear industry.
8 Throughout my naval and civilian career, I have 9
had particularly strong association with the issue of 10 maintenance et nuclear generating plants, and currently I 11 am the Chairman of the NUMARC Maintenance Working Group 12 that consists of senior executives responsible for the 13 generation of electricity through the nuclear power at 43 14 power plant units in the country.
The names and 15 affiliations of the Working Group participants are 16 included as an attachment to my prepared remarks.
The 17 working group provides oversight and guidance to the 18 NUMARC process for the development of industry guidance 19 for Maintenance Rule implementation.
20 Tom Tipton, Joe Colvin, and I also serve as the 21 industry interf ace with senior NRC nanagement to assure 22 that industry policy matters associated with the 23 implementation of the Maintenance Rule are appropriately 24 addressed.
25 We appreciate this opportunity this morning to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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discuss with you the results of the development of the 2
industry guideline and being able to do so in a reasonable 3
and cost effective manner from the standpoint of the 4
industry.
It has been a challenge to develop a process F
that provides the necessary balance between flexibility and specificity, and that promotes consistency within the 6
7 industry and while at the same time assures an appropriate degree of regulatory assurance for the NRC and the general 8
o 9
- public, 10 The industry has expended significant ef fort in 11 developing the industry guideline.
Four separate Ad Hoc 12 Advisory Committees were formed that involved 13 representatives from 33 utilities responsible for 14 operating nearly 75 percent of the nuclear power plants in 15 this country.
The expertise assembled included, for 16 example, individuals knowledgeable in probabilistic risk 17 assessment, reliability centered maintenance, codes and 18 standards, and the nuclear plant reliability data system.
19 Maintenance managers and senior reactor operators were 20 also key participants in these advisory groups.
21 Additionally, we had very active involvement of 22 representatives from EPRI, INPO, and NUMARC.
Countless 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> were spent on first understanding the intent of the 24 rule and then developing the necessary guidelines.
This 25 was particularly, I think, a demanding challenge since NEAL R. GROSS COURT REPORTERS Ar40 THANSCRIBERS 1323 RHODE LSLAND AVENUE. N W.
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1 this was the first of the performance-based rulemaking 2
undertaken by the NRC.
3 Following the development of the guidelines and 4
the detailed industry review, the guidance was subjected 5
to a very detailed verification and validation process.
6 And without a doubt, we brought our extensive experience and knowledge in maintenance to bear on the issues at all 7
8 levels within the industry.
9 A major element of the continuation of that 10 process on your part has yet to be developed, and that's 11 the NRC's inspection module.
And at the conclusion of my 12 remarks today, I'll address that in a little more detail 13 in some of our comments in that area, in just a few 14 minutes.
15 I'd like to address three areas briefly today.
16 They are the process that was established to address the 17 implementation of the maintenance rule, the results to 18 date of the industry verification and validation programs 19 which will be undertaken by Tom Tipton, and where we go 20 from here.
21 We found that the cooperative but yet 22 independent process established for proceeding with 23 implementation of the final maintenance rule was a unique-24 one that has achieved more than we really had anticipated 25 at the beginning.
It can and should serve as a model for l-i i
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addressing future complex irsues and rulemaking 2
implementation.
And I commend you individually for 3
providing the methodology, and the staff for its very 4
professional execution.
5 There are, I believe, five critical factors or 6
elements that helped to make this thing work as well as it
?
did.
First was the involvement of the NRC's senior 8
management, including yourselves, the Commissioners, from 9
the very beginning.
And this included you and your 10 technical assistants' participation at least viewing of 11 the publicly held meetings that we've
- had, and we 12 understand the periodic briefings with your staffs that 13 kept you abreast of what was ir. f act transpiring in those 14 meetings.
15 Secondly, the participation by your senior staf f 16 at the NRC to address the policy issues that were 17 identified during the development of the
- guidance, 18 followed by the industry and staff each working 19 independently and sharing the results of each other's public forum to develop the details and 20 efforts in a 21 understandings necessary for the policy implementation.
22 We've had several very productive meetings with the NRC 23 Steering Committee chaired by Jim Sniezek, and this 24 process has worked, in our opinion, very well.
25 The most important but third on my list that I NEAL R. GROSS 1
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think was critical to the success of this was the staff 2
development of the draft regulatory guidance rather than 3
that of a contractor.
This has been a very refreshing 4
experience for us in that the statf knew the basis for the 5
draft guidance being developed, it was not being 6
interpreted.
As a result, the dialogue was clear and 7
meaningful, the confidence level was high in the 8
discussions and, most importantly, the decisionmaking was 9
prompt and decisive.
In the popular parlance of 10 management gurus today, the cycle time was very short as 11 we moved through the development.
This is a very 12 important aspect of the process that should be introduced 13 in other areas where possible.
14 I also believe that this element of the process 15 will form a corporate history for the NRC which will 16 provide a clear basis for development of your inspection 17 module and guidelines.
18 Next, the staff's observation of the industry's 19 execution of the verification and validation process.
In 20 the beginning, there seemed to be some skepticism on the 21 part of some of the staf f of how serious we were in really 22 testing the draft industry guidelines 'that had been 23 developed.
We believe that having observed the depth and
~
24 the detail of each utility, that each utility has gone 25
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1 significantly.- This builds trust and understanding that 2
is important to the continued existence of our industry, 4
3 and there is, _I believe, a stronger recognition between 4
the industry and the com;nission staf f that we have strong 5
mutual objectives to provide reasonable assurance of 6
public health and safety.
7 And the final element was the candor with which 8
the industry and the NRC expressed'their views, bringing 9
their own dif ferent - perspectives up front and on the-10 table, despite the public nature of many of the meetings -
11
- of all the meetings that were held.
If concerns are not 12 clearly stated during the process, it can, in fact, 13 adversely af fect the outcome and, in some cases, could, in 14 fact, destroy the process.
Our respective positions and 15 the concerns that we made clear to everyone -
and I'
16 believe, to everyone's credit, that these were, in fact, 17 --
made clear.
For
- example, we stressed that the 18 implementation of the maintenance rule should not require 19 two maintenance programs -- one to' provide the necessary 20 maintenance to safely and reliability to operate the plant 21 in our terms, and another to comply just with the 22 maintenance rule.
23 Some of this candor made front page news in some 24 of the trade press, and I believe that that's the price of 25 the candor and openness are.at risk in this kind of a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON. O C 20005 (202) 2344 433
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process, but I think that the openness and the candor 2
itself do, in fact, provide a message of openness that in fact, be well received in the general public.
3
- can, 4
As I'm sure you would agree, these five elements that resulted from our efforts in developing the industry 5
guidance are not unique to the maintenance rule but can be 6
7 applied when addressing other issues.
I encourage us both 8
to use the lessons learned in the future as we proceed 9
with other initiatives discussed in detail with you last 10 week by Gene McGrath and other membern of the NUMARC 11 Executive Committee.
12 Tom will now brief you on the results of the 13 verification and validation program.
14 CHAIRMAN SELIN:
Before you move on to Mr.
Tipton, I'd like to make a couple of general comments in 15 16 response to these remarks.
They are really not 17 specifically oriented towards this process, but the 18 implications that you've drawn for the future.
19 The Commission, as you well know, is dedicated 20 to the concept of moving to performance-based regulation 21 where possible, and that's very attractive in many ways.
22 It says that we don't prescribe in detail how you do your 23 job, we look at the results and hold the results up 24 against technical standards and see if these results are 25 consistent with what we are looking for.
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Furthermore, in a process like_this there are 2
two implications.
The first implication is - that the 3
industry, or in specific cases the licensee, gets the 4
first shot at defining what will be done and how it will
+
5 be done, rather than the staff prescribing ~ how that's 6
going to happen.
And so that requires that there be-more 7
interaction, more questions, more cooperation, since going 8
in, a lot of the technical knowledge is in the industry's 9
hand and not in the staff's hand, and it's necessary that 10 the staff get this technical knowledge.
11 The second implication is that we will be more 12 and more, if we follow this policy, allowing the industry-13 to take the lead and not just defining how the job will be 14 done, but implicitly what has to be done.
15 Now, this is a positive approach in many senses, 16 but it does mean that.we have to be very, very careful to 17 distinguish places where we are learning from the peoplc 18 who we will regulate-some of.the technical complexities 19 that are involved in their own peculiar processes, rather 20 than trying to impose a standard process.
But_it's very 21 important that all kinds of careful-checks and balances -
22 are observed t'o make sure that we don't7go beyond-that 23 step and get advice from the regulated industry _on how the 24 regulation ought to be carried out and what the objectives 25 are, that the objectives are very clear, they are the NEAL R. GROSS-COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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government's responsibility.
The technical knowledge 2
necessary to carry out these objectives requires more 3
technology transfer and communication than when one 4
follows a prescriptive set of rules.
5 That's al2 positive, but it does mean that on 6
the one hand, we have to be very careful about where we-sued the initiative and where we maintain the initiative.
7 8
And the second is the discussion in the trade press that 9
you alluded to, Mr. McNeill, I thought, very graciously, 10 but effectivay in the sense of saying it's a necessary 11 evil.
It's not a necessary evil, it's an absolute 12 essential that if we are to have a process where there's 13 much more technical communication, there has to be a 14 countervailing process, be it the presa or the intervenors 15 or what have you, to make sure that we have equal 16 conversation to keep us from going beyond the point of 17 exchanging technical information and perhaps putting 18 ourselves in your shoes.
Having all this communication 19 carries the risk of an identity of views or just a casual 20 and unconscious acceptance of a point of view, and having 21 the trade press, intervenors, et cetera, also very much practical-22 involved in this, I think, will serve as a 23 reminder to make sure that we pay attention to the fact 24 that all parties have to have an opportunity to discuss 25 and have their views made present.
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So, this technical cooperation, as I said at the 2
NUMARC meeting, cannot be accompanied by a sense of 3
coziness, but 1ather a sense of professional respect and 4
opea communication, to which you alluded.
5 I think my own opinion is we've done fine in' the 6
maintenance area, but we need to make sure that we dan't 7
go beyond the levels that we have in the maintenance area, 8
to allowing the regulated community to draw up the agenda 9
or to make the first recommendation on what the standards 10 are to be met.
11 So, there are a lot of positive lessons to be 12 learned here, but there are a number of provisos that have 13 to be followed in the future.
I'm not at all 14 uncomfortable with what has been done up until now, but I 15 want to make sure that we don't just keep going further 16 and further in that direction without paying attention to 17 the proper roles of all the parties.
18 MR. McNEILL:
Tom Tipton.
19 MR. TIPTON:
Thanks, Corbin.
Good morning.
20 There were nine plants involved in the 21 verification and validation process.
I need to emphasize 22 that what we tried to do in setting up this program for 23 the V&V was to select plants that were not involved in the 24 development of the guideline itself because we felt that 25 would be a better test when we went through it with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N W (202) 2344433 WASHINGTON, D C. 20005 (202) 234 4433
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someone completely unfamiliar with it.
So, were 2
successful in selecting seven out of the nine utilities 3
who had not been involved at all in the development.
4 The plants that participated are included as an 5
attachment to my prepared remarks. All four nuclear steam 6
supply system vendor types were represented in the 7
program.
Over the last four months, there has been 8
intense involvement by each of these utilities; the 9
purpose was determine if it is clear how the industry's l')
maintenance guideline works or if additional clarification 11 is needed.
This detailed verification and validation 12 process exercised all elements of the industry's 13 guideline.
There were seven objectives in developing the 14 verification and validation program, and the objectives 15 and the results to date are as follows.
16 The first objective was to test the ability of 17 utilities to understand and use the industry guideline to -
18 implement the maintenance rule.
The participants in the 19 V&V program concluded that the guidance can be implemented i
20 as written. However, it was noted that some clarifications 21 of the guidance would be beneficial to the user.
22 The second objective was to determine the extent 23 to which non-safety related structures, systems and 24 components that are used in the emergency operating 25 procedures should be excluded.
The V&V utility j
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-i1 17 1
participants generally _ concluded that most of the'non '
2 safety. related SSCs in the emergency _ operating _ procedures 4
3 should be included. Exceptions were identified during the 4
process.
For example, there are some systems included in 5
the emergency operating procedures to-protect-key-systems 6
such as the turbine that have only economic benefit and do 7
not contribute _to accident mitigation.
8 The third objective was to identify and evaluate-9 the use of PRA and other methodologies for use in 10 identifying risk significant and plant level performance 11 criteria.
It was concluded, as a result of the V&V=
12 process, that PRAs used in conjunction with experti panels 13 identify the risk significant SSCs effectively.- PRA or 14 expert panels used alone have limitations that are 15 overcome by their use-in combination.
16 The fourth criteria was'to. verify-that the use 17 of the-guideline will result in
- similar, but not-i 18 necessarily identical, results among utilities.
The=V&V i
19 utility participants concluded that many differences in l_
20 results are attributable to actual configuration-l-
21 differences and not to guidance ambiguities. This is a key 1
22 element of the V&V findings in that' it-has-to-be-23 recognized when an individual utility is inspected, care-24-must be taken in attempting:any comparison between similar 25 units because of their different configurations.
-There l
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may be differences in the system selected as well_as the-2 performance criteria. established.- However, based on the 3
findings of the V&V, there were. good justifications for-4 these differences.
was to identify lessons 5
Our fifth objective 6
learned that f acilitate the rule implementation among all 7
utilities.
The implementation of the rule will affect utilities differently due to the different approaches thab 8
9 went into developing the individual maintenance programs
~
10 and the state of implementation for each of the utilities.
11 This includes the utilities' in-house capability, existing 12 software and databases, - as well as-individual utility 13 objectives and approaches for implementation.
Key ~
14 differences among some V&V participants were due to 15 system / train bounding and the-databases that currently 16 focus on component-data collaction rather than system or-17 train data.
Some utility performance monitoring, cause 18 determination and corrective action may need to be 19 expanded.
y 20-
-Our sixth objective was to identify the cost to 21 implement - the rule using care not to understate _ the:
i t
L 22 estimated implementation cost.
Our preliminary average l
L 23 non-recurring initial cost in labor hours -is approximately -
l l
24 16,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, that's approximately eight person-years per 25
_ plant. The average annual recurring cose was~ estimated to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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be around 5800 hours0.0671 days <br />1.611 hours <br />0.00959 weeks <br />0.00221 months <br /> per year, or about three person-years 2
per plant. We plan to provide information to the industry-_
3 on the anticipated resource needs and i.ow to efficiently 4
and effectively focus them.
5 CHAIRMAN SELIN:
Could I stop you for a minute?
6 MR. TIPTON:
Sure.
7 CHAIRMAN SELIN:
My understanding was that this 8
type of maintenance that we're talking
- about, was 9
maintenance that well run plants would be doing anywy and-10 poorly run plants ought to be doing.
So, when you talk 11 about resource implications, are there offsetting 12 resources that go over these net increments to what the 13-average plant is already doing in the way of maintenance?
