ML20136A934
| ML20136A934 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8511200082 | |
| Download: ML20136A934 (100) | |
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Date: Wednesday, November 6, 1985 Pages:
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This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on a
11/6/85 in the Commission's office at 1717 H St reet,
9 N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
e 13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcEipt g
17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.
22 23 24 25
1 1
UNITED STATES OF AMERICA 2'
NUCLEAR REGULATORY COMMISSION
'3 uwm 4
BRIEFING ON NUMARC INITIATIVES 5
xxx 6
[PUBLIC MEETING 3 7
8 Nuolear Regulatory Commission 9
Room 1130 10 1717 H Street, Northwest 11 Washington, D.C.
12 13 Wednesday, November 6,
1985 14 16 The Commission met in open session, pursuant to 16 notice, at 9:37 a.m.,
the Honorable NUNZIO J.
PALLADINO, 17 Chairman of the Commission, presiding.
18 COMMISSIONERS PRESENT:
19 NUNZIO J.
PALLADINO, Chairman of the Commission 20 THOMAS M.
ROBERTS, Member of the Commission l
21 JAMES X.-ASSELSTINE, Member of the Commission 22 FREDERICK M.
BERNTHAL, Member of the Commission 23 LANDO W.
- ZECH, JR.,
Member of the Commission 24 25
r, 2
<0.
1 OTAFF AND PMESENTEMO SEATED AT COMMIOSION TABLE:
2 S.
CHILK 31 M,
MALSCH 4
J.
MILLEM 3
W.
OWEN 6
C.
WOODY
?
AUDIENCE SPEAKERS:
8 J.
OPEKA 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
1 3
1 PR OC EED I NG S l
l 2
CHAIRMAN PALLADINO:
Good morning, ladies and 3
gentlemen.
We are pleased to have with us this morning 4
representatives from the Nuclear Utilities Management and e
5 Human Resources Committee known as NUMARC.
We last met with 6
NUMARC on March 20th of this year.
7 Since its inception about a year and-a-halt ago, 8
NUMARC has been developing important non-hardware programs 9
relating to management and human resources.
The NRC has been 10 very interested in these programs.
And the NRC Statt has had l ' 'r 11 many discussions with NUMARC to determine the extent to which 12 NUMARC and NRC programs can be dovetailed.
13 NUMARC has provided important input on a number of 14 recent Commission etterts that have been finalised.
Examples 15 include training accreditation and expertise on shift or currently NUMARC is involved 16 policies.
Clearly NUMARC 17 in developing programs on titness for duty, maintenance, and to has recently expressed an interest in becoming involved for 19 the first time in technical hardware issues such as station 20 blackout.
21 The NUMARC proposed agenda for today*s meeting is 22 available in the rear of the room.
They will briet us on the 23 tollowing initiatives, I believe.
Fitness for duty, 24 engineering expertise on shift, maintenance, and initiatives 25 in technical hardware areas.
4 1
I noto that at cur last mooting NUMARC spocitioclly 2
indicated that it would' work with Statt to address the 3
question of check operators.
The Commission was interested in 4
whether such a concept was considered a good idea or whether 5
NUMARC might propose alternative thoughts which would 6
tacilitate enhanced operator performance.
It possible, we 7
would appreciate hearing where NUMARC stands on this ettort.
8 At the completion of t o d a y *'s meeting we should 9
discuss tuture NUMARC/NRC interactions.
I understand Regions 10 II and IV are listening in on the telephone.
I should also 11 point out, I must leave pretty promptly at 11: 00.
12 Before turning the meeting over to NUMARC 13 representatives, do any of my tellow Commissioners have other 14 opening remarks?
15
[ Chorus of n o s. 'J 16 CHAIRMAN PALLADINO:
All right, thank you.
Then let 17 me turn the meeting over to Mr. Miller.
16 MR. MILLER:
Thank you very much, Mr. Chairman.
19 Thank you for allowing us to appear before you today.
20 I am J.H.
- Miller, Jr.,
president of Georgia Power 21 Company and chairman of the NUMARC steering committee.
With 22 me today are Warren Owen, executive vice president of Duke 23 Power Company and vice chairman of the NUMARC steering 24 committee.
And C.O.
Woody, vice president nuclear ops at 25 Florida Power & Light and chairman of the NUMARC working group
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2 And we have some other NUMARC members and 3
representatives with us, and I would ask them to stand, it 4
they would please.
5 Thank you very much.
6 COMMISSIONER BERNTHAL:
You always have an 7
impressive roll call when you join us.
8
[ Laughter.3 9
MR. MILLER:
They come willingly, sir.
10 Chaughter.)
in today*s 11 MR. MILLER:
In today*s presentation 12 presentation I will review NUMARC*s activities since our last 13 briefing on March 20th.
Warren Owen will discuss the status 14 of all of the industry commitments we've made to you through 15 NUMARC.
And C.O.
Woody will then discuss NUMARC activities in 16 the area of maintenance.
And finally, I will discuss the 17 recent NUMARC initiative for technical and hardware related 18 issues.
19 Many of the issues that we will discuss relate to 20 various aspects of INFO programs.
In this regard INFO 21 president Zack Pate would normally be here today to answer 22 any questions on INFO managed programs.
Previous commitments 23 preclude Mr. Pate*s attendance however, but I understand that 24 he is supposed to briet this Commission on INPO programs on 25 December the 11th.
6 1
New you know that wo*vo involvod nucloor utility 2
managers and executives will hundreds of man-years of 3
experience in nuclear operation and management in our review 4
of management and people related issues.
Based on these 5
reviews we've developed positions with industry-wide support, 6
and have initiated actions to help strengthen our operations.
?
We*ve undertaken this because we believe that our 6
industry must pursue excellence in these areas to ensure high 9
levels of plant safety and reliability, and because we believe 10 that several regulatory actions in the areas identified by 11 NUMARC are fundamentally unnecessary and will result in lower 12 levels of safety and reliability than it the industry 13 aggressively takes the lead.
the 14 The NRC and industry have a common purpose 15 safe operation of nuclear power plants.
We fully support the 16 NRC*s mandate to protect the public health and safety, 17 However, in some instances we feel the industry and the NRC do 18 not need additional regulations to accomplish this.
in fact we support the purpose 19 We do not oppose 20 of most NRC regulations.
The industry and NUMARC fully 21 recognize the need for a strong and ettective regulator.
22 However, we believe the NRC needs to work closely with us with 23 more understanding and give appropriate recognition to our 24 initiatives.
With your aggressive support we can increase our 25 strength and move on toward our goals of excellence.
=
7 1
New wo bogen in March of 1984 and we've modo semo 2
progress.
We have obtained the support of all $$ utilities in 3
this country.
And it*s not just marginal or nominal support.
4 All 55 utilities have designated senior executives as members 5
of the executive group and made a manager or executive 6
available to serve on one or more working groups.
These 7
senior executives are involved in nuclear matters on a daily 4
basis, and can commit their utility to take action.
9 We have had excellent representation at all 10 executive group meetings.
At the last two meetings 53 of the 11
$$ utilities were in attendance.
All $$ examined and voted on 12 the proposed positions that we have discussed with you and 13 your Statt To date, at least 51 of the 55 utilities have 14 endorsed each of the positions that we have presented to you.
15 And 100 percent have endorsed most ci the positions.
i 16 As you know, we require an endorsement of 80 percent 80 17 before accepting that as a utility or industry position t
18 percent or more.
And you*ve seen the group here today, it's 19 pretty substantial 20 Our steering committee and working groups have been more than a year now.
And they prioritised 21 at work over a 22 a large number of issues, and we*ve developed some action 23 plans which are or will be made available to you today.
Our one of the purposes we had today is to briet you on 24 purpose 25 each of those commitments.
6
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8 1.
After our discussion on March tho 20th, wo 2
established a working group to address the area of security.
9 3
That working group chairman is Bruce Kenyon.
He's senior vice 4
president of Pennsylvania Power & Light.
It has completed 5
that group has completed its interactions on access 6
authorisation with the NRO Statt, Bob Burnette, director at 7
the safeguards division.
8 These interactions resulted in an industry guideline 9
for establishing programs on access authorisation.
I am told 10 your Statt acknowledges the guidelines as an acceptable 11 alternative to the proposed rulemaking in this area.
And that 12 guideline was forwarded to Bill Dircks on September the 5th.
13 This working group moved forward and reached agreement with 14 the NMC Statt bringing together the expertise of the industry 15 and the Statt.
We request that you consider this guideline i
i 16 carefully when deciding the outcome of this issue.
17 We also have formed a working group to look at the 18 operator requal issue.
The chairman of this working group is l
l 19 Jorin Grittin, senior vice president, energy supply at Arkansas 20 Power & Light.
Their NRC point of contact has been changed 1
21 recently and is now Bill Hussell, director of human tactors 22 safety division.
The working group has held two meetings and 23 has interfaced with NHC representatives on several occasions.
24 We expect the working group and your Statt to 25 complete the identittoation of problems in operator requal,
9 e
1 including concidoration of a chock pilot possibility, and to 2
recommend possible solutions for consideration in due course 3
after they complete meeting with your Statt.
4 Furthermore, Phil Clark who's president of GPU Nuclear is heading a working group looking at issues related 6
to potential wrongdoing that could attect the public healtn 7
and safety.
We're }ust in the early stages of looking into 8
this issue, including discussion with your Statt, and we'll 9
report to you more at later briefings.
10 The latest meeting of the NUMARC executive group was
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11 August the 28th, and at that meeting we endorsed a NUMARC 12 initiative in the technical hardware related area on selected 13 issues, and I'll discuss that later.
14 Now I'm going to introduce Warren -- Warren Owen, 15 executive vice president, engineering, construction and 16 production group at Duke, and vice chairman of the NUMARC 17 steering committee, and he's going to discuss the to impiementation of the industry commitments we've made to you 19 through NUMARC.
Warren?
20 MR. OWEN:
Good morning.
21 As Jim indicated we, as NUMARC, came before you over 22 the past 18 months or so and made commitments as an industry 23 in ten major areas.
And I think you've been provided a copy 24 of this action plan.
It*s labeled action plan for meeting 25 industry commitments made through NUMARC.
It's been our
10 6
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-1 documont'avor that period et time, that INFO has used to r
2 assess our progress.
3-In the right hand column of that document, under 4
status in bold print, is the current status of each of our 5
commitments.
All utilities are committed to accomplish the l
6 elements in this plan.
And many of the commitments i nvolve 7
actions by utilities, others by. INFO and even others by other 8
industry organisations.
9 And INFO, as I said, has been coordinating and 10 tracking these activities.
They follow up on the majority at
- 11 the items and they provide updates to us at each at our 12 meetings.
13 I want to briefly go through those issues on that 14 action plan and highlight the status of the commitments made-15 by the industry.
And I*d like for you to tollow along in your l
16 document, it you will.
17 The first item pertains to the accreditation of 18 training programs and, as you're aware, the industry i s tremendous and has for a number of years 19 expending 20 ettert and resources to upgrade our training programs through 21 the INFO managed accreditation process.
That process was
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22 carefully developed to ensure implementation of performance l
23 based training programs for nuclear power olant worker r
24 positions, some ten positions in the plant.
25 And I e*aphasise the term performance base because L
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tho accroditotion procoon requiros tho onelysis of jobs and 2
tasks that workers actually perform so that we can be sure to 3
structure our training programs for maximum benefit.
- Thus, 4
the training is performance based.
5 The industry and INFO are working hard to meet the 6
accreditation schedule.
Our commitment, as you recall, was to 7
have ten programs at each of the 61 plants ready for 8
accreditation by December 31st, 1986.
Ready for accreditation 9
means that the self-evaluation report is submitted to INFO and 10 is acceptable to INFO., In other words, the program is ready 11 tor accreditation team visits and ready for accreditation at 12 that time.
13 INPO reports that of the SERs received, 235 have 14 been reviewed and found acceptable.
That's through October of 15 this year.
14 have been returned to utilities for additional 16 work.
16 are currently under review.
17 And as an industry, we are committed to meeting the 18 schedule that we've laid out and I'm sure Zack will be 19 reporting to you on December lith with more details.
20 CHAIRMAN PALLADINO:
Would you mind repeating those 21 numbers again, Warren?
22 MR. OWEN:
235 SENs have been reviewed and found 23 acceptable.
14 have been returned for additional work and 16 l
l 24 are currently under review at INFO.
i 25 CHAIRMAN PALLADINO:
Thank you.
12 1
COMMISGIONEW ZECH:
Mcw cany havo you got to 20 all 2
together?
3 MR. OWEN:
610.
4 We're aware, also, that the NRC Statt is conducting 5
reviews of training programs that are already accredited at 6
six selected plants, in order to check the accreditation 7
process.
These post-accreditation reviews are being performed 8
in addition to the active involvement that the NRC already has 9
in the overall accreditation process.
10 This involvement, it we could spend a few minutes on 11 that, includes NRC Statt members observing approximately 20 12 percent of the INPO accreditation team visits.
In addition, 13 an NRC Statt member has attended every accreditation session 14 at the National Nuclear Accrediting Board.
The NRC nominated 15 tour of the 18 members that serve on those Nuclear Accrediting 16 Boards.
17 To date, the NRC has had 11 observers accompany INPO 18 accreditation teams at eight ditterent sites.
At each of i
19 these eight site evaluations, there was a representative from, l
20 NRR there.
These NRC representatives are encouraged to spend 21 the tull time on-site with the accreditation team and that*s 22 typically one tull week, and have access to all information 23 that is reviewed by the team.
24 As such, the NRC Statt is able to review the 25 complete process by which station training programs have been
13 1
devolopod trcm job and tack analysos.
They have access to all 2
of the materials, including lesson plans, instructor guides, 3
qualittoation cards, simulator scenarios, exercise guides, and 4
they can review the technical and instructional qualification 5
of the training statt.
6 They are able to observe INFO interviews and
?
instructors, program developers, supervisors, and current and 8
.past trainees.
And also, to observe classroom training, on 9
the job training, laboratory training, simulator training to sessions as they are being conducted.
11 They can also review the stations own evaluation 12 process that*s used to measure the ettectiveness of the 13 training programs.
And of course, the NRC observer attends 14 all INFO accreditation team meetings while on site and can 15 review INFO *s written material 16 In other words, they are able to see the full 17 details of the INFO program as it takes place in the field.
18 Attendance at every accrediting board review 19 session, where utility training programs are presented to the-20 board for accreditation, ensures that the NRC Statt is able to 21 see the tinal phase of the process.
An NRC Statt member is 22 therefore present for all interactions between the accrediting 23 board and the utt11ty seeking accreditation.
24 Finally, with regard to the individuals the NRC 25 nominates to serve on the National Nuclear Accrediting Board.
u_
14 t
As you are aware, one of these individuals must participate in 2
the decision-making process for each accreditation.
And the 3
majority of the five members in a decision-making board are 4
always from outside the utility industry.
i 5
In addition, NHC's Division of Inspection and 6
Enforcement is conducting performance oriented training
?
inspections to assess the effectiveness of training at various e
utilities.
These visits are explicitly provided for by the 9
policy statement you issued.
The post-accreditation visits 10 are not.
11 In essence, the NRC currently is able to examine the 12 elements of the accreditation process in great detail from the 13 beginning to the end.
Given this current level of 14 involvement, we do not understand why NRC needs to conduct 15 post-accreditation visits of accredited plant trainin,g 16 programs.
17 The NRC post-accreditation reviews of accredited 18 plant training programs are redundant to its existing 19 oversight of accreditation.
They have a negative impact on 20 our personnel and our organizations.
These reviews consume 21 key utility resources, primarily our best people that could better be directed toward and in my view 22 otherwise 23 getting remaining training programs ready for accreditation or 24 other important management activities.
respectfully request that you 25 We request
15 i
1 oliminato thoso post-accroditation visits.
If you fool tho l
2 need to see more of the process, then we invite you to have a l
3 Statt member participate in every INFO accreditation team site i
4 visit and on INFO tollow-up visits, it necessary.
o 5
That completes item 1.
We'll be happy to discuss 6
it 11 you want to, or we can go on through the remainder of 7
the items.
Some are fairly short.
8 CHAIRMAN PALLADINO:
Why don't we go through the 9
rest of the items, unless you have a burning question.
10 MR. OWEN:
Item 2 is a commitment, and 11 you*11 11 turn to page 2 and follow along, item 2 is a commitment to 12 enhance the performance of corporate nuclear management in the 13 direction and support of nuclear plant activities.
14 Each utility committed to provide executive or 15-senior level managers to participate in the INFO corporate 16 evaluations to enhance the INFO corporate assistance and 17 evaluation of the program.
Recall that in October 1984, INPO 18 shifted its corporate assistance visits to corporate 19 evaluations, thereby strengthening that process and requiring.
20 a commitment by the utility to correct each item identified as 21 needing improvement.
22 These commitments have been met and will continue to 23 he met.
INFO reports that to date 53 utility executives have 24 participated in the 29 oorporate evaluations and assistance 25 visits conducted since January of 1984.
In my view, that's l
16
.+
1 truo rospensivonoss.
2 Item 3, at the bottom of that page, is that of 3
licensed operator performance and professionalism.
Here, each 4
utility committed'to provide some of their best senior reactor 5
operators in evaluating on the job and simulator performance 6
of licensed operator activities.
?
CHAIRMAN PALLADINO:
Is that the check pilot?
8-MR. OWEN:
No.
Mr. Chairman, they go typically to 9
SRos from another utility, join the evaluation team and 10 participate in the evaluation team and concentrate on 11
_ interactions with the operators and. observation of the 12 training activities that are taking place.
13 CHAIRMAN PALLADINO:
It*s not the check pilot 14 concept?
15 MR. OWEN:
It*s not the check pilot concept, per se, 16 although it has some of the 17 MR. MILLER:
It has some of the relevance of that.
18 MR. OWEN:
It has some of the same merits.
19 CHAIRMAN PALLADINO:
I appreciate that.
I didn*t 20 want to misinterpret what was said here.
21 MR. OWEN:
Their participation has, in our view, 22 improved the effectiveness of the evaluation process.
It has 23 provided a learning opportunity for these senior reactor 24 operators and has also elevated the stature of the licensed 23 operator community.
17 1
This program is operating exceptionally well, 2
-Utilities continue to provide some of their best people to 3
INFO to assist in this program and hear INFO reports that to 4
date industry SROs have participated in 100 percent of the 63 evaluations conducted since the start of the program in 6
September of 1984.
And I would say that this commitment has 7
also been-met.
8 Now item 4, on page 3,
pertains to the readiness of 9
NTOL plants for operation.
This commitment states that INFO 10 will visit each NTOL plant and corporate several months prior 11 to fuel load to assess and enhance the stati's readiness to 12 operate their. plant.
13 In order to accomplish these assessments, INFO 14 performance objectives and criteria for corporate evaluations 15 was revised to include all phases of stait preparation for 16 plant operation.
In addition, senior utility executives and 17 senior reactor operators are being used to enhance the NTOL 18 corporate plant assistance visits.
19 This commitment is also being fully met.
on page 4,
is item 5, which has to 20 Also on page 2-21 do with improving the diagnostic abilities of shift operating 22 personnel This commitment involved many actions by INFO and 23 by utilities to ensure that senior shift operations personnel 24 are knowledgable of appropriate engineering fundamentals and i
25 are able to develop and maintain a high degree of diagnostic
18 1
ability.
2 I'd call your attention specifically to items 5.1 on 3
page 4 through 5.8 on page 5.
Note that all of the 4
commitments that were due to be completed by this date have 5
been completed.
It is now up to each utility to complete 6
implementation and diagnostics tra.ining and for INPO to 7
continue to emphasize accident diagnosis and response training B
during plant evaluations and during reviews of utility 9
training programs.
10 So in that case, work has been done.
The base has 11 been laid and it*s up to the utilities to carry out their 12 commitment and I know that they are doing that.
13 CHAIRMAN PALLADINO:
I apolaud you in this ettort.
14 MR. MILLER:
INFO will be checking them, too.
Of 15 course, that's 5.10.
16 MR. OWEN:
5.9 and 5.10 have'a fairly short 17 implementation date.
18 Now item 6 on page 5 pertains to nuclear management 19 experience development.
It involves commitments on the part 20 of each utility to upgrade programs designed to develop 21 candidates for nuclear utility management positions.
22 NUMARC has tormed an ad hoc group to assist 23 utilities in management experience development and INFO 24 has upgraded performance criteria and evaluation programs.
25 You will note that again it*s now up to each utility
19 1
to roview, upgrado, or formalizo as nocessary thoso progrcms 2
designed to develop candidates for nuclear management 3
positions.
And INPO will be evaluating those actions, or is 4
evaluating those actions as part of its ongoing evaluation 5
program.
6 Item 7 is on page 6 and deals with the shortage of 7
qualified personnel.
Here we made a commitment that each 8
utility will adopt policies and practices designed to increase 9
the stability of its nuclear staff and the availability of 10 qualified personnel.
11 Utilities recognize the importance of this item and 12 have implemented many changes in their internal programs.
For 13 example, 100 percent of the utilities raport that they have 14 developed approaches to reduce the use of contracted personnel 15 in permanent utility positions.
NUMARC is tracking this item 16 and will obtain follow on reports of progress in 1986.
17 In addition, 34 utilities have reported that they 18 have plans and agreements with local educational institutions 19 involving specialized higher education to promote increased 20 stability of utility statis and the availability of highly 21 qualified and well-educated personnel 22 The recently formed National Academy for Nuclear 23 Training is another example of industry initiative in this 1
l 24 area.
Commitments within this item are being met.
r 25 CHAIRMAN PALLADINO:
You say recently formed I
20 1
WCSn't GwCr0 that they havG actually formod it.
2-MR. OWEN:
Well, it has been anncunced internally 3
and the work is underway.
There are a number of committees 4
functioning at INFO to flesh out that concept.
Most of the utilities are planning some sort of announcements of that in 6
connection with our training programs and I think that's a 7
good concept and one that holds much promise for us down the 8
road.
9 CHAIRMAN PALLADINO:
It's still being tieshed out, 10 if I understand you correctly?
11 MR. OWEN:
Yes.
12 COMMISSIONER ROBERTS:
And this is an INFO 13 initiative?