14 MR. TIPTON:
In looking at the VIV reports, 15 there are not necessarily net increment increases because 16 of the rule.
In one report I noticed that they had an additional ~-
17 indicated that they were anticipating.
person-and-a-half-year because of the 18 person-year to a 19 administration of the program, in tracking the maintenance 20 failures, the repetitive failures, reviewing industry l
21 data, et cetera, as required by the maintenance rule. : So,-
22 I can't say that it is an increment in all cases.
23 MR. McNEILL:- I would add the following.
There 24
.was a degree of-variability between'various plants which 25 suggests that some people will have significantly less NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 13.?J RHODE ISLAND AVENUE,. N W.
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1 implementation manpower devoted to this, and others may 2
have more.
I think one of the preliminary conclusions 3
that you might draw from that is, what is the current 4
state of the maintenance programs at those plants.
So, we'd have to do a little more testing on that to do it, 5
6 but there was in excess of 100 percent difference at some facilities in the implementation, and I think that there 7
8 is some conclusion that you could draw, that that's 9
because they have a different degree of maintenance 10 program.
11 CHAIRMAN SELIN:
The one-time cost I could see 12 because if you go from one system to another system, 13 there's a cost to do that.
But I'd be quite interested as 14 time goes on, at the operating cost.
Most of the 15 paperwork, as I understand it, is paperwork that people 16 think ought to be done anyway, not additionally to meet 17 our requirements.
As Mr. McNeill says, there'd be a big 18 range of resources depending on what today's maintenance 19 is.
It would be really good if we could get some sense in 20 the future of whether the improved maintenance has led to 21 lower operating costs or lower operating ef fects by doing 22 preventive maintenance instead of losing availability of 23 devices. But I guess that's beyond the immediate focus of
~
24 your program.
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V&V.
2 Our last objective was to determine if 3
implementing the rule by use of this guideline results in 4
benefits to the industry, especially in regulatory areas.
5 It is clear as a result of the V&V program that some 6
utilities will benefit from implementing the maintenance 7
rule and updating individual maintenance programs.
8 However, it is also recognized that some utilities will 9
expend resources to implement the rule with no significant 10 benefit to their maintenance activities because of the 11 ef fectiveness of the programs that they have previously 12 established.
13 As we have discussed with the staff before, 14 there may be changes to the regulations that should be 15 made as a result of the final maintenance V&V program.
16 For
- example, during the V&V program the utilities 17 collected and provided us a
large amount of data 18 associated with containment leak rate
- testing, the 19 requirements of Appendix J of 10 CFR 50.
It was noted as 20 a result of the review of this test data that a large 21 majority of the penetrations and valves that are required 22 to be tested do not f ail. As discussed in our December 21 23 letter to you, Chairman Selin, the NRC was encouraged to 24 evaluate.ppendix J in light of the performance criteria 25 and pursue appropriate regulatory modifications.
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Corbin?
2 MR. McNEILL:
Are there any questions that you 3
might have of Mr.-Tipton?
4 CHAIRMAN SELIN:
I have a general question, but 5
it's not in response to something you've raised.
6 MR. McNEILL:
Okay.
Then I'll finish and then 7
we'll go over it.
8 COMMISSIONER REMICK:
Excuse me, I have one on 9
Appendix J.
I'm not sure I understand, Tom, what you just 10 said about Appendix J, what you found and the implications 11 on Appendix J.
12 MR. TIPTON:
Well, when we went through the 13 exercise, we asked each of the utilities to provide us 14 data on what they had seen.
And we had utilities give us 15 input from one to six outages.
In other words, they went 16 back at least six cycles to soe what they had found.
And 17 in several cases, for example, in five outages, 200 18 penetrations had been tected and two had fa!. led out of-the 19 200.
What we were finding was the trend based on 20 historical data, in effect, penetrations just are not 21 failing due to the testing.
22 So, our suggestion would be to look at a 23 performance-based philosophy based on historical record, 24 just like we're doing in maintenance.
25 COMMISSIONER REMICK: Performance-based Appendix NF.AL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE N W.
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J, is that --
2 MR. TIPTON:
That's correct.
3 COMMISSIONER REMICK:
Okay.
Thank you.
4 COMMISSIONER de PIJd1QUE:
I'd just like to 5
follow up on your seventh item.
You said some utilities 6
will be expending resources without a positive benefit.
7 The implication la they were ahead of the pack in doing 8
the maintenance programs essentially, anyway. Is that the 9
proper inference?
10 MR. TIPTON:
I think it is in that we had one 11 individual utility in the V&V program that had not only 12 finished their
- IPE, but they had a
very detailed 13 reliability centered maintenance program.
They had 14 developed all of this technology in-house.
And their 15 response to us was they would not really see much in the 16 way of benefit because of their programs, but they would 17 see approximately 1500 person-hours per year additionally 18 because of the administrative burden to do it.
19 COMMISSIONER de PLANQUE:
Just the 20 administrative burden, not a need to change the program 21 per se to comply with --
22 MR. TIPTONr They didn't see any major change in 23 their programs, no, 24 COMMISSIONER de PLM1QUE:
Okay.
25 MR. McNEILL:
The next question-that we intend NEAL R. GROSS COURT REPOHTERS AND TRANSCntBERS 1323 RHODE ISLAND AVENUE. N W.
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24 t
1 addressing is whero do we go from here?
In addition to 2
our efforts to develop and verify the industry guideline l
3 in the V&V program, we have responded to the NRC Federal 4
Register notice requesting comments on your draft 5
regulatory guide.
In our response we described changes to 6
the industry's guideline that we are considering based on 7
the results of the V&V program as well as other comments l
8 from the indu.stry.
9 The next step, from our point of view, is to 10 review with the etaff the comments received on the 11 industry's guideline as well as changes we are considering-12 incorporating by March of this year, and then to finalize 13 that guidance by June of this year.
14 Following the
$1nalization of the industry g
15 guideline, NUMARC plans to hold two three-day workshops in 16 July and August to cover-in detail the results of the V&V 17 program, changes made to the regulatory guideline, and to 18 provide a detailed discussion of how to properly implement 19 the guideline and to do so effectiv0ly and efficiently.
20 We anxiously await the development of the NRC's 21 inspection module associated with this regule. tion.
I must l
22 stress that.a major concern-of our industry continues to 23 be how our facilities will be inspected against a
1 24 performance-based regulation.- During the public-comment ~
25 period of-the draft regulations, NUMARC-has spent many NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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25 1
hours with individuni utilities discussing those 4
2 individual utility concerns regarding the potential that 3
the scope of the rule could be unnecessarily expanded or 4
utility implementation inappropriately evaluated.
It is 5
clear, as a result of the VIy program, that the NRC should 6
not compare one plant to another during inspections, but 7
evaluate the individual plant based upon its actual B
perf or-ance, taking into account its individual design 9
characteristics and the effectiveness of its maintenance 10 programs.
11 We have received assurances since the start of 12 this process that the industry would have meaningful input public forum into the review of the inspection 13 in a 14 module.
We are prepared to do so and look forward with 15 keen interest to similar interactions.
16 In conclusion, I'd like to stress two key points 17 as we go forward in this process.
Iu is imperative that 18 the Commissioners continue to be involved in the process 19 through the final development of the industry guideline,-
20 that the NRC's. inspection module and the associated.
21 training required to fully implement this first of a kind-22 "perf ormance-based"' rule.
It's very important that we 23 continue interacting during the three years remaining
' 24 prior to the final implementation, or full implementation, 25 in July of 1996, as issues come to NUMARC's attention,land f
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26 f
1 to the NRC's attention, that we resolvo them in a
2 satisfactory and timely manner.
We need to continue to
[
3 have candid and well thought out discussions during the 4
three-year implementation period.
We look forward to 5
continuing our discussions with the staff and with the i
6 senior management of the IRC as we go forward.
7 Thank you very much, and we would be pleased to 8
answer any questions that you might have.
9 CHAIRMAN SELIN:
I'd like to start off with a 10 fairly specific question, and then allow my colleagues to-11 come in.
I have some general comments and questions at 32 the end.
13 I wasn't here during the preparation of this 14 rule, so I missed some of the history and some of the 15 interesting interplay, but reading the rule as it resulted 16
-- I have sort of a general question and chon a specific 17 question for you -- and it has to with the 50.65, Parts 18 (a)(1) and (a)(2), the requirements for monitoring the 19 ef fectiveness of maintenance in nuclear power plants. Let 20 me just tell you both questions.
21 The-general question is, as.you road this, how l
22 do you see the difference in the implications =for what y
l 23 utilities will have-to'do, depending on whether an SSC is l
or paragraph-(a)(2)?
And then,.
L 24 put into paragraph (a)(1)t 25 specifically, how would you-determine for a giv~en SSC NEAL R. GROSS-CQVRT REPORTERS AND TRANSCRIDERS -
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where you think it ought to be, under which paragraph it 2
ought to be?
In other words, the general questien is, 3
from your point of view as you read this rule, what do you 4
see the implications for the utility in performing 5
maintenance on SSCs that fall in paragraph (n)(1) versus 6
SSCs falling in paragraph (a)(2),
and
- then, more 7
specifically, how would you noe looking at an SSC and 8
trying to determine, from your point of view, where it 9
belongs?
10 MR. Mc!1EILLt My opinion on that is that the 11 actual maintenance that will be done, if properly -- if 12 the maintenance routines are properly generated, either on 13 an experiential basis or on an engineered basis like in a 14 reliability centered maintenance program, that the true 15 impact of the rule is more in the monitoring and the basis 16 of the monitoring and the basis of the performance, and 17 that management will have a
better view of the 18 effectiveness of that maintenance on specific systems, 19 components and structures than they might otherwise have 20 done absent the rule.
21 Secondarily, there is in the rule a process --
22 or at least in the implementation of the rule -- a process 23 that should identify repetitive,
- faulty, improper or 24 lacking maintenance, and would provide a
feedback 25 mechanism to correct that.
And I personally think that NEAL R. GROSS CoVRT REPORTERS AND THANSCR$ERS 1323 RHODE ISLAND AVENUE. N W.
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that's appropriate in some measure to the application of 2
this to the life extension issue, is that there is a 3
feedback mechanism built into this process that requires j
4 correction if, in f act, you don't meut certain maintenance 5
standards.
I think that the 6
liow, we have struggled 7
biggest struggle that we've had in developing tho 8
guidelines and in our discussions with the staf f, has been 9
around the (a)(1)/(a)(2) category and defining those. And 10 very candidly, we, I believe, have ended up with a 11 document that complies with the rule, but is-somewhat 12 different than envisioned by the draf ters of the rule but, 13 in
- fact, makes more sense when applied in a plant 14 situation.
15 CilAIRMAll SELI!1:
But in practice, do you see a 16 big practical impact for an SSC, depending whether it's 17 (a)(1) or (a)(2), or is it just a modest difference?
18 MR. McNEILL:
No, it 's - a modest difference, l
if you are not performing 19 because if you-don't 20 effective maintenance in (a)(2), you are going to end up 21 in (a)(1).
22 CHAIR!4AN SELIN:
So, you would see a process.by I
23 which SSCs would go back and forth, depending --
i 24 MR. Mc!!EILL: Some would, some of them will stay 25 in (a)(1) because of their safety --
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29 1
HR. TIPT0!It In (a)(2).
2 MR. McHEILL
-- In (a)(2) -- well --
i 3
MR. TIPTOll:
Maybe we should quickly go through j
4 the process as set up in the guideline.
Basically, the i
l 5
way the process works is you identify those systems, 6
structures, and components that are in the maintenance j
7
- rule, and then through a PRA or a critical system 8
- analysis, et
- cetera, you determine those
- systems, 9
structures, and components that are risk significant, and 10 those that are risk significant and those that are 11 standby, you would have to identify performance criteria N
12 to evaluate them against.
13 Now, if they meet the performance criteria based 14 on historical record -- and our historical record is two 1
they would stay in 15 refueling outages before 1996 16 (a)(2). The third group would be those non-safety related
'l l
17 systems that are operating, such as feedwater system, that 18 would have their performance criteria at the plant level -
19
- scrams per thousand operative hours, et cetera.
20 So, the perf'ormance criteria would be -- set up.
21 You evaluate your systems, structures,- and components 22 against that criteria.
If they don't meet it, you go to.
c 23 (a)(1) and establish goals for'two reasons.
.The first:
24 reason was our first goal was to make_sure-.we-had.one 25 maintenance system, not two; the second was if you have a NEAL R.. GROSS COURT REPORTERS AND TRAN$CR$tRS
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goal on a system, it would be clear to the managernent that 2
it's not meeting its performance criteria.
In other 3
words, there is a significance to the word " goal".
And so 4
in establishing the guideline, when the V&V program went 5
through
- that, they established, for
- instance, the.
j 6
availability as a performance criteria, then they went l
7 back and looked at the last two cycles.
If they had the 8
acceptable availability, let's say, that was used in their 9
IPE, then they would stay in (a)(2) under the preventive 10 maintenance program but, if they didn't, they could move f
11 into (a)(1).
12 CHAIRMAN SELIN:
So, on day one there could be i
13 quite a bit of difference from one plant to another about 14 what systems are (a)(1) or (a)(2).
l 15 MR. McNEILL:
That is correct.
+
16 MR. TIPTON:
Absolutely, based on historical 17 record.
18 CilAIRMAN SELIN:
I see.
19 MR.
McNEILL:
And.that is one of the 20 realizations that we came to, that we had to even 21 though the rule-does not-become effective until 1996, you 22 have to really be implementing it prior to that in the 23 plant so that you hit 1996 with the required data and 4
24-
_ performance criteria already well in hand.-
25 CHAIRMAN SELIN:
Well, let me just go on to NEAL R. GROSS COURT REPORTERS AND TRANSCk1BER$
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this, and then I'll turn it over to the rent of the 2
Commission.
Would you see any systems being so important 3
to safety that they would be in any one initially, in other words, 4
regardless of the plant performance 5
just across-the-board?
6 MR. TIPTON: Not the way we've set this up, no -
the reason being we tied to the performance of that 7
8 system, okay?
9 CilAIRMAN SELIN:
In that plant.
10 MR. TIPTON:
In that plant.
11 CHAIRMAN SELIN:
As opponed to industry-wide 12 performance.
13 MR. TIPT0!!:
That's right.
14 CHAIRMAN SELIN: I mean, if diesels were running 15 at 92 percent reliability instead of 98 percent 16 reliability, you still wouldn't be --
17 MR. TIPTON:
They would be (a)(1).
18 MR. McNEILL:
They would be back --
19 CilAIRMAN SELIN:
Across-the-board.
20 MR. TIPTON:
Well, no.
If a diesel at that 21 utility was not meeting its reliability --
22 CHAIRMAN SELIN:
That's not the question I'm 23 asking.
The question I'm asking is, are there systems 24 that are so important to safety and where the industry-25 wide performance is not so exceptionally good that you NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 RHODE ItLAND AVENUE. N W.