I 14 MR. OWEN:
Yes, this is an INFO initiative.
15 Item 8 on page 7 pertains to our commitment to 16 improve fitness for duty programs and that is each utility 17 would implement a basic titness for duty program by January l
18 31st, 1985 and then improve and enhance its fitness for duty i
19 program.
l r
l 20 CHAIRMAN PALLADINO:
So that is 1985 there?
21 MR. OWEN:
It's actually listed as February of
'85, i
22 but our commitment internally was by January.
23 CHAIRMAN PALLADINO:
I was looking at the first 24 sentence.
25 COMMISSIONER BERNTHAL:
- 86 is what you mean, isn*t
21 1
it?
2 COMMISSIONER ASSELSTINE:
No, they put them in 3
place.
4 MR. OWEN:
'83.
The basic program is in place.
5 What I'd like to do is go on and come back to that 6
particular one because we do want to discuss that one in some 7
detail.
8 We can skip to item 9 on page 8.
That involves our 9
ongoing commitment to reduce automatic reactor scrams.
Now this calls for each utility to 10 each utility will adopt 11 adopt practices and policies designed to reduce the number of 12 unnecessary automatic reactor scrams.
13 Accomplishment of this goal involves a wide range of 14 actions, including root cause analysis of the scrams, and these are 15 evaluation of post-scram procedures used 16 evaluated during INFO visits, evaluation of plants with goed i
17 scram records and the implementation of improvement measures 18 throughout the industry.
19 And the industry has already made substantial 20 pregress in this area, although we're not where we'd like to 21 be.
Unplanned automatic scrams, while synchronized to the 22 grid, have been reduced from an average of six scrams per unit 23 in 1980 to an annual average of 3.7 scrams per unit through 24 September et
'85.
And that's an annualised number.
- Actually, 2$
I think we're at about 2.2 right now, but expect to be at J
22 1
about 3.7 through the year end, 11 that rato continuos.
And 2
that's a reduction of about 40 percent over that time trame.
3 And we*ve also established an aggressive goal for 4
1985 to. achieve an average of no more than 3 automatic scrams per unit while critical, for plants with more than three years 5
6 commercial operation.
This is a ditticult, more demanding 7
test than heretotore used.
In 1984 the industry had an 8
average of 4 per unit while critical Through September of 9
'85, the average was about 3.8.
10 CHAIRMAN PALLADINO:
You're saying your target is 3?
11 MR. OWEN:
Our target is 3.
12 MR. MILLER:
For this year.
13 MR. OWEN:
For 1985.
14 CHAIRMAN PALLADINO:
Long term. I would hope it 15 approaches as close te zero as you can get.
16 MR. OWEN:
Obviously, our aspiration is to be at 17 sero.
It makes good sense from every standpoint.
18 We've recently established a more aggressive goal i
19 and our long term goal is to have no more than two scrams per 20 unit while critical by 1990, industry-wide.
21 MR. MILLER:
We had some discussion, from time to 22 time, about making the goal sero.
And I think that our is 11 you have a zero goal and you 23 thinking -- mine anyway 24 put an incentive with it, which we do with my company, and the 25 guy has a trip in January, he loses his incentive.
So we try
23 1
to have three levels of goal.
We're driving towards a soro 2
goal and we would call that our excellent goal we don't have a name on 3
But we would then have but it would probably be one or two.
One would be 4
the file 5
another level and two would be another level.
If you've got 6
more than that, then you lose incentive, among other things.
7 COMMISSIONER ZECH:
But the goal should' clearly be 8
sero, not three.
9 MR. MILLER:
In due course, Admiral.
But to make it 10 sero today, I think would impose a risk of 11 COMMISSIONER ZECH:
But you really want sero.
12 MR. MILLER:
That's exactly right.
13 COMMISSIONER ZECH:
Your aspiration is sero, not 14 three?
15 MR. MILLER:
We're trying to get zero, but what to we're trying to do is do it over a period of time that will be 17 accepted as a challenge and performed as a challenge by the 10 people at the plant.
it's 19 COMMISSIONER ZECH:
I understand, but I just 20 important, I think, that we don *t think three is good.
21 MR. OWEN:
Our aspiration is sero for all of those 22 obvious reasons.
I think Jim's point is you dangle a carrot 23 out in front of folks, not so far out that it*s not f
24 attractive.
i 25 COMMISSIONER ZECH:
I understand.
Sure.
24 1
COMMISSIONER BERNTHAL:
I think tho other point to and I 2
he made is a long term goal of 2 trips, I presume is per utility.
And it every 3
think you mean it this way unit, sorry.
Per unit. I misspoke, of course per 4
utility 5
unit.
And it every unit is serious about a goal like that, all 6
then the average over the long term -- for all plants 7
utilities will surely be less than 2.
8 The thing that's dragging the average down right now 9
is some utilities and some units that are much, much more than 10 2 or 3 per year.
So it every unit has that goal, we're going 11 to do better than 2 per year.
12 MR. OWEN:
We want that to be the case and we 13 believe that will be the case as we develop the programs that 14 we talked about.
15 I would point out that there are things that are 16 going to be important to us in achieving those goals, such 17 things as the amount of surveillance testing that we do on 18 line.
And we're going to be coming back to you trequently.
14 It does not necessarily follow that we can achieve these kinds 20 of results without some really hard consideration of what 21 causes these and certainly the problems associated with l
I 22 surveillance testing on line is one of the key ones.
23 COMMISSIONEM ZECH:
Yes, that's a good point.
24 CHAIRMAN PALLADINO:
I was going to make the 25 observation that many of the scrams relate to either
25 1
ourvoillanco or maintononco that*o going on whilo a plant is 2
operating.
And again, it comes back to the need to emphasize 3
the training on maiEtenance so these people know what they are 4
to do and they know how to do it before they get in there.
MR. OWEN:
Absolutely.
6 COMMISSIONER ZECH:
I agree with that.
We should be 7
looking into that, because it seems to me that surveillance 8
and testing is perhaps something that merits our attention and 9
does result in unplanned scrams.
10 But I think the key point here, too, to remember 11 that we're talking about unplanned scrams.
We're not 12 discouraging the operator from shutting down the plant 11 he 13 thinks there's a real problem.
That's very important.
So 14 we're really only talking about unplanned scrams.
15 MR. MILLER:
We are, too.
16 COMMISSIONER Z E C il:
The operator himself, you know, 17 trying to do a good job, he should never ever feel that he le can't shut down that plant, it he has any concern at all.
19 MR. MILLER:
We call unplanned automatic.
20 COMMISSIONER ZECH:
Right.
21 MR. MILLER:
It it's operator initiated, and he 22 feels like he wants to, we want it shut dcwn.
23 COMMISSIONER ZECH:
That's right.
That's important.
I think we're in agreement 24 MR. OWEN:
Well, we 25 that as the direction we want to go and we will be back to you
1 26 1
when wo boliovo that tho ball, scmo part et that ball is in j
2 your court.
And maybe we can work together to achieve those 3
goals.
that's on page 9 4
Finally, item 10 involves 5
involves enhancing management ettectiveness.
To accomplish 6
this, each utility committed to develop and promulgate goals 7
and objectives reflecting a commitment to excellence and to 8
develop and use a nuclear plant performance indicator system 9
to monitor the performance of its plants.
10 INFO has also emphasized management involvement in 11 operations and the use of goals and objectives as a part of 12 plant corporate evaluations.
13 INFO also compiles and publishes performance 14 indicated data as a measure of industry progress.
And I think 15 you will note that the first report was published in December 16 of
'84 and the second report was published in May of *85 and 17 there will be continuing reports.
s 18 MR. MILLER:
The Statt, I believe, has received 19 copies, is that correct?
20 MR. OWEN:
I think that's c o r r e c t.-
21 In all, the industry made many specific commitments 22 and improved their operations and has carried out these 23 commitments.
Most were completed on or before the scheduled 24 date.
And I hope you'll note that all that are due at this 25 time have already been met.
And I believe that, and plus the
~ -.
W 27
. attendoneo horo toccy is indicativo of tho importanco the 2
industry places on these items and this opportunity.
3 Let me point out that when we say that an item is 4
complete, it does not mean that attention to this area has 5
ended.
Our industry is committed to continue to strive for 6
excellence in all areas and INFO will provide the mechanism 7
for us to accomplish this goal.
8 Now it we could continue for just a minute.
Related 9
to our comments, there have been three major areas on which 10 NUMARC has worked with the Statt to develop policy statements 11 in lieu of rulemaking.
And I'd like to turn our attention to 12 those policy statements.
13 The first area was training and qualitication on 14 which you issued a policy statement on March 20th, 1985.
And 15 1 believe we've already discussed that area sutticiently.
16
~
The second area, engineering expertise on shift and 17 the third, titness for duty, have not met with the same 18 success as the policy statement on the training and 19 qualification.
And I'd like to discuss these two areas in 20 some detail, r-21 First, engineering expertise on shitt.
As you 22 recall, as of January 1st, 1980, the NRC required each nuclear 23 power plant to have on duty a shift technical advisor whose i
24 tunction was to provide engineering and accident assessment 25 advice to the shitt supervisor.
As far back as 1981 the NRC
\\
l i
28 1
Statt proposoc roquiring that shift suporvisors hold 2
bachelor's degrees in science or engineering.
3 Industry studies were performed in 1981 and then 4
again in 1983, And we found little evidence that such a 5
degree would contribute significantly to the performance of 6
shift supervisors.
7 On October 12th, 1984, NUMARC executives met with 8
you and requested that you delay a final decision on the NRC 9
proposed policy statement on engineering expertise on shift 10 until after NUMARC could review it.
On November the 5th, 11 1984, you met to discuss engineering expertise and other 12 issues and directed the Statt to develop a policy statement in 13 cooperation with the industry.
m
,f 14 The NRC Stati developed a policy statement in 15 cooperation with NUMARC, and on February 27th, 1985 the 16 positions expressed in the NRC proposed policy statement were 17 endorsed by the overwhelming of the NUMARC executive group.
18 On March the 7th, 1985, NUMARC notitied the Statt that the 19 industry would support the policy statement the NRC Statt had.
20 worked out with the NUMARC working group.
21 Then SECY 85-150 was issued, on April the 26th, 22 1985, recommending approval ot either a version A or a version 23 B.
This SECY letter highlighted the Statt's recommendation 24 that completion of SRO and STA accredited training is an 25 acceptable option for the combined SRO/STA position.
29 1
do ngw undorstond that the policy statomont that was 2
carefully worked out has been changed by deleting option 1.E.2 3
and by deleting some of the alternatives to formal education 4
in option 1.B.1.
The process established and used for 5
developing the initial policy statement ensured that the 6
collective experience and expertise in the industry was fully 7
and carefully considered.
3 Agreement was reached on the concept, tho' thrust, 9
and the substance of the po18cy statement, as a comprehensive 10 package.
The full NUMARC executive group overwhelmingly 11 endorsed the positions expressed by the policy statement.
12 Frankly, we don't understand the basis for changing 13 such a policy statement without some term of consultation.
I 14 have highlighted this issue because this approach, as an 15 example, has the potential to weaken tuture cooperation and to industry initiatives.
We believe we must all work harder 17 to minimise this type of occurrence in the future.
19 The next area of ditticulty for us is titness for 19 duty.
As you recall, you approved a titness for duty rule on.
20 July the 5th, 1984.
The rule required each licensee with an 21 operating license to establish and implement written
" provide retsonable assurance and ! quote 22 procedures to 23 that any person in a vital area, while performing any duty in 24 that area, is not 1) unfit tot duty due to the influence et 25 alcohol; 2) untit for duty due to the influence of any drug or
30 1
drugs thot oculd ottoet his er hor icoultion in any way 2
contrary to safety; or 3) untit for duty because of any other 3
mental or physical impairment that could atteet performance in 4
any way contrary to safety."
5 At that time, the NRC Statt stated that it planned 6
to use the industry developed EEI guide as a basis for 7
reviewing utility programs.
On October 12th, 1984 NUMARC v
8 presented to you a position unanimously endorsed by the "the and again ! quote 9
industry.
That position stated 10 industry is willing to develop program elements and criteria 11 tor use by INFO in evaluating utility titness for duty 12 programs it the pending rule is worked on and replaced with
'13 polley guides.
Should the titness for duty rule be put into 14 ettect, NUMANC would have to withdraw its commitment and 15 discontinue its activities in this area."
16 As you recall again, you agreed to recall the rule 17 on titness for duty on October the 17th, 1984 and had your 18 statt work with the industry in the development of a policy 19 statement.
The polloy statement developed by the Statt and 20 the industry was subsequently provided to you in SECY 85-21, 21 dated January the 17th, 1985.
22 Since the beginning, the industry has tatthfully 21 carried out all of its commitments as outlined in the dratt 1
24 polloy statement, even though a polloy statement has not been
(
25 issued.
Specittoally, these include the implementation of a l
l
31 1
basic titness for Cuty prcgrec, in ploso, at oach utility by 2
January.the 31st, 1985.
3 In response to a request from INFO, every utility 4
reported in writing that they would have a basic program in 5
place by February 1st, 1985.
4 Commitments also include INFO evaluation at utility 7
titness for duty programs based on new program elements and 8
criteria updated by February 1985 tor planned evaluations.
9 And by August 1985 tar corporate evaluations.
These 10 evaluation criteria go beyond the more general guidelines of 11 the revised EE! guide to ettective drug and alcohol titness 12 tot duty program.
These evaluation ortteria have been 13 provided to utilities for their own use and copies have been 14 provided to the NMC Statt.
15 As part of the plant and corporate evaluation 16 programs, INFO has been and will continue to evaluate utility 17 implementation of titness for duty programs, note dettoiencies 18 and make recommendations for improvement and tollow up to 19 ensure such improvements are implemented.
INFO has expanded 20 the evaluation program to strengthen this activity.
21 EE! guide t,o atteotive drug and anochol titness for 22 duty polloy development was revised in August 1995.
It has 23 been published.
The ut!!1 ties have committed to upgrade their 24 programs to meet the INFO oriteria and the intent of this 25 guide by the end of March of 1990.
The industry has l
E 32 1
conducted anothor workshop on titnoss for duty on Ostebor tho 2
22nd and 23rd, primarily to address the revised EE! guide and 3
Jim Miller along with Jim Taylor of your Statt were attendees 4
and speakers at that workshop.
5 In summary, the proposed policy statement was worked 6
out in good tatth, with great ottort, by many in the industry 7
and in the NMC Statt.
The proposed polloy statement was S
unanimously endorsed by the tull NUMAMC executive group 9
membership.
The industry has tu11111ed its commitment and is 10 upgrading its activities to improve titness for duty, as 11 outlined in the proposed policy statements.
12 I would say that these commitments go well beyond 13 the earlier proposed NMC rule.
14 Fitness for duty programs are being improved 15 industry-wide.
The utilities believe strongly in a titness 16 tor duty program.
The utilities are now addressing ott site 17 use and sale et drugs, areas which the previously approved NMC 16 rule did not address.
19 However, at your Gotober 22nd meeting, I understand 20 you expressed a number et concerns in this area that need to 21 he addressed.
The first is whether the NMC can enforce a 22 polloy statement it a utility has a titness for duty program, 23 which all 55 utilities have reported to INFO as having.
i 24 Entorceability, in our view, is not an issue.
It a 25 person is found in a vital area under the influence et drugs t
l
I 33 1
er alschs!, thoro shculd bo no doubt in tho minds et the NMC 2
Statt or the Commissioners that the individual would be j
3 removed from the vital area and it he is not, we know that the 4
NMC can act under its responsibility for public health and 5
safety, to require immediate corrective action.
6 It appears to us that there is no need for turther
?
regulations for enforceability.
We believe the regulator has S
the authority to act, based on performanos or results of the 9
program, together with its responsibility for public health 10 and safety.
11 The industry is after results, just like the NMC.
12 We do not want someone under the influence et drugs or alcohol l 'J in our plants where they could make dangerous and very costly i
14 mistakes.
We've made many improvements and will continue to 15 enhance this program, i
16 The purpose at our titness for duty program is to 17 help ensure personnel under the influence at drugs and alcohol 18 are not working in vital areas.
We recognise, as you did in 19 the proposed policy statement, that drug and alcohol abuse are 20 pervasive problems atteoting every segment of society and that 21 they exist, to some extent, in the nuclear industry.
22 Therefore, a titness for duty program cannot totally prevent 20 drug and alochol abuse.
A program can, however, identity 24 personnel involved with drugs and alcohol.
25 The ability for a titness for duty program to l
34 7
1 identity such problems demonstrates the workability of the 2
- program, It does not, in any way..signity an inettective 3
program as some seem to believe.
On the contrary, as we
'4 enhance our titness for duty program, we might expect to i
5 identity more problems.
We recognise that changes will be 6
necessary in the titness for duty programs, as the industry 7
gains experience in this area.
Not just our area, all l
8 industries.
And we plan to continue to work with your statt
(
9 in this area and provide periodio updates as to the.nanges 10
- involved, i
11 1 guess, in summary, we request that you immediately 12 approve the proposed policy statement on titness for duty as 13 it was submitted to you, t
14 Jim, I guess that wraps up my --
15 MM. MILLEM:
That doesn't cover the entire report 16 but it does cover the commitment package that we made to you.
17 We still have a couple of other items to address, but it you 16 want to talk about those commitments at this time, or do you 19 want us to go ahead and tintsh our entire report?
20 CHAIMMAN PALLADINO:
How much more do you havet 21 MM. MILLER:
We've got about 15 minutes more.
22
- 0MMISSIONEN AWSELSTINE
I would go ahead.
23 CHAIMMAN PALLADINO:
All right.
I do want to come 24 back and clarity some points on titness for duty, but we'll 25 wait.
35 1
MM. MILLER:
Yos, sir.
2 Before I introduce C.O.
Woody to discuss maintenance 3
activities, I would like to provide an overall perspective and 4
background of NUMARC activities in the area of maintenance.
5 As you know, we formed a working group in June or 6
1984, a little over a year ago, to look at the maintenance 7
area industry-wide.
This group includes utility workers and 8
has been quite active.
They expended more than 13,500 man 9
hot. of ettort to help identity improvements in the 10 maintenance area.
11 The first task taced by this group was to identity 12 and detine speottic overall industry maintenance problems.
In 13 doing so, the working group identified a number of real 14 problems and need for long range improvements.
And the 15 industry is working on programs, long range programs, to make 16 improvements in maintenance.
17 NUMARC is working with the NRC Statt in the 18 maintenance area and the working group has interacted with NRC 19 Statt members in informational and technical exchange 20 meetings, the latest being October the 10th.
We have provided 21 a copy of the list of attendees and the agenda to illustrate 22 the types of activities discussed at that meeting.
It is my 23 understanding that a good deal was learned by everyone l
24 present.
25 Opportunities for realistic, cooperative, long term l
l
36 1
upgrados to onhcn00 scioty and rolichility cro many.
to 2
locused our comments in the maintenance area on some of the 3
questions forwarded to NUMARC by the Statt.
But let me talk 4
just a moment about NUMAMC.
5 As you recall, NUMARC is an ad hoo group.
It's a 6
confederation of all SS of the U.S.
utilities represented by 7
nuotear utilities involved in the daily operation of the 8
plants.
Members pledge to each other, and sometimes to you, 9
to meet their commitments.
10 When commitments are made by NUMARC members in areas 11 within the scope of INFO activities, within the scope of INFO 12 activities, NUMARC asked INFO to evaluate the status of these 13 commitments during their evaluations.
And those occur en the 14 average of about every 15 to 16 months per plan.
15 INFO evaluates maintenance programs and have 16 reported substantive improvements from their ettorts which 17 have been achieved over the industry as a whole.
However, 1 18 should note that real improvements take time.
There are not 19 too many shortcuts available for real and meaningtut 20 improvements in many areas, and that includes in the 21 maintenance area.
22 With that, C.O.
Woody, Vloe President of Nuolear Ops 23 at Piorida Power & Light, who is chairman of the maintenance 24 working group, will describe the status of that working 25 group's activities.
37 1
M3. COODY:
G@od mDrning gonticoon, and thank ycu i
2 ter allowing me to briet you today on the activities in 3
progress that we've made in the maintenance area.
4 In our last briefing with you, in March, I reported 5
on the formation and composition of the NUMARC working group 6
on maintenance, our ettorts to assess and analyse the state 7
of maintenance in the industry, our plans for installing 8
maintenance indicators and our activities to improve 9
performance.
10 Our assessment and analysis work was necessary to 11 see it there were major program development needs and to help 12 us work on the right elements to produce the improvements wo 13 seek.
We have determined that there are valid working 14 programs in the industry capable of socomplishing retults in 15 all areas of concern.
There are many advanced, leading edge 16 programs already in place and others are under development.
17 We have found that some utilities are doing an 16 outstanding job of assimilating these new techniques into l
19 their programs.
Others have not moved as rapidly and some may 20 need help.
The transfer of technology and innovation is 21 taking place and through the extensive ottorts at INFO, EPRI, 22 owners' groups and others, we are making progress in this 23 complex area.
24 We will continue emphasis on turther progress and 25 tind ways to accelerate the self-improvement ettort L_
38 1
Gorly in cur wark, wo roccgnisod that wo noodod c 2
way to document this progress.
Therefore, the working group 3
has put into place a maintenance performance in,dicator program 4
that I will cover in more detail a little later.
5 I would characterise our work from July 1984 to i
6 April of 1985 as a period of assessment and planned l
7 development.
8 I would now like to tell you what we have 9
acocuplished since our last meeting with you in March.
s 10 Maintenance performance indicator data has been gathered for 11 the year 1984 tor ten parameters, some of which have sub-tier 12 data and the first report has been issued to the utt11 ties and 13 your statt has received a copy of that.
14 We believe that these ten broad parameters can be 15 used to track performance, however we must understand that 16 they are only indloators and cannot be used as absolute and 17 sole measures of performance.
The data for the first two 1B quarters of 1985 has now been received and is being 19 processed.
The management of this program has been accepted 20 by INFO as a part of their overall performance indicator 21 program.
This program provides each utility with an industry 22 look in histogram form, showing each utility's performance to l
23 them personally and then providing some comments such as 24 medians, upper and lower quartile so that they can analyse 25 their performance and take steps where necessary.