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i 32 I
would start off and say they are all in (a)(1) in every 2
plant until a given utility can show it's much better than j
3 the overall standard?
4 MR. TIPTON:
Not the way we set this procedure 5
up, no.
6 MR. McNEILL:
But the end result is that you 7
will get what you're looking for.
8 MR. TIPTON:
If it's not performing.
9 MR. McNEILL:
Well, you're going to get it 10 monitored even beyond --
1 11 CHAIRMAN SELIN:
Let me just tell you why I'm 12 asking this
- question, is that-when we talk about 13 performance monitoring, we usually are talking about the 14 performance ~of one plant compared to the industry average 15 but, in fact, a lot of the ' performance monitoring is 16 industry-wide.
You know, if you have small samples, you 17 may not have good data on one plant to another. about-18 variations, and the question is, across all 107-108 19 plants, what'is the performance of-this system, and your-20 answer leads me to believe that you believe for the major 21 the major systems you can determine characteristics on a 22 plant-by-plant basis, even though some of these samples 23 are pretty small.
24 MR. TIPTON:
Well,.it's also required in the 25'.,' maintenance rule that you evaluate against_ industry data NEAL R. GROSS-COURT REPORTERS AND TRANSCRIBERS S
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1 where applicable, And in the diesel situation, there's 2
industry data that you're required to review against.
3 CilAIRMAN SELIN:
Okay.
Commissioner Rogers?
4 COMMISSIONER HOGERS:
I wonder if you would 5
comment a little bit on how many significant plant systems 6
aren't entered into the NPRDS database that really are 7-needed to be able to make this judgment of dispooltioning 8
of SSCs into Category I or Category II.
9 MR. TIPTON:
In the industry?
10 COMMISSIONER ROGERS
- Yes, the data isn't 11 entered into the NPRDS system really, on some systems.
I 12 think the Inst.rument Air system is one that was mentioned 13 here.
11ow many important systems do you-feel there is an 14 inadequate database in NPRDS?
15 MR. TIPTON:
The only one that I'can remember 16 going through che reports was the Instrument Air, but you' 17 have to understand that they ' don't rely just on NPRDS, la CFAR, et cetera. They basically look first at their plant 19 history on those systems and at a system / train level.
20 Now, there will be situations where you'll want to go to 21 the. component level because it's an isolation _ valve 22 between systems.
But genovelly speaking, I think--one or 23 two of the V&V programs did go back and go through their 24 NPRDS database systems compared to the industry, to.do a 25 check on where they are relative to the industry, but it's-
~
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34 1
more based on their plant's history at that plant.
2 The other thing that complicates it a little 3
bit, you have to understand we're looking for maintenance 4
preventable fal)ures alone in t6rms of making the 5
decision.
So, that wrinkle's in there.
6 COMMISSIONER ROGERS:
On these workshops that 7
you plan to hold in July and August, who's going to 8
participate in those?
9 MR. McNEILL:
I don't think we've come to that 10 conclusion, but I would see these in a manner similar to 11 a number of workshops that we've had, that we will 12 probably have both NRC and NUMARC presenters at the 1
13 workshops.
14 MR. TIPTON:
We will definitely -- I'm-sorry.
15 MR. McNEILL I would think we will' invite the 16 NRC to participate.
17
'MR. TIPTON:
Yes.
18 COMMISSIONER ROGERS: Well, you know, just along
~
19 the lines that the Chairman referred to very early,. on the l
L 20 importance of openness in this process, do you expect that' 21 any other organizations might be able to participate'if 22' they wish to?
9 23 MR. TIPTON:
In the'past, what we have-done is
~
24 we have the utilities, INPO, EPRI, et cetern, involved in 25 our program. Basically, what'we do in our workshops is go NEAL R, GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHODE ISLAND AVENUE. N W, (202) 2344 433 -
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through -- for instance, in this case, we would go through 2
what the vs.V plants went through, and be in a position to 3
answer quustions from their point of view.
So, since the 4
workshops will be focusing on the guidelines, that's how 5
we'd handle it.
6 MR. McNEILL:
I think another -- we will get 7
back to you and give you our opinion on whether --
8 COMMISSIONER ROGERS: Yeah, I think that's worth 9
taking a look at just to see --
10 MR. McNEILL:
It's not clear what their rola.
11 would be, whether they would be a presenter -- I'm not so 12 sure they have the expertise to make the presentations for 13 the nature of the -- but to be someone in the audience.
14 We may be able to arrange that, but we'll get back to you
- t 15 through the NUMARC staff.
16 COMMISSIONER ROGERS:
All right.
.It would be 17 interesting to hear what your thoughts are on that.
18 CHAIRMAN SELIN:
May I just follow up?
19 COMMISSIONER ROGERS:. Sure.
20 CHAIRMAN SELIN:
If this were a mature process, 21 and really it is just a communication about how the rule 22 applies to main feedwater pumps, that would be fine, but 23 this is an evolving process with implications, as you 24 drew, Mr. McNeill,-that goes f ar beyond.. a speech and, L
25 therefore, the importance of not only accepting but going NEAL R. GROSS COURT REPORTERS AND TRANSCRlRER$
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out of the way to getting a range of opinions of what you 2
might think of as a technical workshop is essential becaune it won't be just the presentation of here's how it 3
4 works, it'll be almost certainly further evolution in what 5
the policy and the process is, and it's essential that 6
such meetings be not only open, but anybody who has a say 7
be invited to do that say at that session.
8 I'm sorry.
9 COMMISSIO!1ER ROGERS:
11 0, that's fine.
- Really, 10 that's all I wanted to say.
11 CHAIRMAN SELIll Commissioner Curtiss?
12 COMMISSIOllER CURTISS:
I just have a couple of 13 comments and a couple of questions here.
I thought the 14 presentation was generally pretty thorough at summarizing 15 what obviously reflects a good deal of work that's gone in 16 since July of 1991.
17 Let me say a word or two about the process 18 because I, in many respects, share the observations that 19 the Chairman made, and would like to pick up on your 20 commenta, Mr. McIloill, about where we go from here.
I 21 have several comments I'd like to make.
22 First, I think, from my perspective, that this 23 process that we've employed which, in many respects, was 24 necessitated and appropriate because of the f undamentally 25 dif f erent kl.nd of regulatory approach that's been taken in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4413 WASHINGTON. D C 2000$
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this rule and, hence, needed and, I think, benefitted from 2
senior attention both within the agency and within the 3
industry.
4 The process, in my view, as it's been undertaken 5
so f ar, has been a model of the way we in carrying out our-6 independent responsibilities, and you in ensuring that you 7
have sufficient flexibility to adopt approaches that may 8
differ from plant-to-plant but nevertheless will achieve 9
the objective or goal that we've established in this rule.
10 This process, I think, comes pretty close to the mark in 11 terms of being about an ideal process.
12 It is not without its vulnerabilities, the 13 Chairman has summarized those, and I think there are 14 vulnerabilities in terms of the impression that we're'in 15 cahoots in developing this approach, or somehow'it's not 16 being done in a fully open process, that we need to-be 17 sensitive to, and I'd like to say a word or two about that 18 because I think there are-things that we have done and can -
19 think about doing in the future to make sure that there is-20 as inclusive a process that will benefit from a wide range 21 of views, not just those represented here in the agency or 22 within the regulated community, that will" serve to improve 23 the regulatory product.from the standpoint of our job, 24 which is to ensure that the public health and safety is 25 protected.
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38 1
It ought not to be lost upon anybody that this i
2 process has been in some respects a confrontational one.
confrontational, I
i 3
Deginning from the very outset 4
think, productively so -- beginning from the outset, I 5
will note when the industry as a whole opposed adoption of 6
a maintenance rule that the commission, nevertheless, for 7
reasons that I think have been borne out in the subsequent i
8 developments, believed were appropriate and necessary.
9 Secondly, my sense, having watched this process 10 rather closely and having attended some of the meetings 11 and read all the minutes and been briefed on a-continuing.
12
- basis, is that we set out in the clearest and most 13 unequivocal terms what our objectives were as an agency in t
14 terms of implementing this rule, and I think there came 1
15 pretty close to the mark at the outset as well.
There was 16 a lot of productive discussion-on how we achieve those 17 objectives, but very little give on what the objectives 18 were in terms of the performance of SSCs within a plant.
(
19 And if there has been any. accommodation here in that 20 regard, I'd commend you for the significant movement that 21 you've taken in the direction of what the staff insisted 22 upon from the very outset in terms of how this rule had to 23 be implemented. And I think that's been productive, been 24 a lot of give-and-take on the prescriptive details._ We've 25 certainly benefitted from the V&V program, which I think -
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39 and I'll get back to in a minute -- gave us a technical 1
2 perspective, as the chairman emphasized, that we wouldn't 3
otherwise have if we didn't have the benefit of a program 4
like that.
5 1 think the procean has been a useful one.
I 6
think, as I say, and I've suggested in other contexts with 7
all the caveats, about the need for opennesa.
These 8
meetings have all been conducted in a public fashion, and 9
the opportunity for people to comment and to address 10 raise and address issues, that this process can and 11 perhaps should be used in other contexts, not just limiteri 12 to performance-based regulatory initiatives where there 13 was a unique justification for it here.
14 I read with great care your comments on the 15 development of the inspection guidance, and I have, in 16 fact, come to recognite that the inspection guidance for 17 this rule is a matter of great sensitivity because that's 18 where the " rubber hits the road" when we go out and 19 inspect against what this rule in this guidance now will 20 hopefully accomplish.
21 And I haven't given a good deal of thought to 22 where I come out personally on the question of how to 23 achieve the same kind of interaction effectively, in an 24 open way, on the inspection guidance as we've achieved on 25 the development of the guidance for the rule itself, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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1 I do think because we are talking about inspection 2
- guidance, there are uomo considerations that warrant 3
taking a careful look at how we approach our respective 4
responsibilities in the development of that guidance, and 5
I'd like you to think about that, our people, I know, 6
have thought about it because I've talked to them about 7
it.
8 one thought that I would toss out for your-I 9
consideration -- and I don't need your reaction at this 10 point unless you'd like to -- we have, for tha development.
11 of the interim inspection guidance, which is the guidance 1?
that now governs inspection of maintenance programs 13 between 1991 and 1996, employed a process that it seems to 14 me might appropriately balance all_
the competing 15 considerations, and I would commend it to_you for your 16-consideration here.
Our people are hard at-work-on the 17 development of the inspection guidanec, and I think we'll 18 hear more about that when they make their presentation.
19 I would offer the thought that perhaps what_we 20 ought to do is take the inspection guidance when our~
21-people complete its development and give_it'their_best 22 effort -- we'll find _ out when that-is here shortly ---
23 publish it for public comment so that it will get the' 24 widest possible public opportunity for-vetting, if-you 25 will, and maybe in conjunction with that-and.similar to NEAL R. GROSS COURT REPORTERS AND TitANSCRIDERS 1323 MHODE ISLAND AVENUE. N W.
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i 1
what we did on the interim inspection guidance, conduct a 2
workshop, we would conduct a workshop -- and I haven't 4
3 raised this with the others, but it's an approach that the 4
Chairman has suggested in the context of Part 52 and I 5
think worked remarkably well there.
We have used it for 6
the interim inspection guidance and it worked there as 7
well, and it might provide an opportunity for you to take 8
a look at what our staff believes would be a first good i
9 cut at the inspection guidance to have an interaction like 10 we've had in this context, but it's to ensure that there's 11 an open forum where anybody else who wishes to interact, 12 after being published in the Federal Register, would have 13 that opportunity. And I toss that out for your reflection 14 as we move to the next step.
15 I do have a handful of specific questions that 16 I would like to ask you.
Picking up on Commissioner 17 Rogers' question 'about NPRDS, I,
- too, had the same slightly different perspective.
18
- question, but from a 19 Instrument Air is the one system that you have determined 20 is risk significant, that is not reported in the NPRDS 21 context. And while I think you've described appropriately 22 and accurately how an individual licensee will set.the 23 goals and performance criteria under this rule,- the 24 question, I guess, that recurs in ~ my mind is, in the 25-experience with the V&V program, did we learn anything NEAL R. GROSS COURT REPORTERS AND TRANSCH DERS 1323 RHODE ISLAND AVENUE, N W.
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about the comprehensiveness cf the NPRDS system that might 2
suggest that as an industry-wide effort, NPRDS in certain 3
respects perhaps could be more useful for the purposes 4
that commissioner Rogers laid out, to gain industry-wide 5
experience and to fill the gaps that might exist today in 6
the NPRDS reporting system, so that can complement in a 7
more effectively way what we are doing in the maintenance 8
context.
9 MR. TIPTON:
Commissioner Curtiss, based on the 10 experience of the nine V&V plants, their conclusion was 11 overall at this time that there didn't need to be a change 12 in the NPRDS database, okay -- but that's a sample of the 13 industry.
14 As we go forward in full implementation for the 15 industry, we may see a benefit, a need, et cetera.
So, I 16 can't close out changes,-but just based on what we have
'17 gleaned from the reports and the feedback from the nine 18 plants, they didn't-see changes. in the NPRDS at this time.
19 COMMISSIONER CURTISS:
Okay.
- Well, I'd
{
20 encourage you to take a look at that.
I know our folks in 21 AEOD over-the years have focused on the question of how l
22 durable and comprehensive the NPRDS database is.
It would-r L
here in taking into account the 23 be extremely valuable 24
-industry-wide _ experience in setting goals and performance 25 criteria not required, but -- NPRDS is not a system that's-h NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS-1323 RHODE ISLAND AVENUE, N W.
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required to do that, but it seems to me it could be 2
extremely beneficial if any shortcomirige that have been 3
Identified can be addressed here.
4
- Second, the one majcr change that you have 5
- proposed, or major expansion, if yose will, in the 6
guidance, is in the area of the use of PRAs.
Could you 7
say a word or two rnoro on how, based upon your comments, 8
you'd propose applying PRAs in the risk significance 9
context?
10 MR. TIPTON:
I will get out of Iny area very 11 quickly if I go too far on this, that's why I have the 12 experts behind rne,
but what happened was, when wo 13 originally developed the concept of risk significant 14 systems, we were looking at it in terms of contribution to 15 core melt f requency, but other schemes came up during the 16 V&V process that were equally applicable to make that 17 decision on which systems were risk significant.
18 And, so, what we developed -- there were major 19 changes to the guidelines after the V&V, as a result of 20 that, to make that determination of which systems had the 21 rnajor contribution to reducing risk and identifying those 22 systems through the PRA, and then based on that providing 23 that to the expert panel for those areas where there's 4
24 uncertainty or the model didn't cover the modes, all modes 25 of the plant operation -- for instance, refueling outage NEAL R. GROSS COURT REPOnTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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where you have RilR as an active system instead of a 2
standby system.
3 And, so, with that combination of the two, and 4
the fact that through the V&V they came up with the 5
" risk /wortha
- criteria, that's why we had the major 6
changes.
But I want to emphasize that PRA is not the only I
7 way, as in the guidance, that you can get a handle on the
]
8 risk significant systems.
9 COMMISSIONER CURTISS:
I was impresa..I with ~~
10 I read the section here that you propose to expand upon, 11 the risk achievement worth section in 9313, and I must say 12 I was impressed with the work that's been done, and it's 13 really come as a result of the V&V program where it's 14 gotten greater focus, to define in more detail how PRAs-15 might be used in this context, and give some practical 16 meaning to the IPEs that will be coming in here and can-be 17 used, I think, very effectively in this context.
18 MR. TIPTON:
Yes.
19 MR. McNEILLt I think that we recognize not only-20 that, but we recognize that IPEs have not:yet broadened 21 beyond a certain set of operating conditions for the plant 22
.-- generally, the operating plant as opposed to t_he shut-
~
23
'down plant.
24 And, secondarily, we acknowledge that there-is 25 uncertainty associated with PRA calculations, and that you NEAL R. GROSS COURT REPORTERS AND TRANSCRIDER$
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can, in fact, use human minds to interface with that and 2
interpret those results more than you necessarily can with 3
statistics.
4 COMMISSIONER CURTISS:
Okay.
Just two other 5
quick questions and then l'll be done here.
On the 6
(a)(1)/(a)(2) question, Corbin, you had an interesting 7
comment that you didn't think it was quite in accord with 8
the drafters of the rule and what they were thinking at P
9 the time.
And as one who was around at the time and 10 involved in ihe drafting of the rule, I guess.my view is 11 that we've seen some evolution in whether a system, 12 structure, or component will start out under (a)(1) or 13 (a)(2), but two comments that I guess I'd make.
14 First, it ought not to be lost _. night of that' 15 whether you're under (a)(1) or (a)(2), that distinction 16 has been the focus of a lot of discussion because there 17 are two separate sections there that have different 18 requirements associated with them, but it ought to be 19 emphasized that there's a good deal of monitoring, as that 20-term is understood in the-(a)(1)_ context, that will go on 21 in the (a)(2) context of licensees' PH programs, and 22 because of the discussion.of the difference between the
~
23 two, I think we've seen the distinctions between the two'-
24 breakdown a little bit.
Thero's been. this, I know, 25 obsession with having systems all start out.under (a)(2)
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and stay there because of a fear of what (a)(1) might 2
cause a licensee to have to do, but from my own personal I
3 perspective I think that the rule itself is aufficiently 4
flexible to accommodate this outcome.
In fact, I think 5
it's a reasonable outcomo and, f rom sny perspective, thin 6
approach is fully in accordance with the rule itself, if 7
there was any question --
l 8
HR. McNEILL:
I have no question-about that, but 9
it has, in fact, gone through a lot of interpretation, 10 public interpretation.
I think we're fully in compliance 11 with the rule.
Part of the problem came from the 12 definitions of terms in the beginning, which were not all 13 fully defined -- what is monitoring as opposed to what in 14 data taking, and things of that nature.
15 COMMISSIONER CURTISS:
In that regard, let me 16 ask you, based upon the effort that you've undertaken to 17 date, are there any modifications or changes.to the rule 18 itself that you believe we need to consider?
4 19 HR. McHEILLt I don't think we are prepared to 20 answer that question right now.
We do know,-or let's say.
21 we're cognizant of the fact that there has been some 22 discussions about a minor modificationfof the rule-at 23 sometime before it's full implementation date,:and I think' 24 that as time goes on and we work our way through this, 25 that we may have some suggestions there, but --
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COMMISSIOllER CURTISS:
- Okay, 2
HR. Mc!1EILL:
Go ahead.
3 MR. TIPTOll There's one that's had a lot of 4
discussion, and that is instead of annual review, go in a 5
fuel cycle because you get data during a refueling cycle.
6 COMMISSIONER CURTISS:
Right.
That's the one r
7 that I'm aware of.
8 MR. McitEILL:
That's the only very physical one t
9 that I know of.
10 COMMISSIONER CURTISS:
Okay.
You don't know of 11 any other -- there are no others that you.believe need to 12 be made?
13 MR. McNEILL:
No.
I think we havn been able to 14 construct implementation guidelines that implement the 15 rule satisf actorily, and do so in an effective manner from 16 the industry's viewpoint, and not require a rule change 17 other than that one specific one.
18 COMMISSIONER CURTISS:
Okay.
Finally, on the 19 question of how this approach might fit into or be 20 integrated with the license renewal rule, do you have a based upon your experience -- obviously, to the 21 sense 22 extent.that one:might look to this rule as providing a 23 database related to performance of SSCs that are covered 24 under both-rules, the question that arises, how long do l
l 25 you need to develop that database?
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Mr. McNeill, I think you touched on the question 2
of utilities needing to get going on the implementation 3
rule prior to 1996.
Do you have a sense, based upon your 4
V&V program, as to what period of time in implementation l
5 of the rule, one would need in order for the performance 6
of SSCs to settle out in terms of whether they are under 7
(a)(2) and addressed appropriately, under (a)(1) and the 8
subject of goals, to give you a good database under your 9
belt'l 10 MR. McNEILL:
I'm going to ask Mr. Tipton to 11 address that, and I'm going to provide one further comment 12 on the issue.
13 COMMISSIONER CURTISS:
Okay.
14 HR. TIPTON:
The way we set up the guidelines 15
'and the fact that we hopefully will finalize them in June 16 of this year, we think the three-year time frame between 17 now and full implementation we'll have sufficient time 18 with the-data we've already collected, to collect the 19 necessary data to make that-determination in terms ~ of 20 their performance.
21 COMMISSIONER CURTISS:
Okay.
I don't want to 22
-put words in your mouth, but if the.. licensee implemented 23 this rule during that three-year period come July 1st of 24 1996, the potential'that you see for application of this 25 rule in the license renewal context would lead you to say NEAL R, GROSS COURT REPORTERS AND TRANSCR:BERS 1323 RHODE ISLAND AVENUE. N W, (202) 234-4433.
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that we ought to have sufficient information upon the 2
performance of SSCs to say that the maintenance program 3
cither is or isn't working of fectively for that particular 4
SSC'/
5 MR. mci 1EILL I believe that's the case, and 6
certainly no more than one year beyond that particular 7
case.
0 11ow, I'd like to -- I know there's been a great 9
deal of discussion about ma!.ntenance rule applicability to 10 the life extension rule, and I'd like to give you one 11 example that we've in fact had at our Peach Bottom 12 station, and it's not a life extension issue, but it's 13 very, I think, relevant in this case.
14 Back in the 1960s, the popular power cable at 15 that time was made with a dielectric material -- and I do 16 not know the specific name of it -- which in a moisture 17 environment has broken down under a
process that's 18 ref erred to as " treeing", and it applies not only to power 19 plant, but in fact we see it on our transmission and 20 distribution systems.
And we have had a failure at Peach 21 Bottom from that.
We did the appropriate diagnosis, and 22 we have in fact gone in and sampled other cables by 23 pulling them out and examining them. And I would say that -
24 that's the kind of outcome that should occur in the 25 maintenance program that in fact provides relevance to a NEAL R. GROSS COURT HEPORTI HS AND TPANSCRIDERS 1323 RHODE ISLAND AVENUL I4 W.
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brood area of the aging issue for it.
2 So, I am personally -- and I'm not speaking for 3
the industry here -- I do think that there is a great deal 4
of relevance of the implementation of the maintenance rule 5
to plant life r.< tension and building the requisite data 6
necessary to support life extension.
7 COHMISSIOllER CURTISS: Okay. That's all I have.
8 CilAIRMA11 GELIlit If you'd just forgivo me for 9
one minute, I'd like to follow up on this question of rule 10 changes that of all the areas where we must be absolutely 11 certain that everybody has an opportunity to comment on 12 that, not just the licensees, that is the critical area.
13 Obviously, any recommendations for rule changes that come 14 from the regulated community will be vetted for interest.
15 Do you have any other suggestions as to how that area can 16 be kept wide open?
17 MR. MellEILLt We had no anticipation that the 18 rule change that we might suggest would be handled in 19 anything other than the Commission's routine process for 20 modifying its existing rules, which would include open 21 public comment, and public notice, and whatevar.
22 CHAIRMA11 SELIllt Yeah, but there's another hat, 23 which is the experience that has been gained through these 24 joint working areas might suggest to other people rules 25 changes.
We need to figure out a way to make that NEAL R. GROSS l
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1 experience publicly availabl9 so that -- your conclusion 2
is only one change is necessary.
Somebody else might 3
conclude something different.
4 MR. Het1EILL:
I believe they have a process to 5-submit recommended rule changes to the Commission, I
i 6
believe.
7 CIIAIRMAtt SELIN:
Commissioner Remick?
8 COMMISSIONER REHICKt What impact, if any, do
{
s 9
you foresee on the implementation of the maintenance 10 guidance document, depending on whether the inspection 11 guidance comes out sometime reasonably soon versus being 12 delayed for several years?
Do you see any impact on the 13 implementation by utilities?
14 MR. McriEILL:
Well, I see -- there will be.a 15 risk, let's say, at least a perceived risk in doing that.
you know,.the 16 We are in the first of a performance 17 first example of a performance-based rule.
There is --
18 there was industry concern on how we - were. going to 19 implement that rule.
There has been industry concern -
20 about how'it will, in fact, be enforced.
And I think,;
21 though, if we wait too long, there will be an uneasiness 22 out.there'as to whether I'm doing it right or not.
- And, 23-you-know, we would suggest that there be development of a 24 module, that that module be piloted a rumber of. times 25 early in the process, before the rule is fully effective, NEAL R. GROSS CoVAT REPORTER $ AND TRANSCRIBERS 1r3 RHODE ISLAND AVENUE N W.
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1 and that the lessons learned from that be brought back
)
2 into the industry, and there may be ame Jessons for the 3
staff to understand also.
4 I think we have the basis of a good -- the other 5
reason for not waiting too long is that the individuals 6
and the NRC's corporate history that's been involved in 7
the verification and validation and in the dialogue that's 8
gone on in the development of the guidance will evaporate 9
with time, and if you don't codify those thoughts and 10 understandings f airly early in the process, you may end up 11 with an enforcement document that is quite different than 12 the basis under which the guidelines were developed.
13 So, I would suggest that the sooner we move 14 ahead with a draft document, the better off we would be, 15 COMMISSIONER REMICK:
I certainly share those 16 Jr*
because I
think more than one
- occasion, the 17 implementation of a rule through the inspection process 18 was dif ferent than my interpretation of what the rule was, 19 so I agree with that.
20 I'm very pleased with the outcome of this 21 interaction on developing regulatory guidance.
I'm 22 personally not aware of any law of nature that says that 23 knowledge, wisdom, experience, or insight increases as one 24 gets closer to the Potomac, and I si:.ongly favor the 25 process carried out by a number of other regulatory bodies NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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in other areas of the world, in which thoso who.have the 2
expertise to contribute to. complex issues like the 3
development of this guidance, sit down around the table-4 and work it cu* an open forum, and I think that should 5
be done and not worry about what the trade prus, how they 6
might report it.
7 I perstenally know of no other agency in this 8
town that's more open than this agency, and I applaud that 9
openness and certainly want it to continue.
J' fact, I'm.
~
10 so much in favor of openness that I f avor that this i
11 maintenance rule in its present forum should have gone out 12 for public comment, which it did not. I think through that 13 we might have improved upon paragraphs (a)(1) and.'(a)(2) 14 so that they are more consistent with the way that=they 15 are being implemented.
But I'm very pleased ;with the 16 process that we went through.
I-think we should not put 17 it to rest.
I think there are other arees-whereJit can t.
18 work, and so I am, as I say, very pleased with= the 19 interaction between the staff and those who participated-20 in the development, and I hope that our staff ---and.I 21 realize they have resource limitations and-other 22-priorities -- but as soon as we possibly can work on the 23 insp_ection guidanco, I hope that we can.-
24 CHAIRMAN SELIN:
Thank you very - much, 25 Commissioner Remick.
Commissioner de Planque?
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COMMISSIONER de PLANQUE:
I have no further 2
questions.
3 CHAIRMAN SELIN:
Okay.
I have a couple of 4
comments to make.
First of all, obviously, I feel the 5
same way that Commissioner Remick does about the openness, 6
but what we are essentially inviting. people to do is to 7
comment on this rule as we see -- not to spend so much 8
time 'looking at the rule before we see the regulatory 9
guidance, but having the guidance in hand, we're inviting 10 the world to go back and take a look at the rule and-11 saying, having.the guidance worked out,-are there changes 12 that ought to be made in the rule..
13 The second is that I would like to point out 14 that we did issue the interim guidance for comment, which 15 is quite unusual in our case.
We felt obligad that since 16 the industry was-putting so much of a cooperative effort-17 into working on the regulatory guidance, that the interim-18 guidance -- you ought to have a chance and the world ought 19 to have a chance to take a look at the interim guidance-to 20 see if it was a step-in the right direction or the wrong.
21
. direction.
So, - this process..has led to a lot-of-22 communication at a lot of dif ferent levels in what I think 23 is an appropriate fashion.
24 Third is I'd-like to make just a.short comment 25-about the NPRDS in a generic sense.
I said before, NEAL R. GROSS COURT REPORTERS AND TRANSCR10ERS 1323 RHODE ISLAND AVENUE, N W.
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remember, performance is both industry performance and To 2
power plant performance, individual plant perf ormance.
3 the degree that there are industry statistics, these are 4
the a priori probabilities that go into the testing or the 5
evaluation of the individual plant.
There's a big 6
difference between having some plant statirties but no industry statistics, in which case that's your only basis, 7
8 and having industry statistics and say going in the 9
reliability is such-and-such, let's see what additional 10 information comes up. So, whether it's through the NPRDS, 11 which a lot of us are comfortable with, or some other 12
- device, effort has to go into getting industry-wide 13 statistics, not just rely on the plant statistics to 14 determine the best estimates of probabilities.
For a 15 small sample or unusual features, you'd be very hard put 16 to look at, I don't know, a containment failure, or 17 something like this, on a plant -- structural problems on 18 a plant basis, when these are very usual events.
19 So, once you consistently try to use industry-20 wide statistics in a statistically valid way to arrive at 21 the plant estimates.
22 Finally. ?'d just like to say this has been, by 23 all accounts, a very successful process, and it was not 24
- ordained, from what my colleagues tell me at the 25 beginning, that it wouldn't work out so well.
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that necause the process has been so-successful, it has 2
been essential that we make these admonitions to you about 3
not just casually extending the process to other areas 4
where the prerequisites of transfer -of technical 5
information and the ability to lay it all out on the table 6
may not follow.
It's really a compliment to what you've 7
done rather than a complaint about what you've done that's 8
led to these general comments. And in particular, from my 9
own experience with this process, I have to say that Mr.
10 McNeill's leadership has been invaluable, and we hope that -
11 it's volunteered for many future projects in an equal 12 fashion.
So, thank you.