F 39
?
1 Co oro p10tting such things as unit avoilobility, 2
forced outage rates, corrective and preventive maintenance 3
backlog, ratto of corrective and preventive maintenance work, 4
personnel radiation exposure due to maintenance, and lost time 5
aooident rate.
NUMARC has provided some industry experts to 6
INFO to provide an independent assessment of the utiltty data 7
and to validate the data.
6 We obtained input from the NRC Statt during the 9
development of this program and they have received a copy of to the first report.
11 The maintenance performance indicator program is a 12 part ot.a larger INFO performance indicator program that also 13 has, as one of its elements, the establishment at 14 industry-wide long term performance goals and those have been 15 spoken to earlier today.
16 A key part of our work during the past six months 17 has been information exchange and technology transter.
In 18 this regard we've assisted INFO in a number of areas such as, 19 formulation of a guideline for conducting maintenance at 20 nuclear power stations document.
21 I have a copy of that document here with me.
And it 23 bastoally is a model on how to conduct maintenance, organise 23 it, control it.
It covers organisation, training and l
24 quantinostion, facility and tooling, procedures, planning and 25 scheduling, control of maintenance, post-maintenance testing,
40 e
1 cnd tinolly, on oxtonsivo sostian en haw to dovolop a l
2 preventive maintenance program with some of the predictive and 3
scientitle techniques that are now being developed.
l 4
This guideline is a broad-based manual on how to do 5
maintenanot.
Even though not yet formally released, several 6
utilities have obtained advance copies and are already using l
7 this vehicle to structure improvement in their programs.
We 8
expect final release of this guide in mid-December.
Your 9
Statt has been provided a copy of the present dratt, j
l 10 We have assisted INFO in publishing a very useful l
11 writer's guideline for maintenance test and calibration 12 procedures.
This document enhances the human factors aspect l
13 of procedure writing.
Utilities are now using this guideline 1
14 in their procedure upgrading ettorts.
The Statt has a copy of 15 this document.
They have commented favorably on its quality.
j 16 We have provided several members of the working 17 group to accompany INFO on plant evaluations.
In addition, 18 the utilities are now providing maintenance managers on 19 selected INFO teams as peer evaluators.
They serve both as 20 peer evaluators and provide a flow of information to and from 21 our working group.
This is probably the most eilective and 22 etilotent technology transfer that we can provide.
23 We've been aggressive in providing speakers at 24 industry meetings to discuss the overall subject of 25 maintenance performance and improvement.
We've partionpated
41
?
1 in AN3 m30 tings, IEEE m30 tings, NOMUS m30tingo end tho INFO 2
maintenance superintendent's workshop.
In the case of the 3
workshop there were 97 percent of the nuolear utilities 1
4 represented with 114 maintenance management personnel present.
i We've conducted two separate exchange meetings with 6
senior members at your Statt.
One at the Charlotte, North 7
Carolina maintenance equipment and application center, and as 8
Jim Miller indicated, the second at Crystal River plant.
9 These meetings were planned by Bill Russell of your Statt and 10 myself to exchange information and concerns.
I hope that 11 you*ve gotten some positive teedback tros this ettort.
12 Our working group has had a very active role with 13 the Electric Power Research Institute.
As reported to you in 14 March, the nuclear industry has spent over s20 million on 70 15 projects that are designed to improve plant performance in the 16 maintenance area.
These include programs in outage p14nning, 17 preventive maintenance, tooling, robotics, material control, 18 and predictive maintenance techniques.
19 During our meeting with the Statt on October 16th at 20 Crystal River we demonstrated some of these predictive 21 maintenance techniques in areas of vibration analysis, l
22 thermography, Lubol analysis, and motor operated valve l
23 diagnostics.
Since September we've been able to obtain 24 preliminary approval through the EPHI structure for an l
25 additional s7 million in the maintenance area.
42
?
1 Ono vory prcmising progrcm that's boing pursuod new j
2 is a diagnostic center that would be statted and utilities 3
could call and receive help on information that they have that centralised and scientiito data might be available to help 4
5 them in analysing what to do.
6 I'm pleased to report to you that we are being 7
effective in correcting previous communtoation problems in 8
technology transfer.
Examples of this improvement can be s
9
.ound in a marked increase in the utilisation of nuclear 10 network and the NFMDS reporting system.
The extensive use of 11 INFO good practices observed during plant evaluations and 12 distributed to the industry through nuclear network is but one 13 example of how information is being utilised to accelerate
+
14 improvement in the maintenance.
and there are at 15 These good practice documents I
16 least 18 of them in the maintenance area cover issues that i
17 are common where a good fix has been developed, and they are 18 now being aggressively sought by maintenance managers in all 19 the stations, i
20 Our vendors and architect engineers are a vital 21 resource to us.
We are finding improved ways to gain help 22 from them and to focus on the right issues to correct I
23 repetitive maintenance problems, Examples can be found in the 24 vendor scram reduction work, the feedwater regulation at low l
25 load program, and reactor coolant pump seal seminars.
l t
i L.
43 1
Finally, I would liko to contien our work in 2
analyzing maintenance practices of other countries, It does 3
appear t.a t we can learn from some of their techniques.
A 4
technical exchange visit to utilities in Japan has been 5
completed this year.
The team consisted of representatives 6
from seven nuclear utilities, two industry suppliers, the 7
Electrio Power Research Institute, the National Nuclear 8
Accrediting Board and others from INFO.
9 The report from this trip should be released to the 10 utilities within the month.
A copy will be provided to the 11 NRC Stati.
We have also reviewed the NRC NUREG on your 12 Staii's visit to Japan and are isotoring its observations into 13 our future work.
14 In addition, there are many industry and INFO visits 15 to foreign utilities; Taiwan, Korea, several countries in to Europe in the past year.
INFO has a liaison engineer loan 17 program that is also helping provide a greater insight into 18 maintenance practices from foreign countries.
19 In addition, many utilities, including the one that 20 I work for, have agreements and programs in place to further 21 this process.
I'm taking a 10-man team of our company's 22 nuclear group to Japan on December 5th, 1985.
We've been 23 meeting tour hours per week as a team to prepare for this 24 exchange.
One of the key areas of interest is maintenance.
25 In summary, I believe that the industry programs and
44 1
soli-improvement ottorts are producing results.
The industry 2
scram reduction rate, improved performance in occupational 3
exposure, reduced significant events, and reduced forced i
4 outage rates give quantifiable validation to this position.
5 Although these are good indicators, we are not 6
satisfied and we are aggressively looking for ways to affect 7
more improvement.
The motivation for, and results of our 8
performance improvement should go far beyond that which can be 9
driven.by regulation.
In this regard, our working group will 10 continue to pursue ways to accelerate technology transfer and 11 assist each ut i l i t y w:. t h he l p to apply these advanced systems 12 and techniques as appropriate at their plant.
13 Thank you.
14 MM. MILLER:
Thank you, C.O.
15 Our next area of discussion this morning is the new 16 NUMARC initiative to address selected technical or hardware 17 related issues.
This initiative was overwhelmingly approved 18 by the NUMARC executive group on August 28th of this year.
19 NUMARC informed the Staff of this initiative, this new 20 initiative in a letter to Bill Dircks on September the 6th, 21 1985.
i 22 Organizational 1y, we've formed a technical i
23 subcommittee.
That subcommittee is chaired by Jack Ferguson, 24 president of Virginia Power, and currently it has two working 25 groups to address some selected hardware related issues.
k
I 4t 1
Ono working group is roviowing tho issuo of station 2
blackout and it is headed by John Opeka, senior vice president 3
of Northeast Utilities.
I think John was also one of the 4
co-chairman of the NUGSEO group that's been working on that 5
for some period of time.
6 The other working group headed by Bruce Kenyon, 7
senior vice president of Pennsylvania Power & Light is 8
reviewing the sort of a maze of all of the issues to 9
prioritize and see 11 NUMARC will become involved in any of 10 those.
11 Specifically the station blackout working group is 12 coordinating industry ettorts to address the station blackout 13 issue.
The working group includes participants from the 14 Nuclear Utility Group on Station Blackout -- NUGSBO -- AIF, 15 and EPRI.
And it presently evaluating the different 16 approaches to this issue.
17 Therefore, we request that you take no formal 18 Commission action on the station blackout issue until we have 19 had the opportunity to work clo:ely with members of your Statt 20 to obtain their prrdstotive and insights.
We would expect to 21 briet you on the results of these interactions and any other any industry positions that might be developed therefrom.
22 23 We believe that focusing the expertise of the 24 industry and industry support organizations on this issue will 25 result in the best practical solution to a problem.
46 1
CHAIRMAN PALLADINO:
Do you h t. e u.
.ndscatton of the group might reach a point 2
when you think that 3
MR. MILLER:
Well, John Opeka*s here, let me just 4
ask him.
John, are you here?
5 MR. OPEKA:
Yes, February of
- 86.
6 CHAIRMAN PALLADINO:
February
- 86.
7 MR. MILLER:
That*s their goal 8
In closing, we thank you for this opportunity to 9
provide an update on NUMARC activities.
We will tentatively,
10 plan to brief you on our NUMARC activities overall two or 11 three times a year, or any time that you request us to come.
12 And subject to your questions and comments, this concludes our 13 briefing.
14 CHAIRMAN PALLADINO-
'"h a n k you, Mr. Miller.
I*d 15 like to make a couple of comments and then focus on two areas 16 for my questions.
I 'l First of all, I'm very pleased to see the strong 18 continuing active program that NUMARC has.
I think you can do 19 for the industry, by your commitments, what we could never de 20 purely by regulation.
You are seeking, striving for, and I 21 think seeing the results of that work in achieving excellence.
22 CHAIRMAN PALLADINO:
And I think I speak for my 23 colleagues on that.
We are pleased with the progress that is
.4 being made.
Specifically in areas like atintenance and like 25 diagnostics, titness for c er t y, expertise in shift.
47 s'
1 Howevor, any timo two organizations work togethor 2
and each having a different perspectives, there are bound to and I 3
be areas where we're going to not agree.
Eut I hope 4
want to emphasize, that we should not let the differences 5
becloud the many constructive efforts that have been 6
undertaken, and the very worthwhile progress that has been 7
made.
Because sometimes when we develop or talk about 8
problems, people think that*s all that exists.
9 But the problems, as you pointed out, emerge from a 10 base of many areas where we do agree and progress has been 11 made.
12 Now let me talk about two areas, if I may.
With 13 regard to witness for duty, at the October 22nd meeting, there 14 were three points that the Commission did discuss and on which 15 it made recommendations.
One was the fact that the broad 16 objectives of the program weren't as well stated in our policy 17 statement as the Commission could do.
18 Second, there was concern about whether or not or chemical 19 utilities were bringing about clinical testing 20 testing to identity the use of drugs or alcohol.
And we felt 21 that we should put in our policy statement that we would 22 expect them to put in that area.
23 And we similarly were concerned that not all 24 utilities are equally forceful in developing an enforcement 25 program.
And the recommendation that came out of the
48 1
discussion, as I recall, is that we would expect all utilitios
, ~,
_2-
_to develop an enforcement program of their own.
3 We did get to the verge of saying, well, maybe we 4
ought to be putting out a rule on this.