13 MR. McNEILL:- If I might conclude with just a 14 personal observation, and maybe a suggestion, and I'm 15 speaking now for myself and my company possibly,-but not 16 NUMARC'or the industry.
I have been a strong believer ir.
17 what_I would call a revolution in the regulatory process 18 in this business, recognizing that that takes time and 19 takes testing and takes what I refer to as " baby steps" at 20 times, but I think I agree that some of the observations, 21 this has been, from my viewpoint, a very successful 22.
process.
It's been a successful test of a methodology 23 that might be utilized.as we move forward in~ the l
24 appropriate areas.
l-25 I-think we ought to be proud'and_ confident of f
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what we've done rather than too excusatory, if you want to 2
call it, of some of the dangers that are found here.
But 1
3 I would suggest possibly in order to solidify the public 4
confidence in this process,: that you undertake, or have
~
5 the staff undertake, a modest independent review of the 6
process that went through here, and have them start back-J l
7 with the day that the industry was offered the input in-8 this forum, and test it to see if there's a factual basis 9
that says that the public interest was protected, openness 10 and candor were part of the process, and build a history 11 of that based upon a separate review, that says -- that 12 documents the fact that this appear-to have worked, and 13 you can provide input from'the public on that-particular 14 process also as a basis for doing that.
15 CHAIRMAN SELIN:
Thank you very much,. Mr.
16
- McNeill, 17 Mr. Taylor?
18 (Whereupon, the first panel stepped back from 19 the table and the second panel came forward.)
20 CHAIRMAN SELIN:
Good morning, Mr Taylor.
We 21 welcome the views - of the staff on.this issue, both 22 historical and perspective, and turn the' floor over'to 23 you.
24 MR. TAYLOR: Good morning. With me at the table 25-are members of the NRC Steering Committee which
'I.
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?
-58 1
appointed,- and-the Working Group which we established for:
2 Timplementing the maintenance rule.
~
3 on my'right, Owen Rothberg and Bob Baer,_from 4
the. Office of Research; Jim Sniezek,. my Deputy; to my.
5 left, Bill Russell and Rich correia, from the Office of 6
Nuclear-Reactor Regulation.
7 The regulatory guidance for the maintenance rule 8
is scheduled to be. issued about-June 30th of this-year, 9
and the purpose of this meeting is to describe NRC staf f's E
10-efforts to develop that guidance as well-as the related 11 inspection procedures'and other.related activities.
12 Mr. Sniezek has headed the-Steering Committee, l
13 and he has-been working with the staff on the development 14 of this guidance, and will brief you on exactly where we 15 stand and what we've planned ahead.
Jim Sniezek.
16 MR..SNIEZEK:
Thank you,. Jim. -Can I:have-alide
~
17 2, please.
(Slide)
?
18 ThisLslide just highlights the topics:we'll be 19 covering during: the presentation.. today.
- I thinknit's L
-20 self-explanatory, s
21
-Slide 3.
(Slide)
- 22
- The' maintenance:was.' published as a-final rule ini 23
- July, 1991,. to be ef fective in. July of ?1996..
.The l.
24 Commission ~~ directed the staff to :have implementing l
~
l-l 25 guidance in place-within two years-of rule publication,f so
~
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that the industry would have aufficient time to make any 2
necessary changes in maintenance processes and practices 3
prior to the effective date of the rule.
4 Shortly thereaf ter, in August,
- 1991, NUMARC 5
proposed that the industry develop the guidance necessary 6
for consistent implementation of the rule.
The NRC staff 7
supported the industry initiative, but concurrently 8
initiated the development of a detailed regulatory guide 9
so that the staff could have a guidance in place to 10 endorse in the event that industry did not come through on 11 its effort.
12 slide 4, please.
(slide) 13 Therefore, in August,1991, a Steering Lummittee 14 composed of managers f rom Research, NRR, and the of fice of 15 the EDO was formed to interface with the senior managers 16 of NUMARC and industry regarding the key elements of 17 guidance which the staff deemed necessary for effective 18 implementation of the maintenance rule.
The Steering 19 Committee also provided appropriate guidance to the NRC 20 staf f who had the task of developing a regulatory guidance 21 for rule implementation.
A working group comprised of 22 appropriate staf f from Research, NRR and the Regions, was 23 tasked with developing the regulatory guidance in the f orm 24 of a detailed regulatory guide.
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of a detailed regulatory guide was terminated since it was 2
determined by the working group and the Steering Committee 3
that the progress of the industry developed guidance was 4
such that with a few changes it could be endorsed.by the -
5 NRC as an effective way of implementing the maintenance 6
rule.
7 You will note from the composition of the 8
working group, we even envisioned at that stage that the 9
implementation by the NRC would require regional input, so 10 we had regional people on the working group as well as 11 Research and the Office of Nuclear-Reactor Regulation.
12 It's important to note that in carrying out its 13 functions, the working group received support from various -
14 offices in the PRA, Trends and Patterns, and legal arenas.
s 15 The key support personnel are identified on the slide.
16 Slide 5, please.
(Slide) 17 The NRC Steering ' Committee had eight public 18 meetings with the industry steering committee between 19
- August,
'91, and June, 1992, and the working group ~had 20 nine public. meetings with the NUMARC. working group to 23 res'olve a number of issues regarding the industry guidance -
22:
documents, once it was decided that the industry developed 23 guidance document was consistent with the maintenance 24 rule.
[-
25 NUMARC, in July of 1992, released its. draf t l'
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61-1 guidance so that we could use it as an endorsement point-2 in our draft regulatory guide which went out for public 3
comment.
We went out for public comment in November of
~
4 1992, and the comment period closed on January 15th of 5
this year.
6 Slide 6, please.
(Slide) 7 As of. January 27th, we received comments from 8
nine organizations plus the Division of Engineering and 9
Research of the NRC.
A quick review of the comments 10 indicates there are no issues.not previously considered by 11 the-staff during the guidance development process.
We 12 still have to do, obviously, a more thorough review of the-13 comments that we have received.
In the event the staff 14 deems any changes to NUMARC guidance: are necessary, we 15 will so inform NUMARC.
16 Slide 7.
(Slide) 17 In addition to the Steering Committee meetings 18 and the workin_g group meetings, the NRC staff working 19 group attended as observers four NUMARC verification and 20 validation meetings between August and November,1992.. We 21 did that to learn first-hand the views of the industry 22 regarding the usefulness of the NUMARC guidance document 23 and to confirm the staff decision to endorse the industry 24 guidance document.
Until we completed that stage, we>
25 weren't positive that we would go through with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVENUE, N W.
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endorsement.
I believe that NUMARC described the insights 2
that came out of the V&V effort, and we won't-dwell on 3
them at this time.
4 We expect NUMARC to provide revised guidance in 5
the March time frame that we can use in going through 6
NRC's internal process of the CRGR and ACRS to enable us
- /
to promulgate the final regulatory guide.-
8 Slide 8, please.
(Slide) 9 Regarding proposed changes to the maintenance 10 rule --
11 CHAIRMAN SELIN:
Before you go on, Mr. Sniezek.
12 My memory of this process was not as smooth as that which 13 is depicted at this point.
It seems to me that there were 14 a couple of points-where the NUMARC approach and the staf f.
15 approach were quite divergent, and it took some hard work 16 to get them back.
17 MR. SNIEZEK:
Early on-in the process we had.
18 some very hard meetings, I will-call that.
In fact, we 19 were a little chagrined to see the-manner in which they 20 were portrayed in the press, but it was.very essential.--
21 CHAIRMAN SELIN:
Because they were so 22 inaccurate, or because they were_.so accurate?
23 MR. SNIEZEK:
Well, they were accurate --
I l
24 (Laughter.)
f 25 CHAIRMAN SELIN: You have to get used to the new NEAL R. GROSS l
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1 world --
therc's no 2
MR.
SNIEZEK:
I guess what 3
problem.
We were quite blunt with eacl other, and I'm a 4
believer in being blunt whether you're in a public meeting 5
or you're having an internal staf f discussion or what have 6
you because, if you're not blunt, you don't get the issues 7
on the table.
8 One of the issues that was discussed by the 9
Commission with NUMARC was this (a)(1) /(a)(2) concept. We 10 had a major problem understanding what the industry wanted 11 to do, at first.
And it boiled down very simply.
In our 12 mind, there is very little difference between (a)(1) and 13 (a)(2).
We finally recognized the f t.ndamental dif f erence 14 is not in what we're going to do in the maintenance area, 15 but it's the management attention that gets paid to the 16 issue.
17 In the (a)(2) process, there are performance 18 criteria which the components and systems and trains will 19 have to meet.
If they don't meet them, then it gets 20 kicked up to the (a)(1) process and senior management 21 starts focusing on it and it starts getting trended.
But 22 the fundao3ntal types of maintenance remains constant 23 whether you're in the (a)(1) or (a)(2) process.
We had 24 quite a few meetings ca that isaue.
25 Bill -- there are a couple other topics, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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that --
2 MR. RUSSELL:
There were other issues, whether 3
you needed to monitor for performance at the train level 4
rather than just the system level, what constituted a 5
eystem failure.
So, there were a number of disputes that 6
were quite candid
- and, basically, we got down to 7
describing the rationale for the positions that were 8
taking on each side, and what we would deem to be 9
acceptable and what we were concerned about was somehow or 10 other coming up with some words that would take the 11 substance out of what we were trying to achieve with the 12 maintenance rule.
13 MR. SNIEZEK: What really worked well is, we had 14 developed our regulatory guide how we read it, and we were 15 doing it how we would have done it.
In the meantime, the 16 industry developed the way they wanted to do it and, 17 obviously, they weren't in locked step, and we had to come 18 to an understanding of why the differences exist.
19 COMMISSIONER CURTISS:
Let me emphasize that 20 point because that was a key -- I don't know if it was a 21 tactical decision or what have you, but the decision, 22 perhaps driven by the schedule, to develop what the staff 23 believed to be an appropriate guidance document for the 24 implementation of this rule.
I know a lot of work went 25 into that by Owen and Bob and some other people, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RH00E ISLAND AVENUE. N W.
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considerable ef fwt to think through in careful detail 2
what the staff expected.
b 3
Itaving that out on the table and laying out the 4
expectations that you had in terms of the objectives in 5
the clear and unequivocal fashion that you did, in my 6
view, gi.ves this process an important perspective.
That 7
is to say, it was clear and up front and open right at the 8
outset, with the details, the prescriptive implementing 9
details subject to the back-and-forth, what it is that we 10 expected out of this process.
And ths observation that I 11 made when the industry representatives were here, that 12 there was a lot of give-and-take, but with respect to the 13 objectives, those were laid out in clear and equivocal 14 terms.
And that decision to put that guidance docunient 15 out, I thought, helped catalyze the process and focus the 16 thinking and was a useful step.
17 MR. SNIEZEK:
If I could digress just a moment 18 at this time, I had mentioned that it made the process 19 even more difficult to reach resolution because we had 20 sort of solidified our thoughts and, you know, once a 21 regulator solidifies their thoughts, it's very difficult 22 to get them to change.
But that did preserve their 23 original objectives, so there was no question that the 24 original objectives would be met. And that may be a thing 25 we want to consider in the future.
It's different than NEAL R. GROSS COURT REPORTERS AND TRANSCh.JERS 1323 RHODE ISLAND AVENUE, N.W.
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from starting from scratch and-sitting around a table and 2
just thinking about it from two dif ferent ' sides.
When you 3
both have your positions put down and then start knocking 4
heads, I think you get a better product overall.
5 Going on, changes to the maintenance rule.
6 Early in the guidance development effort, it became clear--
7 that the evaluation period should' be changed to every 8
refueling outage since the normal full maintenance cycle 9
is based refueling cycles.
A proposed. rule change is-10 being developed by the staff and should be ready to go out 11 for public comment by the time' the maintenance guidance is 12
-finalized in June of '93.
13 HR. TAYLOR:
This will go through our standard 14 process.
15 MR. SNIEZEKt. Standard process.
16 Slide 9, please.
-(Slide):
17 Related NRC ' activities.
There are several:
18 related NRC ' activities.
One is - license ' renewal.
The 19 staff is of the belief that-the licensee's implementation 20 of the maintenance rule c a n _- fulfill many-of the-21 requirements for an ef fective program to_ address age-22 related degradation ~ under' the license renewal rule.
This 23 will be suggested in the - discussion - section of the:
24 regulatory guide for the maintenance rule, and can be 25 detailed in. the regulatory guidance for the ' license-NEAL R. GROSS-COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W-(202) 234 4433 WASHINGTON, D C. 20005 (202) 234-4433
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renewal rule.
2 The staff's exact proposal remains to be fully 3
developed, and will be presented to the Commission in 4
March of this year when we discuss the license renewal 5
rule.
6 Diesel generator reliability.
.n June of '91, 7
the Commission gave staff direction to develop a rule 8
pertaining to diesel generator reliability.
A proposed 9
rule and reg guide was issued for public comment last 10 year.
Based on the comments and further staff review, we 11 believe that the industry guidance document for the 12 maintenance rule can be modified to use the diesel as a 13 specific example for treatment under the maintenance rule, 14 and this would eliminate the need for a separate rule and 15 reg guide on diesel generator reliability.
The example 16 would include both the reliability and availability 17 aspects of the diesel generator.
NUMARC is developing 18 guidance to put into their guidance document to use this 19 as an example, and we will be coming shortly to the 20 Commission with a paper and follow up with a direction to 21 issue a rule on the diesel generators, and provide some 22 options to the Commission of which one of the options will
(
23 be to use the maintenance rule and the example of the-24 diesel in the regulatory guidance as fulfillment of what 25 we need to have for the diesel generator.
That will be up NEAL R. GROSS 3
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1 68-1 in, what, the March time frame, I believe, it will be 2
before the Commission.
3 Could_I have slide 10, please.
(Slide) 4 CHAIRMAN SELIN:
Let me just say, that sounds.
5 sort of cute to me, I have to tell you that.
Please make 6
sure that when you look at this proposal, you take a look 7
at the implications and precedents for dealing with what 8
amounts to the rule change in the guidance document.
It's 9
not that we need a lot more rules, but somehow that has a 10 feeling of being a little bit too cute.
11 MR. PARLER:. We don't have any precedents that 12 say you can change a rule in a guidance document, that I'm 13 aware of.
If we do have them, I wouldn't follow them.
14 CHAIRhAN SELIN:
I'm sorry, it's not change a-15 rule, we don't have rules today, but it's a --
16 MR. SNIEZEK:
This would obviate the need for a 17 new rule.
18 MR. TAYLOR:
Could.
19 MR. SNIEZEK Could.
20 CHAIRMAN SELIN:
I did say it', I didn't say_.it 21 properly, but it's an area in which we've at least 22 considered that a rule was the appropriate vehicle, and if'_
23 we don't do it by rule but by guidance, let's make sure we:
~
24 carefully think out what are-the implications.
~
25 MR. SNIEZEK:
And it has to be based on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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69-1 public comment that we have received so far on this.
2 CHAIRMAN SELIN:
Okay.
3 MR. TAYLOR: i'a'll bring that to the Commission, 4
obviously.
I'm sure l' we do that, we have an agreement.
5 MR. SHIEZEK:
The NRC inspection procedures.
6 The NRC inspection procedures are to be developed by the 7
staff immediately af ter the regulatory guide issuance.
8 Since the regulatory guide is to be the basis for 9
inspection procedure acceptance -- this is very-important 10
-- we expect the procedures to be drafted by mid '94, and 11 to hold _public workshops and conduct staff training in i
12 that time frame.
13 It-is important to note at the-public workshops 14 we will specifically invite not only industry, but various -
15 public interest groups to participate in that workshop.
16 Shortly af ter we have the workshops and refine our 17 inspection procedures and ccnduct staff training, we will la be conducting pilot inspections.
We're shooting for the
~
i 19 late '94 time frame to con' duct our pilot inspections.
20 In our mind, it is very important that.a 21 consistent performance-based regulatory philocophy, as 22 espoused in the rule, be portrayed in thci guidance
.t 23 document, in the NRC inspection procedures, and regulatory 24 interpretations made by our' field inspectors.
We-believe-25 that the above process will help ensure the consistency as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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well as a common understanding by the licensee and the NRC 2
staff regarding expectations.
4 3
Slide 11, please.
.(Slide) 4 Schedule for completion of the regulatorj gu' 5
As I mentioned, public comment period has closed.
Public.
6 comments will be resolved by the end of March,
'93.
We 7
will be going through the ACRS and CRGR processes in April 8
and May, and-we expect to issueLthe regulatory guide in 9
final form by the end_of June,
'93.
10 CHAIRMAN SELIN:
How does the diesel issue fit 11 into this schedule?
12 MR, SNIEZEK:
It will be before the Commission 13-before then, so that it -- in the March time frame the 14 Commission will get the diesel issue to make a decision-15 on.
16 CHAIRMAN SELIN:
And there-will have - already 17 been suf ficient public comment that the Commission can act-18 on that then?
19 MR. SNIEZEK:
-We have already received public 20 comments. They've been examined, and they're forming part 21 of the basis'of our recommendation to.the Commission.
L 22 This concludes the staff's presentation.
s 23 CHAIRMAN'SELIN:- Commissioner. Rogers?
24 COMMISSIONER ROGERS: _ Yeah. Just on some of the.
25 comments that you received, could you:' indicate wh'at the NEAL R. GROSS COURT REPOR*_
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nature of the Division of Engineering Research comment 2
wan?
3 MR. SNIEZEK The Division of Engineering -- and 4
I'll paraphrase it; I just spent ten minutes looking at 5
it, so I haven't done u thorough analysis, and I'd ask 6
other people to chime in if they so desire -- is that, in 7
my mind, it was trying to change the maintenance guidance 8
document into an aging guidance document, change it more 9
into a license renewal guidance document, which also means 10 that we have a lot of work to dc with our staff yet, to 11 make sure they understand how this all ties together.
12 That was it, in my mind, in a nutshell, Commissioner.
Do 13 you have anything you want to add to that, Bill?
14 HR. RUSSELLt I would just add that the major 15 emphasis appeared to be on the Class I structures and some 16 of the components which we have not yet captured with rule 17 change, that we're looking at, related to tanks and other 18 components.
We're working on endorsing later versions of 19 the ASME code which would capture some, and there is some 20 experience with Class I structures.
But we have not, at 21 this point in time, concluded that they should be given 22 treatment within the scope of the maintenance rule.
23 COMMISSIONER ROGERS:
Uh-huh.
Okay.
Of the P
24 comments from the outside, there really seemed, at least 25 in the materials that we received, only two that were --
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seemed to be negative and how would you regard those two -
2
- the substance of those two negative approaches? One was 4
3 the Illinois Department of Safety and the other was from 4
Centerior Energy.
It seemed to me the Illinois Department 5
of Safety comments really
- related, really, almost 6
philosophical, and they related to a totally different 7
view of what regulation ought to be in this area, quite 8
contrary to the one that the Commission adopted, in which 9
we specifically took the position that a performance-based 10 rule was what we were looking for, and we really wanted to 11 emphasize the responsibility of the licensee to define --
12
.look very carefully and define those systems which really 13 needed maintenance activities, and to justify that 14 definition.
Whereas the Illinois Department of Safety 15 seemed to feel that unless the regulator made that 16 definition, that it wasn't going to result in an effective 17 maintenance program.
I wonder if you might comment from 18 your point of view on that.
19 MR. SNIEZEK:
Commissioner, I think you read it 20 just the same way I read it but, again, it was a very 21 quick look at it and we haven't really focused that hard 22 yet.
Owen, I think you 23 Bill, or anybody else 24 probably looked harder than anybody els-so far.
25 MR. ROTHBERG:
What they were outlining was a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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-7 3 -
1 prescriptive rule that
- was, well, rejected by the 2
Commission in '91.
A lot of those points, those specific
~
3 points that the Department of Illinois came up with, were -
4 right out of some of the background material for that 5
prescriptive rule.
6 COMMISSIONER ROGERS: The comments that you.made-7 a little bit earlier about the importance-of the staff-8 attempting to make its own guidance before you.had to 9
comment on the industry view of thie, to me, that's a very 10 important ptocess.
I agree with you totally that it gives 11 for a much better result.
I'm not sure that it has to be-12 contentious, necessarily, although I suppose there will be 13 some of that inevitable -- inevitably will creep in -- but 14 the staff sitting down and really trying to do the job 15 itself before commenting on somebody else's - efforts, I 16 think, is very salutary.
You have a much better feeling 17 about what you think the issues-are, and-I think that is 18 terribly _important.
19 How would you characterize the-important l
20 dif ferences, though, between-the staf f's approach and the 21 industry's approach here in developing;the guidance?
22 MR. SNIEZEK:
I think the-important-difference t
23 was they took it from an implementation standpoint and 24 what it meant to the plant staf f and the management of = the 25 plant and the time expenditure of_the various people in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1
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the plant staff, where we took'it more head-on with these 2
are the right things to do, you should have goals, you 3
should have training, et cetera.- They ended up doing the 4
same thing, but it really broke down to what level-of 5
management do they really want to focus in the plant,_on 6
the issues whereas under (a)(2), whether you're meeting i
7 your performance criteria in your maintenance program, may 8
be judged by the plant manager and the maintenance manager 9
and the operations manager under (a)(1), if you-find you 10 weren't meeting that and it gets kicked up to (a)(1), the 11 trending and the goal-setting to get back so you are 12 meeting your performance criteria, would be looked at by 13 the vice president--- VP, Nuclear -- at that level.
So, 14 it's more -- we saw it as a delineation of who is really 15 doing the job in the utility. - And that was hard for us to 16 get into at first, and we had a lot of discussion on that.-
17 COMMISSIONER ROGERS:
Yes.
Uh-huh.
I 'see.
18 Well, I think that's helpful to see that. Someplace-there 19 uas a reference to the concept of the appointment of an 20 expert panel to bring together PRA and the IPE results,.
21 and I wondered if you had any thought.of how such expert
~
22 panels might be set ' up, or - whether ~ there 's been any.
23 experience in trying to do that, particularly in this area 24 of prioritizing SSTCs -- and I notice we now have a "T"
in:
25 that collection that didn't used to be there.
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'l MR. SHIEZEK I'd ask Bill Russell if he would 2
address that, please.
3 MR. RUSSELL:
Well, the process -- in fact, my 4
looking at the proposed changes to how they define " risk l f-5 significance", I think what came out of V&V is, in fact,'
6 a step in the right direction.
It has both deterministic 7
processes that are -followed from the standpoint:-of 8
identifying importance of maintenance and maintenance 9
work, summing those up and then making judgments about how 10 much improvement you can get with maintenance as it 11 relates to reliability and availability, and -then 12 subjecting that to the individuals and the plant'_ staff 13 both that would have risk experience, maintenance:
14 experience, and operations-experience, to test that 15 because there are a lot of uncertainties in the process.
16 And, so, I would characterize it more combining 17 those two features rather than.using one or the other.-
18 And, in fact, the-methods that they've defined in their 10' comments appear to me to be a step in the right direction.
20 It's using. importance ' measures, whether you're using 21 importance measures for change in core damage or potential ~
22 improvement-in-risk as a result of maintenance assuming 23 maintenance was perfect, and how much improvement can you=
24 achieve.
So, the techniques seem to'be reasonably-well' 25 thought out, and the-process is one of then applying that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBEPS 1323 RHOOE ISLAND AVENUE. N W-
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to judgment and testing what comes out numerically to see 2
if it makes sense.
3 COMMISSIONER ROGERS:
But this panel you would 4
see as being composed entirely of people from the plant 5
itself --
6 MR. RUSSELL:
Yes.
7 COMMISSIONER ROGERS:
-- or the licensees --
8 MR. RUSSELL:
The way it's envisioned now is 9
that this would be done with licensee resources.
Whether 10 they brought consultants in or others to assist them with 11 the process would be up to them, but it would be a _ process 12 that would be executed by the licensee.
13 COMMISSIONER ROGERS:
Did you-have any comments 14 on the NUMARC definition of
" criteria" for the risk 15 reduction worth listed in 9.31.1?
16 MR. RUSSELL:- As'it relates to the comments we 17 received, we're still reviewing-those in detail.
What 18 I've given you is what I'd characterize as kind of?a top 19 level review.
We still need to go through those in some-20 detail.
We have received comments:from the-staff, and we 21 have not yet reviewed those internally with the steering 22-group.
Once we do that, we plan on having' a public-23 meeting with NUMARC to review'their-comments as well as 24 other comments we've received.
There are some areas that-25 we feel we may want to make some changes to the NUMARC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W, (202) 2344433 WASHINGTON. D.C. 20005 (202) 2344433 -
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1 guidanco, for staff reasons, and that process is ongoing.
2 COMMISSIONER ROGERS:
I see.
All right.
3 MR. RUSSELL:
So, rather than giving an answer 4
now, I'll give you the general feel, and that is we think 5
it's going in the right direction, and that it is an 6
improvement, but we don't have detailed comments on it at 7
this point.
8 COMMISSIONER ROGERS:
Wel) those are the only 9
detailed questions or comments I have, except that I think 10 that this -- I really want to echo some of the remarks 11 that Commissioner Curtiss made earlier, that this started 12 out a little bit rocky road, but it has, I think, proven 13 to be a very successful approach to dealing with issues and leadership 14 where the responsibility clearly 15 clearly has to be with the licensee.
We don't do 16 maintenance, they do maintenance.
And I think that while 17 it is a possibly delicate matter of to what extent we are 18 working hand-in-glove with the licensee in developing 19 those things, I think that the issue that must.be kept 20 very much in mind is that the more the licensee takes the rre acknowledging their 21 initiative, the more they a
22 responsibility and the less that accusation can be made 23 that they are only following what we told them to do, when 24 it's really their responsibility to carry out effective 25 maintenance.
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So, I think that to.mo the process has.been a 2
very salutary one, and one which, in fact, reinforces the i
3 serse of ownership of the plant by the licensee, which is 4-absolutely fundamental to long-term safe operation.
So, 5
I think that's something to be kept in mind when ' one 6
expresses some concern about how closely we're working 7
with the industry here.
We're forcing them to come 8
forward with a definition of what they really want to do 9
and how they want to do it, and that, it seems to me, is 10 absolutely fundamental to long-term safety.
11 MR.
SNIEEEK Commissioner, I think that's 12 exactly right, and I'd like to draw something as a 13 corollary to NRC.
The inspection procedures are our 14 responsibility to go through.
And I think it's very that 15 NRC staff defines what we're going to inspect.
-Now, 16 whether or not our acceptance criteria appears to - be:
17 acceptance with the guidance documents, I think that's -
18 where we need the feedback from the public and the 19
- industry, but what we inspect-
-is a-regulatory 20 responsibility.
I think when we develop our inspection 21 procedures, we have to keep that in mind on that side of-22 the coin as well.
23-COMMISSIONER ROGERS. I think that's a very good 24 point, to draw that distinction, yes.
Yes.
Well, I'd p
25 like very much to commend the staff for bringing this to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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1 this, I think,-very positive point in t.ie development of 2
the maintenance rule.
3 CHAIRMAN SELIN:
Any other comments?
4 Commissioner Curtiss?
5 COMMISSIONER CURTISS
.Let me just cummarize..
6 I don't have any questions except for a couple on the 7
schedule.
The one thing I do want to do is commend 8
everybody here at the table, as well as a couple of people 9
who are not here at the table, who have worked so long and o
10 hard on this product from July of 1991.
I know from 11 watching it closely and talking to you and meeting with 12 you about every other month in that period of time, that 13 your effort to bring this to the conclusion that it's at 14 now and, over the course of the next four or five months, 15 to move forward with the final reg guide and-..the 16 development of the response to the comments, has been s
17 truly, I think, commendable and - significant.
A lot of 18 long hours went in on this --= Tom Foley and Gary Mazuno, 19 who are not here at the table but in the room, senior-20
- management within the agency, Tom Murley and Eric Bechjord 21 who made this process work _ because it involved-the 22 devotion of people.from both NRR-and Research -- there are
]
l t
1 23 a lot.of people to be comme ~ led here, and I'.ve probably:
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l 24 missed some by picking the people that I've selected, but 25 Rich Correia, Bob Baer, and Owen Rothberg, I must say, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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I'll say so in this public fashion, have done a truly 2
creditable job here.
3 Just a couple of quick comments and questions.
t
- i 4
I'm pleased to see that you're on schedule to have the reg 5
guide finalized by Juas 30th of this year.
That's been a 6
point of particular intorest to me, and I have watched 7
with great interest as that schedule, which I keep in my 8
file on my desk, has continued towards that conclusion for 9
the reg guido. ' And I look forward with great interest to 10 the staf f's recommendations on the diesel generator rule, 11 B-56, which will come up, I guess, in March of this year, 12 together with your recommendations based upon what we've 13 done in this context on the license renewal initiative, 14 that I know NRR and others are working on carefully right' 15 now.
16 Two questions that I guess I ' d li;ke to ask.
17 Where do we stand on the OMB paperwork clearance package?
10-Has that gone to OMn?
19 MR. ROTHBERGt
.It went over to OMB on the 21st 20 of January.
21 COMMISSIONER CURTISS:
Do you anticipate,=or 22 have you heard --
23 HR.' ROTilDERG Sixty days.
24 COMMISSIONER CURTISS:
They have 60 days - to 25.
review that?
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1 MR. ROTilBERGt They have 60 days.
1 2
COMMISSIONER CURTISS Okay.
All right.
I 3
assume that process will go forward smoothly, but given 4
our experience with some of the other rulemaking packages, 5
if there are any difficulties that arise in that context, 6
I think it would be appropriate to raise those up to the 7
appropriate level to ensure that they get resolved and
(
B that doesn't become a critical path item.