But we did recognise 5
thatfwe had made a commitment to NUMARC and we intend to honor 6
that.
So at this point, we're asking the Statt to revise the 7
policy statement to have the broad objectives, add the 8
expectation that there be chemical testing and add the 9
expectation that there be some enforcement program in the 10 utility programs.
11 Many of these things are in the EEI program but 12 they're discretionary, and we'd like to encourage those 13 points.
14 The second area that might -
I'd like to touch base 15 on since I'm one of the possible thorns in your side on this 16 topic is that of degreed people on shift.
And one of the 17 reasons I applauded your program on diagnostics is that I 18 think that*s where people with strong background are needed.
19 And I haven't said that any particular person ought to have or with a 20 be the one with a degree program, but I think 21 degree, but I think that somewhere on each shift there should 22 be available, and in the supervisory area, an individual who 23 has the best possible base from which to make diagnostic 24 judgments when particular incidents take place.
25 So I strongly felt that we should -- in an 1
1
49 1
installation as complox, costly and having such far-roaching 2
potential consequences 11 there -- when things go wrong that I 3
think we should have as highly trained a person, and educated 4
a person as we can get for the purpose of making sure that 5
whatever happens at the plant is properly recognized and o
corrective action taken.
7 Now, one question I did want to ask with regard to 8
the fitness program.
Do you know the extent to which 9
utilities are including in their prog 1ams periodic chemical 10 testing for drug use?
11 MR. OWEN:
I don *t believe I can answer that 12 specifically.
I think that most are in the process of 13 implementing that.
There*s been substantial improvement made 14 in that chemical testing, and there*s been substantial 15 improvement made i n -- perhaps in our understanding of the 16 quality of that test.
17 And I think that*s been awfully important to us in 18 that there are pretty strict liability laws in the country 19 today.
So I think we're all moving in that direction.
I can 20 report that at a meeting the other day that virtually every 21 utility there had it underway in some form.
22 I know we*ve been working on it for a long time, on 23 the verge of -- have been using it for pre-employment testing but on the verge of making it a company-wide requirement 24 25 for certain sensitive jobs, and for annual who has to have an
50 1-annual physical, which_I might add, includes the officors of 2
the company.
But that takes time.
We're currently in the 3
development of an educational program that will be used 4
company-wide with our p e o p l e'.
5 So the best answer I can give you is that I think 6
we're well down that road.
Many companies are already there.
7 I know Jim's is.
And I think most of the rest of us will be we take into account your 8
there shortly.
It is 9
encouragement that we include it, and I think that it will be when you look at state 10 in most people's programs.
It is 11 laws and other things, union, differences across the country, 12 it's not something that can come about overnight.
13 MR. MILLER:
I think one of the key points to 14 remember is that EEI revised guide has just been revised in 15 August.
We committed to have.it revised by May
- 83.
16 MR. OWEN:
July.
17 MR. MILLER:
May
'85.
We review it and we committed
. 18.
to have it out by August.
I don't know whether that was to 19 you or internally, but we did.
And we got it out in August.
20 CHAIRMAN PALLADINO:
Yes, I think --
21 MR. MILLER:
It took a little doing to get it out.
22 It wasn't something that just popped up.
But as a practical 23 matter, that program is now being implemented.
And INFO has 4
24 put out now the performance objectives and criteria and 25 revised them on the basis of that guide.
$1 1
Now that guido has floxibility in it.
And I really 2
believe that's an approach that can be used by the you know 3
that there are $$ utilities.
4 CHAIRMAN PALLADINO:
No, I think it's an excellent 5
program.
6 MR. MILLER:
.One size 40 suit doesn't necessarily 7
tit everybody.
And you put a size 40 suit on you're liable to 8
find you wish it was a 44 or a 46 or a 38, depending on the 9
circumstances.
We're going to learn a lot as we implement 10 these things.
We already have at Georgia Power.
And I'll 11 assure you that chemical testing is not as simple a matter as 12 it sounds like it is.
It is a very difficult and demanding 13 task, and it requires absolute accuracy in performance and l
14 recordkeeping or it won *t stand the test in court.
15 And I'm sure that the utilities will be doing this 16 because INFO is going to be checking on them.
Now I can say 17 that we will undertake to have an answer to your question next 18 time we come up here, but we don't have it for you right now.
19 CHAIRMAN PALLADINO:
Thank you.
I think that's an 20 excellent report.
What we were trying to do was give i
21 attention to those particular parts that we think are very 22 important.
23 MR. MILLER:
Well, one of the things that really i
you know, from our and I'm not 24 concerns us is that 25 viewpoint, my own personal viewpoint, nothing is static for
52
.1 very long in this world.
One of the things you can count on 2
is change.
3 So I guess what we're asking you to do is go ahead 4'
and approve the one we've given you and we'll work on another 5
one, see what needs to be done.
We'll build in our if that one 6
experiences and see 11 we can't come up with 7
doesn't suit you, might not suit us.
And we'll find out about 8
it.
9 But we think it's a major step and we think that by
-10 making major changes, or making it proscriptive you're going 11 to endanger the process.
12 CHAIRMAN PALLADINO:
No, I don't think we're going 13 to make it more proscriptive.
We're going to indicate in 14 those two areas, it we follow through with what we said, that 15 we have expectations.
And I think it still gives you a 16 tramework in which you can operate, and it's within the spirit 17 of letting the initiative go to the industry until we see that 18 industry isn't coping with it.
19 But the evidence you've given us today shows you're 20 coping with a lot of things very well and we should work with 21 you and continue to work with you in these areas.
22 MR. MILLER:
We tried to do what we said we would do 23 as a group.
I 24 CHAIRMAN PALLADINO:
Sure.
I personally was disturbed the 25 MR. OWEN:
We i
I s
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$3 1
.other day by a court decision with respect to chemical that's another 2
testing.
And so we can 3
COMMISSIONER ROBERTS:
But that was an agent of the 4
federal government.
Now, is it within the broad parameter of, 5
you know, people's individual rights and all that?
Can you 6
make that a condition of employment?
Or is that still being
?
litigated?
8 MR. MILLER:
Well, we're under attack by a number of 9
groups right now.
And we have been successful in every court 10 case that we've tried.
Wr*ve tried several.
Except one.
We 11 did lose one, and it was o,
the basis of whether we had 12 proof.
And it had to do with possession off-site, as I 13 recall.
I'm not sure of that.
But we couldn't really prove 14 that the guy put the stuit in the vehicle, as I recall.
There 15 was a problem with that.
But I think we've been successful.
16 Unless we've been unsuccessful in the last 30 days or so, I 17 feel I would have heard about it.
18 But it is not easy, and it would depend on the 19 circumstances of the state, to some extent, where the utility.
each utility has 20 is located.
And I think you've got to be 21 to be conscious of that.
I haven *t found any lack of support 22 for a drug-free environment.
Now the way of getting there has 23 to be -- might have to be modified in different locales and 24 different relationships with unions or other working groups.
25 MR. OWEN:
We want to be very careful to make
--n
.,n e-
U 54 l'
progress and not have setbacks that put our folks in limbo for 2
long periods of time while we have said we're going' to do one 3
thing and the courts say we can't do that.
That just leaves 4
you with a work force that is terribly disturbed by not knowing where you're going.
6 So I think this is one area where we are devoted, as i
?
Jim says, to making progress.
We obviously don't want people 8
operating our plants, or in our plants who are unfit for 9
duty.
On the other hand, I do believe that it's more 10 important to make carefully thought out progress than it is to 11 try to go too tast.
12 CHAIRMAN PALLADINO:
Well, let me see i t my I-13 colleagues have questions or comments.
Tom?
14 COMMISSIONER ROBERTS:
No.
15 CHAIRMAN PALLADINO:
Jim?
16 COMMISSIONER ASSELSTINE:
Maybe just a couple of 17 broader comments.
Let me say at the outset that I share many 18 of the comments that the Chairman, and the views that the 1
19 Chairman gave to you about the usefulness of what you've 4
20 done.
I think your progress report is very good in outlining 21 the areas that you*ve been involved in and the progress that 22 you*ve made.
i 23 I sense also from your statement, particularly on 24 the engineering expertise on shift element and the fitness for 25 duty part some trustration on your part about how the process T
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- 55 1
is. working.
And I think that*s legitimato.
2 You know, we get together for these meetings every 3
tow months and you all tell us what you've been doing and 4
we're very polite and tell you how good that is.
And I get 5
the sense that in some respects we're not talking about some f
6 of the tougher. issues that are involved in -- as we try to i
?
- explore this new process for a different working arrangement 8
or relationship with the industry.
3 9
And I think we can't do it in five minutes, but wo 10 ought to think about how we can talk about that a bit more, 11 because I think you*ve got legitimate concerns.
If you 12 propose a way of doing business, you carry out your side of 13 the deal, you have a right to expect us to carry out ours.
i 14 And sometimes we don't.
Sometimes'we do different things.
15 Engineering expertise on shift and the different directions 16 that some of us are going in on that is an example.
Fitness 17 for duty is another area.
18 I think we need to talk about why we have concerns t.
19 in those areas and what can be done to deal with them.
And I 20 think it also gets into the working relationship with our 21 Staff One of the things that I hope can come out of this 22 whole process is a better working relationship between the 23 industry on the one hand and our Statt on the other.
24 We're not going to be around forever, but the 25 Stati*s here for a longer period of time and you all are here
de 1
for a longor poriod of timo.
You*vo got plants that you want 2
to operate successfully for 40 years or more in some 3
instances.
And what we ought to be working towards is 4
establishing a good working relationship between you and the 5
Staff that takes advantage of the knowledge and expertise and 6
ability that you all have, and forms an ettective working 7
relationship.
The kind of working relationship that appears 8
to exist in many other countries between the industries the 9
nuclear industry and.their regulators.
10 I,
for myself, have some concerns.
I'm seeing your 11 side of the issue and also seeing ours, about whether we ought 12 to take a look at the way we*ve approached things and see 11 13 we can refine it a bit.
In some respects I think you all may 14 be asking a bit too much of us, when I look back at a couple 15 of these areas.
16 I'm not sure that the industry saying, we're going 17 to go oil and develop an initiative in this area, pretty much 18 on o'u r own decide what our position is, then come back and 19 talk to you about it provides as much interchange or exchange.
20 of views or ideas between our Statt and you all as we need.
21 And I think that's an area we could all work on a little bit 22 more.
23 The business about no regulations versus policy 24 statements.
I*d like to talk about that a little bit more 25 too.
And let me use fitness for duty as an example.
It does i
i
57 1
soom to mo that what wo nood to know is do we have clear 2
guidance on what an ettective program -- say titness for duty 3
as an example -- would consist of that addresses all of the 4
relevant considerations.
On-site use, off-site use, chemical 5
testing, those kinds of issues.
So that everybody understands 6
what one's -- what*s expected of them and what an ettective 7
program consists of.
8 It also seems tu me that we have to have the ability 9
to obtain the information we need to assess not only the 10 ettectiveness of the overall industry program, but how each 11 utility is progressing in meeting their individual 12 commitment.
13 And finally, I think we need the information to know 14 it an individual utility is failing to meet its commitment.
15 And we need the ability to do something about that.
And not
'16 just -- Warren, in the case that you mentioned about where you 17 find somebody that is not capable of doing his or ner job in a 18 restricted area and getting those people out.
19 And I'm not persuaded quite yet that we've got that 20 in the fitness for duty area.
Those three elements that I 21 need.
And maybe what we need to do is figure out a way to 22 talk about that a bit more and get that kind of understanding 23 so that I and others who have, I think, somewhat similar 1
1 24 concerns could be satisfied.
1 l
25 But I guess what I would say as a broad comment is, l
l l
l 58 1
I think wo nood to do somo more talking, about tho approach l
2 and about some of these individual areas.
We*ve made a good 3
start.
You*re to be commended on a number of the things that 4
you've done, and I agree with what the Chairman said.
I don't 5
think the NRC acting alone could have been nearly as ettective 6
in many of these areas as using the knowledge and the 7
capabilities that exist in the industry.
8 I think we're all in agreement on what we want to 9
work towards.
I think maybe now*s a good time to talk about 10 whether we've got all the key elements and whether we're all 11 pulling together in a way that gives us the things that we 12 need and gives you all the things that you're looking for as 13 well And I just make that as sort of a general invitation or 14 otter.
I 15 MR. OWEN:
Well, we will certainly accept that I'm very pleased to hear that you think that wo 16 otter.
We 17 have made significant progress, because my own personal 18 observation is that the industry has made substantial progress 19 on a broad front.
And I think it is ditticult to talk about 20 that regulatory requirement.
21 We don't oppose regulation.
But as professionals l
l 22 and particularly when we have a chance for all 55 utilities to 23 get together and honestly discuss our situation and our 24 position, we feel obligated to oppose regulation, proscriptive and we have 25 regulation in particular where we are convinced
$9 whoro wo cro convinced 1
that rosponsibility for thoso plants 2
that regulation significantly hinders our ability to achieve 3
what we need, and that's excellence in our operation.
And 4
that's different from regulation.
5 So the two may be at conflict.
I'm not sure they 6
have to be at conflict.
I just spent three days in France of their program, with the 7
touring every part of that i
8 exception of uranium mining.
And I very deliberately set out 9
to find out what they consider their major problems to be.
10 And I tried to -- without using the word regulatory or 11 licensing to get them to say those words.
And not once in 12 three days was regulation or licensing even brought up.
And I 13 think that.was significant to me.
14 And I believe somehow or other we're going to have 15 to be successful in this country in improving that you know, it's going to be a shame 16 relationship or else I 17 to be a part of it and not see that happen, 18 COMMISSIONER ROBERTS:
Well, this is minutiae.
Let 19 me ask you, do they have a drug problem in France?
20 MR. OWEN:
They have the same drug problem that we 21
- have, I'm sure.
The degree may be different slightly, but 22 it's a worldwide societal problem.
I did not examine the 23 iltness for duty question, but was struck by the -- some 24 marked differences in their approaches to this interface then 25 we have in this country.
]
60 1
CHAIRMAN PALLADINO:
Lot mo givo Commissionor 2
Bernthal and Commissioner Zech a chance to make whatever 3
comments they'd like to make.
I'm going to have to leave in a 4
tow minutes, but I can turn the gavel over to Commissioner 5
Roberts.
6 COMMISSIONER BERNTHAL:
Yes, I*d just make the 7
comment that France may not have much to say about regulation 8
though, in fairness because for all practical purposes that*s 9
a government run program.
Now I certainly don't want to make 10 any comments about our experience in government run programs 11 versus private sector run programs in this country but it's a 12 point worth noting.
l 13 I want to make a comment or two here on three of the l
l 14 things that you mentioned, I guess.
And it we can get some 15 quick teedback on one or two of them it might be of some use 16 to'me.
17
[ Commissioner Roberts left the room.]
l f
18 COMMISSIONER BERNTHAL:
Let me, first of all, on the and as you recall, Warren, 1 l
19 question of titness for duty 20 talked with you and Jim I guess not so long ago about that i
21 issue and was somewhat troubled, trankly, to learn that there l
22 apparently was a misperception abroad among some of the I
first of all, that it 23 utilities that the Commission was 24 wasn*t going to do anything in the foreseeable future.
And 25 some of your people were apparently waiting to see what we l
l l
01 1
might do.
2 And secondly, a growing question as to whether we*d 3
stand by our commitment in the area of sticking with the 4
policy statement and policy guidance rather than issuing a 5
rule.
Well, I want to assure you that from my standpoint that I intend to stick by that 6
and I assured you then 7
agreement.
8 (Commissioner Asselstine left the room.]
9 COMMISSIONER BERNTHAL:
However, it also is worth 10 saying that I didn't feel that the policy statement drait that 11 was presented to us by the Stati did the job.
I didn't think 12 it was in the tradition that we had established in the earlier 13 policy statement on training and qualifications.
It simply 14 didn't meet that standard.
It didn't provide any broad policy 15 guidance of substance.
16 Now let me just ask you -- well, let me tell you, I 17 guess, what I personally have in mind, and you may offer a 18 reaction, if you like.
I shouldn't ask you questions when I'm 19 intending to issue a comment here.
and I would hope, 20 What I would envision is that 21 at least, is that this Commission issue a policy statement 22 that says three things.
Number one, that from the standpoint 23 of the Commission that sale, the use, the possession of drugs, 24 and certainly the use, and possession, sale of alcohol, I 25 guess, on-site is unacceptable.
And that's point one.
u a.
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Point two would bo that we considor it unaccoptablo 2
for plant personnel to be under the influence of drugs or 3
alcohol.
4 And thirdly, that each utility, each plant site would have to be able to demonstrate that they're carrying 6
through with a program that meets those broad policy 7
objectives.
And that trankly, is about all that I think we 8
need to say.
But we didn*t say it in that earlier version and 9
I think it*s important that we say it.
10 So my question for you is whether, in your judgment, 11 there is a problem with that.
I'm not sure that I'm going to 12 he very flexible on my desire, at least, for the Commission to 13 say that much as a policy.
I think all of us agree that that 14 should be a matter of policy.
15 (Commissioner Asselstine returned.]
16 COMMISSIONER BERNTHAL:
But let me know what your 17 views are as to how that will impact the programs that you've 18 set forth.
19 CHAIRMAN PALLADINO:
May I interrupt just one j
20 moment?
I had a commitment that I made before I made -- we
{
21 interjected this meeting in place.
So 11 you will excuse me, i
22 I'll bow out.
I'll turn the gavel over to Mr. Roberts.
But I 23 do want to express my sincere appreciation for your coming and i
24 discussing the programs, t
25 I agree with Commissioner Asselstine that we should r
-n
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63 1
got discussing semo of the hard nut arons.
And I wculd expect l
2 that that*s good guidance in preparing for the next meeting.
3 So it you'll excuse me, I'll leave.
4 MR. MILLER:
Thank you very much.
5 CHAIRMAN PALLADINO:
Thank you.
6
[ Chairman Palladino left the room.]
7 MR. MILLER:
I'm going to try to respond to a few of 8
these things, Mr. Bernthal.
And of course, I think we d o' 9
understand your position on that.
We've read the reports of 10 the meeting.
it 11 And I think one of our fundamental concerns is 12 might be fine.
There are some things in it that I think would I
13 cause a problem, or could cause a problem.
So I don't 14 can't see myself in a position to respond definitively to 15 everything.
I think the goal is quite good on the first two, 16 and I think it's addressed pretty well without any action on 17 your part, in the EBI guide and in the criteria.
18 The third one is be able to demonstrate.
Now you 19 didn't say demonstrate to whom.
They have to demonstrate to 20 INFO under the criteria.
That is part of the evaluation 21 process that occurs.
So that INFO over the course of its and we have not put a squeeze on them or asked 22 inspections that particular aspect up other 23 them even to move their l
l 24 than doing it in the normal course of evaluations.
That i
l 25 potential exists.
i.
64 1
Part of the problem that I am told is the prob 1cm 2
with the general rule is that it doesn't stay general very 3
long.
It gets specific.
It gets specific in the application 4
of other matters.
5 COMMISSIONER BERNTHAL:
Now we're not talking about 6
a rule though, I want to be clear.
7 MR. MILLER:
Excuse me.
i 8
COMMISSIONER BERNTHAL:
I'm talking about a policy 9
statement.
I I
10 MR. MILLER:
A policy statement.
People begin 11 11 you have to demonstrate it, they have 11 you're going to be 12 to demonstrate against criteria.
And those criteria might be 13 developed in one place, or they might be developed at six 14 ditterent levels or 10 different levels and applied l
15 differently by different regions, or even by different 16 elements of the Statt.
I 17 I'm not going to say anything more about that, l
18 except I see an element in there that would cause me l
19 problems.
I thought we addressed that through the application 20 of INPo*s evaluation program.
So I tnink that if you look at l
you look at the 21 the package -- and I'll ask Warren the same I
l 22 package, all of those things are addressed already.
All of I
23 those things are addressed.
24 COMMISSIONER BERNTHAL:
No, I don't disagree with we both 25 that.
But your responsibilities and ours, Jim, are i
I 1
~
65 l
1 havo rosponsibilitios'and in my judgmont wo havo a 2
responsibility to say what our policy is as well And you 3
have a right to hear what our policy is so that we don't go 4
through this 18 month or what remains, I guess, of the 5
two-year period and suddenly announce that, sorry, your 6
program doesn't cut it because you, haven't been able to 7
demonstrate that you've done these things.
8 It seems to me that everybody is in a better 9
position it we say at the outset what we really are going to hardly more 10 expect in a broad sense, broad language a broad sense of 11 specific than I've described here today 12 what the Commission really expects to come out of these 13 programs.
And I realize that the EEI guidelines are tar more 14 specific in detail.
And in fact, the broad guidelines that 15 I've suggested are already in the EEI guidelines.
16 But we have a responsibility here, too, I think.
17 And you should expect us to say what we think on this subject.
18 MR. OWEN:
Let me just add one comment on that 19 question of demonstration of whatever it is we're trying to 20 do.
I think that needs to be a part of this fundamental 21 discussion because I think that really is the hard nut that we 22 trequently end up with.
23 COMMISSIONER BERNTHAL:
I understand that.
24 MR. OWEN:
I would feel very comfortable on this 25 point 11 you were the one that we were demonstrating to all
66 l ' **
l 1
tho timo.
I think you undorstand
,t h a t the tact that wo 1
2 uncover the use of drugs in one of our plants does not
-3 indicate the tailure of the program, as I tried to point out l
4 in my statement.
It could, but it does not necessarily do 5
that at all.
6 In fact, anybody that sits here and says that there 7
are not drug users in my organization or yours is not facing B
reality.
So finding a problem doesn't demonstrate a tailure, 9
although I have to say that the events of the past 10 years 10 have illustrated that we're not able to cope with that very 11 well as a country or as a regulatory body, maybe as an 12 industry even.
So I think some discussion won't hurt, on that 13 point.
14 I would reiterate though that we would like to see 15 that policy statement.
It's not forever, and it can't be 16 it certainly can be changed.
We understand your goals and we 17 share those goals.
18 COMMISSIONER BERNTHAL Well, I can assure you that I hope at least that the Commission will have a policy 19 20 statement out very shortly, because I know that's one of the 21 things that you wanted.