9 The one-year rule change, I take it there are no 10 other changes in the rule that the staff will be 11 recommending, save for the change from the annual 12 evaluation to an-evaluation period that would comport with -
13 the fuel cycle?
14 MR. SHIEZEKt At this time, that's correct.
15 COMMISSIONER CURTISS:
Okay.
My own view on-16
- that, if that's the
- case, is that based upon - the 17 relatively focused nature of that issue -- in fact, it's in the interes't of-18 almost administrative in nature 19 making sure that the guidance and the rule change, that 20-particular
- one, the OMB clearance package and the 21 inspection guidance, which I'll turn to in:a minute, care 22
-in place as early as possible so that the licensees that 23 may wish to implement this rule before 1996 can do-so, I 24 would encourage you to move forward' as swif tly as possible -
25 with the' rule change to modify the one-year provision and,.
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if that can be done earlier than after the conclusion of 2
the reg guide and, in fact, if it can be dono consistent 3
with the EDO delegations, I think we ought to move forward l
4 an expeditiously as we can.
5 The inspection procedures, I noted that you've 1
6 targeted mid 1994 for the development of those inspection 7
procedures, and I
know because this is the first 8
performance-based rule, and because of the significant 9
interest in those inspection procedures as well as the 10 work that the staff has ongoing in other contexts, that 11 it's important to take the time necessary to do that 12 right.
And I share commissioner Rogers's comment, and I 13 think the comment, Mr. Sniezek, that you made, that that's 14 an instance where it would be useful for the staff to put 15 down first in its own document what.it believes ought to i
16 be the basis for inspection,-and because of some aspects 17 that are unique to the inspection arena, I would encourage 18' you in that context, as I have already for the industry 19 participants, to come up with an approach. that would 20 secure the lightest possible public participation, perhaps 21 even to the point of publishing the inspection guida'nce in 22 draft form prior to the workshop so that people can chew 23 over. that and have a good sense of what their concerns are 24 when they come to the workshop.
i l
25-At the same time, it seems to me that because of L
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the great interest in this aspect of the program and since 2
this will be a contral component, I
- think, of the 3
willingness of licensees to proceed with implementetion 4
prior to 1996, it would behoove us to try to get the 5
inspection guidance out as promptly as possible so that 6
they can "see the whites of our eyen, if you will, and a
7 get a sense of what the inspection guidance might look 8
like.
9 I know a yeoman ef fort has been devoted to this 10 task and has gotten us to this, what I think is, a very 11 successful point, and I trust that same kind of offort 12 will go into the inspection guidance.
And I'll commend 13 you in advance for the development of that.
Thank you.
14 MR.
St11EZEKt Commissioner, one point that 15 11UMARC raised, and that was the loss of continuity, and I 16 think, again, in the selection of the working group, wo 17 picked people who are involved, like Rich Correia is a 18 section chief in 11RR,
who is responsible from a
19 n:aintenance inspection procedure development.
So, the 20 thought process and things of that nature, we're going to 21 strive -- we will have the continuity -- we won't strive 22 to, we will have the continuity in that.
23 COMMISSIO11ER CURTISS:
Good.
24 MR.
RUSSELL:
Me've also committed in a
25 Commission paper that forwarded up the interim guidance, NEAL R. GROSS COURT REPOR1[RS AND TRANSCRIBERS 1323 RHDDE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON O C 20005 (202) 2344433
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that we would have public workshops.
In the last public 2
workshop we had, I committed to following a similar 3
process -- that is, we would notice the availability in 4
the Federal Register, we would make the documents publicly 5
available suf ficiently in advance, and we specifically 6
made of forts to invite others who may have views dif forent t
7 from the industry.
We then took the comments in that 8
workshop and then we made changes as we saw they were 9
appropriate, to the guidance, and then we informed the 10 Commission what changes we made and why, and forwarded it 11 up.
And I think that that process worked well, and it is
'f 12 a very important issue from the standpoint of performance-13 based inspection.
14 We have changed significantly, At that time, I 15 thought that we would be focusing on a
late - 1995 16 completion. I moved that up by about If; months, to try and l
17 get it in the middle of
'94, such that the guidance is 1
18 available and we can have the workshop. The one area that i
19 we need' to think out, and that is how soon we can-get into 20 pilot inspections and inspecting against a iule that's not 21 yet in-effect and how we treat that.
t<e do believe we.
22 need some experience with the guide,-and we need to work 23 on that activity, but our intent ~now-is to both move up
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'95.
2 COMHISSIOllER CURTISS:
Okay.
Very good.
4 3
CHAIRIMll SELIll Commissioner Remick?
4 COMMISSIOllER REMICK:
- First, a question on 5
clarification.
Jim, on slide 7, you need not refer to it, 6
but you indicatri that liUMARC is providing divine guidance
- l 7
based on i.f' af fort by early March, 1993.
Is that in 8
addition b 1h+l.r commsnts provided --
9 MR. SN.TEZEK It'n my understanding that would 10 be refinement to their comments.
They are still working 11 it, and we need something to go with the best we have, to 12 take to ACRS and CRGR.
So, that's why we need a March 13 document; otherwise, we could wait until June.
14 COMMISSIONER REMICK:
I see.
Okay.
I want to 15 accond the comments that commissioner Curtiss made on the 16 inspection guidance.
Hight I assume that your. pilot 17 inspections that will be under your process of managing 18 team inspections, managing, coordinating and so forth, 19 consistent with that guidance you provided us in the past.
20 MR. M SSELL:
Yes. That is'the intent.. We also 21 recognize that this would come to the Commission. probably 22 in draft form, no that you are aware of what we're going a
23 out to' meet on, and then we would conduct the meetings and 24 advise you as'to how we propose to change the guidance --
25 MR. SNIEZEK Commissioner, as another point, I NEAL R. GROSS COURT REPORTF.R$ AND TRANSCRIDER$
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would even envision that stage, since the industry will 2
know who they believe is the furthest along in 3
implementing the industry guidance on maintenance, that I 4
will even ask for volunteers for the pilot inspection to 5
go out.
6 COMMISSIONER REMICK:
Good.
Okay.
In the 7
interest of coherence and consistency of regulatory 8
activities, I personally like what you're thinking about 9
in the diesel generator area, and certainly encourage you 10 to consider along those lines.
That makes a lot of sense 11 to me.
I must a:mit diesel _ generators are a very 12 important system or components, and it's hard to imagine
]
13 why they should be handled separately, so I'm encouraged 14 by your current thinking on that.
15 And I would just briefly like to join in echoing 16 my commendation to the staff, too, for your ef fort in this
+
17 area.
It's highly commendable.
18 CIIAIRMAN SELIN:
Thank you.
Commissioner de 19 Planque?
20
' COMMISSIONER de PLANQUE:
I don't think I need 21 to add to those commendatione,, so let me.. just ask. a 22 question for my education, since-I wasn't here in the 23 beginning_of the process.
24 It's my understanding that in the. beginning:
~
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to what should como under the scope, not just (a)(.t.) and 2
(a)(2), but what should come under the scope in general.
3 lias this problem gone away? And,-if so, can you 4
tell me how that's been resolved?
5 MR. S!1IEZEK Let me say, it's gone away.
It's 6
been resolved.
I don't know if I can tell you how it's 7
been resolved, but it's been resolved.
Bill?
8 (Laughter.)
9 HR. TAYLOR:
Dill, why don't you --
10 MR.
RUSSELL:
Essentially, the way it was 11 resolved was that in the guidance they adopted language 12 which was identical to the rule as it relates to scope, 13 and the one area that there was some negotiation on was-14 the area of "could cause a reactor trip", which could be 15 a subjective all the way back to the mine mouth where you 16 mine the ore, you know.
So, clearly, there needed to be 17 rule of reason.
And what we agreed upon was essentially 10 "has caused a trip", either based upon industry experience 19 or based upon plant-specific experience.- So, that was the 20 one area where there was'some fuzziness,-and we reached 21 agreement on that -fairly o'arly on.-
.: And with - that 22 exception, I think that the scope is-as-defined in the-(
23 rule and as.the background 'and the statement - of 24 considerations described it.
25 HR. S!1IEZEK -
Well, there-was one other, and NEAL R GROSS-COUNT REPORTERS AND TRANSCR$ER$
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that was emergency operating procedures, also.
2 MR. RUSSELL:
Oh, yes, the --
3 HR. SNIEZEK We had a lot of discussion on that 4
one.
And the NUMARC guidance document, the latest 5
version, has gone, as I understand it, even further than 6
where the staff was pushing as a rule of reason.
7 HR. RUSSELL:
In fact, as Tom Tipton indicated 8
in his remarks, where things are included in emergency 9
procedures which are for equipment protection, that would 10 be excluded.
So, for example, if you had the lube and 11 lift pumps for the main turbine included because you 12 wanted to keep from destroying your main turbine, that i
13 really is there for economic protection and not needed for 14 safety considerationr..
15 COMMISSIONER de PLANQUE:
Okay.
So, you're not 16 expecting any problems in this area with implementation?
17 MR. RUSSELL:
No.
18-COMMISSIONER de PLANQUE:
Thank you.
19 CHAIRMAN SELIN:
Thank you.
Well, thank you 20 very much.
I think it's very important to come back and 21 concentrate on'this one point that -- with all respect, 22 you didn't say it right at the beginning, but you. did 23 later on -- the reason for the staff to start off is not L
24 just a-backup in case the UUMARC regulatory guidance was 25 uneven,:it was.to make sure we brought something to the NEAL R. GROSS
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1 table and that we had something we could continuo.
It's liegelian regulation.
You havo 2
what you might call a 3
thesis, and then you have conflict or antithonia, and thnn synthusia at the end of that, and that'n a 4
you got no ne 5
very important lennon. We can't just got lazy and turn it 6
over to nomebody and neo if they turn out something.
We 7
need to know what we think as well, in advanco.
C 8
So, thank you very much, folks.
9 (Whorrupon, at 11:54 a.m.,
the mooting was 10 adjourned.)
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f CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the United States Nuclear Regulatory Commission entitled:
DRIEFING ON IMPLEMENTING GUIDANCE FOR Tile TITLE OF MEETING:
MAINTENANCE RULE AND INDUSTRY VERIFICA-t i-TION AND VALIDATION EFFORT PLACE OF MEETING:
ROCKVILLE, MARYLAND i
DATE OF MEETING:
JANUARY 29, 1993 were transcribed by me. 1 further certify that said transcription is accurate and complete, to the best of my ability, and that the i
transcript is a true and accurate record of the foregoing events.
t R&Pt4 I
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g Reporter's name:
PilYLLIS YOUNG i
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.NEAL R. GROSS
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f COUtf hepceTORS' AND TRAM &CRIDOR$
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f
L IMPLEMENTING GUIDANCE FOR THE MAINTENANCE RULE,-10 CFR 50.65,
" MONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS" PRESENTATION TO THE NUCLEAR REGULATORY COMISSION l
JANUARY 29, 1993 O
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i CONTENTS BACKGROUND STAFF ORGANIZATION SUMMRY OF PUBLIC C094(ENTS NRC STAFF OBSERVATIONS OF THE INDUSTRY VERIFICATION AND VALIDATION (V&V) EFFORT PROPOSED CHANGE TO MAINTENANCE RULE RELATED NRC ACTIVITIES NRC INSPECTION-PROCEDURES SCHEDULE FOR COMPLETION'0F REGULATORY. GUIDE I
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BACKGROUND f
RULE PUBLISHED 7/10/91.
(EFFECTIVE 7/10/96)
INDUSTRY /NUMARC PROPOSED-TO PROVIDE IMPLEMENTATION GUIDANCE FOR THE RULE 8/91.
NRC STAFF FORMED STEERING GROUP AND WORKING l
GROUP 8/91.
1 REGULATORY GUIDANCE TARGET ISSUE DATE IS.
L l
6/30/93.
L
't I
- i
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NRC STAFF STEERING C0ltiUIEE JAMES H. SHIEZEK, DEDR WILLIv4 T. RUSSELL, NRR CLEMENS J. HELTEMEs, JR.,RES ROBERT l. BAER, RES HRC STAFF WORKING GROUR RIcHARo P. CORREIA, NRR MARK RING, REGION III OWEN 0. ROTHBERG, RES THOMAS F. STETKA, REGION IV STAFF SUPPORT TO THE WORKING GROUP CARL E. JOHNSON, JR.,RES PATRICK D. O'REILLY,AEDD THOMAS FOLEY, NRR CHARLES D. PETRONE, NRR GEARY S. HIZuMO, OGC
- I
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EIGHT PUBLIC MEETINGS BETWEEN NRC AND
- INDUSTRY, 8/91 T0 6/92.
NINE PUBLIC MEETINGS BETWEEN NRC AND NUMARC, 6/92 & 7/92.
SECY-92-229 0F JUNE 25,1992 INFORMED COMISSION OF PROGRESS AND STAFF'S INTENT TO ENDORSE THE INDUSTRY-GUIDANCE.
SRM OF 7/17/92 AFFIRMED STAFF'S INTENT.
NUMARC 93-01, REV. 2A, RELEASED BY NUMARC ON JULY 10, 1992.
DRAFT REGULATORY GUIDE OFFERED FOR PUBLIC COMENT (FRN.11/24/92).
COMENT PERIOD CLOSED 1/15/93.
.t
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SUMMARY
OF PUBLIC COMMENTS TEN SETS OF COMMENTS AS OF 1/27/93:
t STATE OF ILLINOIS YANKEE ATOMIC WESTINGHOUSE j
ENTERGY NUMARC NORTHEAST UTILITIES TVA CENTERIOR EWERGY-(TOLEDO EDISON).
ARIZONA PUBLIC P6WER RES/DE u
h-INITIAL REVIEW STARTED.
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- THE IlDUSTRY HFS 'IAFF OASIRYATIONS_0 VERIFICAT10H_AND VA.IDATIOD_
(V&V) EFF_0RI NRC STAFF WORKING GROUP ATTENDED FOUR NUMARC V&V MEETINGS 8/92-11/92.
i INDUSTRY APPLIED-NUMARC GUIDANCE TO ACTUAL i
l PLANTS.
l INSIGHTS GAINED ON 1. NUMBER OF TOPICS SUCH AS SCOPE, PLANT--DATA BASES FOR i
SYSTEMS / TRAINS, USE OF PROBABILISTIC. RISK ASSESSMENT, AND CONSIDERATION OF EQUIPMENT TAKEN OUT OF SERVICE.
NUMARC PROVIDING REVISED GUIDANCE BASED ON i
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V&V EFFORT BY EARLY MARCH 1993.
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I PROPOSED CHANGE TO MAINTENANCE RULE 650.65(A) (3)
" PERFORMANCE AND CONDITION HONITORINGAbTIVITIESANDASSOCIATEDGOALS AND PREVENTIVE MAINTENANCE ACTIVITIES SHOULD BE EVALUATED AT LEAST ANNUALLY..."
INTERVAL SHOULD BE CHANGED TO EVERY REFUELING OUTAGE BUT NOT TO EXCEED TWO YEARS.
A PROPOSED RULE CHANGE IS BEING INITIATED.
PROPOSED RULE CHANGE TO BE ISSUED BY 6/30/93.
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t
t RELATED NRC ACIIVITIES LICENSE RENEWAL (654):
TO BE COVERED BY SEPARATE BRIEFING,.
3/93.
DIESEL GENERATOR RELIABILITY (650.63),
RESOLUTION OF GENERIC ISSUE B-56:
COMISSION PAPER IN PREPARATION TO OUTLINE AND RECOMEND OPTIONS.
INDUSTRY GUIDANCE DOCUMENT OR REGULATORY GUIDE FOR THE MAINTENANCE D
RULE COULD BE N0DIFIED TO PROVIDE GUIDANCE TO LICENSEES FOR SURVEILLANCE OF DIESEL GENERATORS, AS AN ALTERNATIVE TO RULEMAKING.
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I HRC INSPECTION PROCEDERES TO BE DEVELOPED AFTER REGULATORY GUIDE ISSUED.
REGULATORY GUIDE TO BE BASIS FOR INSPECTION PROCEDURE ACCEPTANCE.
PUBLIC WORKSHOPS.
PILOT INSPECTIONS.
4
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SCHEDU_E 0R COMELEIID1_DI R EGU ATO tY GUIDE PUBLIC COMENT PERIOD CLOSED 1/15/93.
PUBLIC COMENTS RESOLVED 3/93.
ACRS AND CRGR PRESENTATIONS 4/93-5/93.
j REGut.ATORY GUIDE TO BE ISSUED 6/30/93.
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l January 29,1993 INTRODUCTION Good morning, Chairman Selin and Commissioners.
I'm Corbin hicNeill. I am President and Chief Operating Officer of Philadelphia Electric Company and am responsible for the direction and management of the Limerick and Peach Bottom nuclear generating stations.
With me at the table this morning is Tom Tipton, Vice President of NUhiARC's Operations, hinnagement and Support Services DMsion responsible for issues such as hiaintenance Rule implementation, the area of this morning's discussions. Also with us are Warren llall, hianager, Walt Smith, Dan Rains and Jim Eaton, Senior Project hianagers within NUhiARC responsible for the development of the industry's maintenance guideline and the verification and validation program. Joe Colvin, the President and Chief Executive Officer of NUhiARC, who would normally attend with us, is on travel and sends his apologies for not being able to be here today, As a member of the NUbiARC Executive Committee and Board of Directors,I participate with other industry executives in the formulation of industry policy of generic application to the nuclear industry.
Throughout my naval and civilian career, I have had a particularly strong association with the issue of maintenance at nuclear generating plants. Currently, I am the Chairman of the NUhiARC hiaintenance Working Group that consists of senior executives responsible for generation of electricity through nuclear power at 43 power plant units. The names and affiliation of the Working Group participants are included as an attachment to my prepared remarks. The working group provides oversight and guidance to the NUhiARC process for the development of industry guidance for hiaintenance Rule implementation at a senior management level. Additionally, Tom Tipton, Joe CoMn, and I serve as the industry interface with senior NRC management to assure industry policy matters associated with the development of industry guidance to implement the hiaintenance Rule are appropriately addressed.
We appreciate this opportunity to discuss with you the results of development of industry guidance to implement the maintenance rule in a reasonable and cost effective manner. It is a challenge to develop a process that provides the necessary balance between flexibility and specificity, and that promotes consistency for both the industry.
and the NRC.
In addition, the industry expended significant effort in developing the industry guideline. Four separate Ad Hoc Advisory Committees were formed that involved 1-
i representatives from thirty three utilities responsible for cperating seventy five peri our plants. The expertise assembled included, for example, individuals knowledgea probabilistic risk assessment, reliability centered maintenance, codes and stand:
the nuclear plant reliability data system. Maintenance managers and senior resctor operators were also key participants. Additionally, we had very active involvement representatives from EPRI,INPO, and NUMARC. Countless hours were spent on firs understanding the intent of the rule and then developing the necessary guidance.
Following its development and detailed industry review, the guidance was subjected to very detailed verification and validation process. Without a doubt, we brought our extensive experience and knowledge in maintenance to bear on the issue at all levels within our industry.
A major element of that process has yet to be developed - the NRC's inspection module. I will speak to the importance of this key element in just a few minutes.
We plan to address briefly three areas. They are:
The process established to address the implementation of the maintenance rule; Results to date of the industry verification and validation program; and Where we go from here.
1 Tom Tipton will discuss the results to date of the industry verification and validation program.
THE PROCESS We have found the cooperative process established for proceeding with implementation of the final maintenance rule a unique one that has achieved m we anticipated, it can and should serve as a model for addressing future complex iss I commend you for promoting this methodology and your staff for professional exec There are,I believe, five critical factors that helped make it work. They are:
Involvement of the NRC's upper management, including the Commissioners, from the beginning. This included you or your technical assistants' participation in publicly held meetings and, we understand, periodic briefings with your staff to stay abreast of the progress being made.-
Participation by your senior staff to address the policy issues that were identified during the development of the guidance followed by the industry 2-
+-
sy-h
+
as-p-
ay.'
y-y--+-
and the staff each working independently and sharing the results of each other's efforts in a public setting to develop the details necessary for policy implementation. We have had several very productive meetings with the NRC Steering Committee chaired by Jim Snlezek. The process worked well.
Staff development of the NRC's draft regulatory guidance rather than by a contractor. This was a very refreshing experience for us in that the staff knew the basis for the draft guidance being developed. As a result, dialogue was clear and meaningful and the conildence level was high and, most important, decision making was prompt and decisive. In the popular parlance of management gurus today, cycle time was short. This is a very important aspect of the process that should be introduced in other areas where possible.
Staff observation of the industry's execution of the verification and validation process, in the beginning, there seemed to be skepticism on the part of some of the staff of how serious we were in really testing the draft industry guidance that had been developed. IIaving observed the depth and detail each utility had gone through, that skepticism has been dispelled. ' Itis builds trust and understanding that is important to the continued existence of our industry. There is the recognition that we have mutual objectives to provide reasonable assurance of public health and safety.
The candor with which the industry and the NRC expressed their views, bringing their own different perspectives up front and on the table, if concerns are not clearly stated during the process, it can adversely affect, and in some cases, destroy the process. Our respective positions and concerns must be made clear to everyone. For example, we stressed that the implementation of the maintenance rule should not require two maintenance programs - one to provide the necessary maintenance to safely and reliably operate the plant and another to comply with the maintenance rule. Some of this candor made front page news in some of-the trade press coverage. That is the price of candor and openness that, if kept in the proper perspective and r.ot allowed to drive the process, is an appropriate price to pay.
As 1 am sure you would agree, these five key elements that resulted from our efforts in developing the industry guidance are not unique to the maintenance rule but can be applied when addressing other issues. I encourage us both to use these lessons learned in the future as we proceed with the initiatives discussed in detail with you last week by Gene McGrath and other members of the NUMARC Executive Committee.
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Tom will now brief you on the results of the verification and validation program.
EliE13!1S OF Tile _YlHlH1CN110N AND VAllDAllON PI(OGitAM Thanks, Corbin. There were nine plants involved in the verification and validation program. The plants that participated are included as an attachment to my prepared remarks. All four nuclear steam supply system vendor types were represented in the program. Over the last four months there has been intense involvement by each of these utilities; the purpose was to determine if it is clear how the industry's maintenance guideline works or if additional clarification is needed. This detailed verification and validation process exercised all elements of the industry's guideline.
There were seven objectives in developing the verification and validation (V&V) program. The objectives and the results to date are as follows:
1.
Test the ability of utilities to understand and use the industry guideline to implement the maintenance rule.
The participants in the V&V program concluded that the guidance can be implemented as written. Honver, it was noted that some clarifications of the guidance would be beneficial to the tuer.
2.
Determine the extent to which non safety related structures, systems and components (SSCs) that are used in the emergency operating procedures should be excluded.
The V&V utility panicipants generally concluded that most of the non. safety related SSCs in the emergency operating procedures should be included. &ceptioru were identified during the process. For example, there are some systems included in the emergency operating procedures to protect key systems such as the turbine that have only economic benefit and do not contnbute to accident mitigation.
3.
Identify and evaluate the use of PRA and other methodologies for use in identifying risk significant and plant level performance criteria.
it was concluded, as a result of the V&V process, that Plbts used in conjunction with ezpert panels identify the risk significant SSC3 effectively. PIG 1 or expert panels tued alone have limitations that are overcome by their tue in combination.
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1 Vetify that the use of the guideline will result in similar, but not necessarily 4,
identical, results among utilities.
The V&V utility panicipants concluded that snany differences in results are attributable to actual configuration differences and not to guidance ambiguities. Tids is a key eternent of the V&V findings in that it has to be recognized when an individual utility is inspected, care rnust be taken in attempting any cornparison between ostensibly similar units because of their different configurations. There may be differenca in the system (s) selected as well as the perfonnance criteria atablished.
However, based on the fimiings of the V&V there were good Justifications for these differenca.
Identify lessons learned that facilitate the rule implementation among all utilities.
5.
The implementation of the mle will affect utilities differently due to the different approaches that went into developing the individual maintenance prograrns and the state of implementation. This includes the utilities'in house capability, existing software and data bases, as well as individual utility objectives and approaches for implementation. Key differences among some V&Vpanicipants were due to system / train bounding and the data bases that cunently focus on component data collection rather than system or smin data. Some utility perfonnance rnonitoring, cause detennination and corrective action may need to be expanded.
Identify the cost to implement the rule using care not to understate estimated 6.
implementation cost.
The preliminary average non recuning initial cost in labor hours was approximately 16,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> that's about 8 person years per plant. The average armual recuning cost was estimated to be approximately 5,800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> peryear about 3 person years per plant. We plan to provide information to the industry on the anticipated resource needs and how to efficiently and effectively focus them.
7.
Determine if implementing the rule by use of this_ guideline results in benefits to -
the industry, especially in regulatory areas, it is clear as a result of the V&Vprogram that some utilitics will benefit from implememing the maintenance rule and updating 5
individual maintenance programs. However, it is also recogni:ed that some utilities will e.rpend resources to implement the mie with no significant benefit to their maintenance activities because of the effectiveness of the programs that they hm'e previously established.
As we have discussed with the staff before, there may be changes to the regulations that should be made as a result of the final maintenance V&V program. For example, during the V&V program the utilities collected and provided us with a large amount of data associated with containment leak rate testing (the requirements of Appendix J to 10 CFR 50). It was noted as a result of the review of this test data that a large majority of the penetrations and valves that are required to be tested do not fail.
As discussed in our December 21 letter to Chairman Selin, the NRC was encouraged to evaluate Appendix J in light of the performance criteria and pursue t.pptopriate regulatory modifications.
Tile FUTURE The next question that we must address is where do we go from here? In addition to our efforts to develop and verify the industry guideline, we responded to the NRC's Federal Register notice requesting comments on your draft regulatory guide. In our response we described changes to the industry's guideline that we are considering based on the results of the V&V program as well as comments from the industry. The next step, from our point of view,is to review with the staff the comments received on the industry's guidelines as well as changes we are considering incorporating by March and finalize it by June of this year.
Following finalization of the industry guideline, NUMARC plans *
.J two 3-day workshops in July and August to cover in detail the results of the V&V program, changes made to the industry guideline, and provide a detailed discussion of how to implement the guideline effectively and efficiently.
We anxiously await the development of the NRC's inspection module associated with this regulation. I must stress that a major concern of our industry continues to be how our facilities will be inspected against a performance-based regulation. During the public comment period of the draft regulations, NUMARC spent many hours with individual utilities dia.ussing individual utility concerns regarding the potential that the scope of the rule could be unnecessarily expanded or utility implementation inappropriately compared. It is clear as a result of the V&V program that the NRC should not compare one plant to another during inspections but evaluate the plant based on its actual performance taking into account its individual design characteristics and the effectiveness of its maintenance programs. We have received assurances since the start of this cooperative process that the industry would have meaningful input in a public i. - - -
forum into the review of the Inspection Module. We are prepared to do so and look forward with keen interest to similar interactions.
. CONCLUSION In conclusion, I would like to stress two key points as we go forward in this process. It is imperative that the Commissioners continue to be involved in the process through the final development of the industry guideline, th : NRCs inspection module and the associated training required to fully implement this first " performance based" rule. It is also ver; important that wc continue interacting during the three years remaining prior to full implementation in July 1996, as issues come to NUMARCs attention, to resolve them in a satisfactory and timely manner. We need to continue to have candid and well thought out discussions during the three-year implementation period. We look forward to continuing our discussions with the staff and the upper management of the NRC as we ;m forward. Thank you very much, and we would be pleased to answer any questions you might have.
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- 4 VERIFICATION AND VALIDATION PROGRAM -
Callaway M; 1125 MW; C.O. 4/85 Connecticut Yankee M; 565 MW; C.O.1/68 Comanche Peak M; 1150 MW: C.O. 8/90 4
Calvert Cliffs CE; 825 MW; C.O. 5/75 Arkansas 2 CE; 858 MW; C.O. 3/80 Crystal River si&W; 821 MW; C.O. 3/77 u
Arkansas 1 B&W 836 MW; C,0.12/74_
Grand Gulf GE; 1142 MW; C.O. 7/85 Fermi GE; 1075 MW; C.O.1/85 C.O. = Commercial Operation w
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NUMARC MAINTENANCE WORKING GROUP CHAIRMAN:
President & COO Corbin J. McNeill, Jr.
Philadelphia Electric Co.
Senior Vice President, Nuclear Pat M. Beard, Jr.
Florida Power Corporation Vice President Louis O. Del George Nuclear Engineering & Construction Commonwealth Edison Company Director, Plant Support Division Donald L Gillispie Institute of Nuclear Power Operations Vice President, Nuclear Services E. Wayne Harrell Virginia Power Company Director, Engineering & Operations James F. Lang Electric Power Research Institute President & CEO Charles W. Pryor, Jr.
B&W Nuclear Technologies, Inc.
Senior Vice President Harold B. Ray Southern California Edison Company F. T. Rhodes Vice President Nuclear Engineering & Construction Wolf Creek Nuclear Operating Corp.
Vice President, Nuclear Operations Wayne D. Romberg Northeast Utilities Services Company Vice President Stephen L Rosen Nuclear Engineering & Construction Houston Lighting & Power Company Donald F. Schnell Senior Vice President, Nuclear Union Electric Company Robert E. Smith Senior Vice President Production & Engineering Rochester Gas & Electric Company
W. G. Smith Chief Nuclear Engineer American Electric Power Service Co. -
Senior Vice President, Nuclear Power Clark R. Steinhardt Wisconsin Public Service Corporation -
Vice President, Catawba Mike Tuckman Duke Power Company l.
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