22 One or two other points here.
I trankly don't know 23 what to say about the station blackout question that you 24 raise.
It strikes me that it's a bit late in the game.
We're 25 well down the line in what is a rather different kettle of
67 1
tish than most of the cooporativo programs that wo*vo emberkod 2
on in the past.
I certainly hear what you're saying and I*11 3
think about that in the days and weeks ahead.
4 One area, however, that I would like to simply toss it*s 5
out a suggestion, that it strikes me is an area that 6
sort of a qualitative judgment, a subjective judgment, where 7
these cooperative areas are most appropriate.
But one area 8
that seems to me you might well get in ahead of the game and 9
be very useful and do things up tront within your organization 10 that might be a long and tortuous process for this Commission 11 to do is the broad issue of site security.
12 I*ve raised this a time or two in recent visits to 13 plants.
But as you know, once again, there has been some 14 concern about security everywhere in this country, including 15 in this city itself.
But that*s something that the industry 16 may very well be able to get in ahead of the game on, and I 17 think do a very good job, and far more quickly than we 18 probably would be able to deal with it.
But that's just a 19 thought and a suggestion.
20 Last comment really.
A short one on the issue of 21 the training, accreditation and the cooperation between our 22 Statt and INFO and your people, utilities in the field.
I 23 have to say that my sense is that as the line went in that 24 famous movie, I think what we have here is a tailure to 25 communicate at some level 1
1
68
'l And I would just hope that thoro is a little bit 2
more diplomacy in communication, and I think that goes for l
3 some of our own Statt people, as well as INFO and the extent 4
.that you're involved in it.
I believe that you have made 5
great strides in the area of training and qualification.
And 6
as Jim, I think correctly suggests, we're just going to have 7
to find a way to reach this kind of working relationship, 8
because our Statt especially and you are going to have to work 9
for a long time.
10 And so I would urge everybody involved here to get 11 back to the table again and figure out what you expect, and 12 what we have to do, and how the two of us are going to tultill 13 our respective responsibilities.
That's all I have to say, 14 COMMISSIONER ZECH:
First of all, I too would like 15 to commend NUMARC for the constructive and positive 16 initiatives that they have been working on, and in some degree 17 have accomplished so far.
I think INFO is also doing an 18 outstanding job.
And I think that the combination of NUMARC 19 working with INFO is certainly contributing to the safe 20 operation of our plants and to public health and safety.
And 21 I don't think we should lose sight of that fact as we discuss
-22 some of the initiatives that you are working on.
23 On the comment made on post accreditation reviews.
l f
24 I'm not sure that I would agree that those reviews are L
25 redundant.
It seems to me we have a responsibility to ensure i
69 1
that tho training is appropriato.
And I thought that wo woro 2
going to review something like 20 percent of them to assure 3
ourselves that the accreditation process was working properly.
4 MR. MILLER:
You do have representatives on 20 percent of the visits.
So you have the opportunity.
6 The fact of the matter is, what we would suggest in 7
lieu of a post accreditation review is just put somebody on 8
every one of them.
And then you've got full participation 9
from beginning to end.
10 COMMISSIONER ZECH:
No.
You know, I disagree with 11 that, I guess, 11 you're telling us that we should not check 12 the accreditation program in the normal course of events.
It 13 seems to me that's our responsibility.
So to ask us to not be 14 involved in training evaluations is not, I don't think, 15 appropriate.
16 We must do that.
We must be assured that the 17 training is proper.
So the post accreditation visits -- 11 18 they result in, and 11 there purpose is to evaluate the 19 training, I think is a proper thing that we at the Commission.
20 have to be involved in.
We simply can't step away from 21 assuring ourselves that training is appropriate.
22 MR. OWEN:
Well, I guess I would have to, 23 Commissioner Zech, agree with Jim on the fact that involvement 24 in the process to me is a much stronger way of assuring 2d results than a post accreditation review.
Particularly in my
70 1
view, when the post accreditation review is based on different 2
criteria, is performed with untrained people, and is clearly 3
in my view-going to have the impact of diverting and 4
demotivating, and even at times demoralizing our 5
organizations.
6 And I just feel compelled as a professional to say 7
that when the regulatory process, it significantly impacts our 8
ability to get our job done, then we have to say that.
9 COMMISSIONER ZECH:
I appreciate that.
10 MR. OWEN:
And I feel this strongly based on the 11 COMMISSIONER ZECH:
I appreciate that and so do we.
12 As a professional I'll.tell you that I intend to carry out my 13 responsibilities just like you do.
And so, I'm not going to 14 back away from anything that I think imposes on public health 15 and safety.
And to me, training is about as close as 16 operations as we can come.
17 All I want to know is we're assured that the 18 training is being conducted properly, and that it is now and I 19 let me say this.
I think the accreditation process 20 know a fair amount about it.
My previous experience has been 21 heavily involved in training.
The accreditation that*s going 22 on in the industry right now, in the utilities across the 23 board is probably the most significant thing that NUMARC and 24 INPO are doing, in my judgment.
25 I have visited over 40-some plants now throughout
=
71 1
the country.
I've involved myself in training and operations 2
at every plant I've visited.
And I can tell you that there's 3
a tremendous amount of interest in the utilities in training 4'
and in accreditation and making it through a more 5
professional way to look at training.
Look at job task 6
analysis; what does the individual have to know; is he 7
properly being instructed; what are the lesson plans; who*s 8
instructing him.
All that.
The whole process is important.
9 So there's a lot going on.
And I'm impressed with 10 that.
All I'm saying is that I want to be convinced myself 11 that training continues to be improved.
And we need to know 12 that and we can't just simply take your word for that.
I didn't mean to infer any lack 13 MR. OWEN:
Let me 14 of interest or understanding of the importance of training.
I 15 certainly have that.
16 My concern is with whether or not this is the most 17 effective way for the NRC to discharge its responsibilities 18 with respect to whether or not we are getting the job done.
19 We don't oppose that.
In fact, set that up in the policy giving you the 20 statement as a very integral part of being 21 opportunity, or your Statt the opportunity to be sure that the 22 job is getting done.
23 COMMISSIONER ZECH:
We simply need to check on 24 that.
And give ourselves the confidence that the training is 25 proper.
That*s all I'm saying.
72 1
MR. MILLER:
that wo, I think -- what I would liko 2
to ask you to consider is to look at the details of the two 3
programs and see 11 you can't meet your objectives by having a or as a matter of tact, two men sometimes, most times.
4 man and I said men generically.
It could be a 5
One from NRR 6
woman.
One from NER and one from the region 11 you want to, 7
or I&E present all the way through.
8 COMMISSIONER ZECH:
I think that*s appropriate.
9 MR. MILLER:
100 p e r.c e n t.
10 COMMISSIONER ZECH:
And all I'm saying is, you know, 11 aside from the accreditation process, we should be able to go 12 to the utility and check on the training in any way we want 13 to.
14 MR. OWEN:
Yes.
And as I maybe sloughed over a 15 little too lightly in my remarks, I&E has such a program, and 16 it*s part of the process is 1 is performance and we believe is 17 18 COMMISSIONER ZECH:
Well, that*s not redundant then.
19 MR. OWEN:
No, we don *t consider that redundant at l
20 all It*s the post accreditation visits that we believe has a 21 negative impact.
And having that negative impact ought to 22 make us worry about it.
I
(
23 MR. MILLER:
What we see is a mechanism that*s a l
24 cur, which is impacting us adversely that can be done a better 25 way.
It is being done partially a better way, and by
73
'l oxpending that can solvo the problom.
2 COMMISSIONER ZECH:
If you understand what I'm 3
trying to'say as regards our responsibilities, that*s i
it seems to me that as
)
4 important to me.
Then it there's 5
tar as the post accreditation process itself we should be 6
involved in it.
1 7
MR. OWEN:
Yes.
8 COMMISSIONER ZECH:
But 11 it*s not working out as 9
such that you think they're using different guidelines or and I don't think we have untrained 10 something like that 11 people out there that you referred to either.
Perhaps we do, 10 but it we do, that's our business and we should look into it.
13 But I do think there's some way or another we must
(.
14 satisfy ourselves that the accreditation program is in place.
15 Especially at first.
And in addition, check on training any 16 time that we feel it appropriate later on.
17 MR. MILLER:
We're not arguing the point.
I think 18 what we're saying to you is, we think we see a better way.
19 COMMISSIONER ZECH:
That's fine.
20 MR. MILLER:
Which will impact us less.
21 COMMISSIONER ZECH:
I'm all for a better way, 22 MR. MILLER:
And we're going to ask you to look at j
23 it.
24 COMMISSIONER ZECH:
And then the Stati and you and 25 INFO and all those involved should grab a hold of this.
I i
l.
f 1
-,7-
-i
?
14 u*
1 think it can be solved.
And it sounds to me like it's 2
probably a matter of communications and working together on 3
it.
But we have to carry out our own responsibilities.
4 MR. OWEN:
Yes.
5 COMMISSIONER BERNTHAL:
Excuse me, I just wanted to 6
interject a question on the same subject.
I had had a e
?
question about exactly what the problem was here.
And I'm 8
wondering 11 it isn't -- let me set up a scenario and see 11 9
you agree with it.
10 I gather that what you are trying to tell us is that 11 our people accompany INFO on an accreditation review 12 presumably.
And then are you saying that either the same 13 people, or perhaps different people of ours come through a few 14 weeks later or months later.
And is the complaint that you 15 sort of sit there and say, but you all saw this just a few 16 weeks or a few months ago, and you've seen the same questions 17 answered.
Is that the problem?
18 MR. MILLER:
That's generally the thrust.
I think there are 20 I was told that in one of the 19 in one 20 percent of them in which your people sit through now.
And 21 what we're saying is, that if you want that information on all 22 of them, we-would prefer that you just send those people on 23 100 percent of them, rather than come back and look at the 24 same things.
Really they're the same things later on.
25 COMMISSIONER BERNTHAL:
I think that's a point worth
75 1
at least asking our Staff's responso on.
2 MR. MILLER:
All we're asking you to do is look at 3
it and see 11 you can't, by that mechanism, get what you need 4
without impacting us adversely.
5 COMMISSIONER BERNTHAL:
Yes, that's the point.
6 MR. MILLER:
Because as soon as we the word that 7
you're going to send five or six people down there out of one 8
of your groups up here, I can tell you that the management 9
attention quits going from everything else to get ready for 10 that visit.
11 COMMISSIONER BERNTHAL:
So the nature of the point 1
12 is that we make some attempt in getting the information -- as 13 Commissioner Zech points out, we have a duty and it's going to 14 he done one way or another.
15 MR. OWEN:
That's right.
16 COMMISSIONER BERNTHAL:
And 11 tiis is only a
[
17 question of at what time it gets done, then it seems to me I
18 there may be some flexibility.
l 19 MR. MILLER:
I was told that on one of the visits 20 they made was to a plant where you all had representation all i
it was really all the way through 21 the way, or essentially 22 the process.
The week's stay at the plant, and then at every 23 accreditation board meeting your people were present.
And I 24 understand have been.
25 So that you*ve already compiled this massive
?
76 1
information about the program.
Now wo'ro not talking about 2
the application of the program, but the program.
The 3
application then comes about later on in the process of 4
examining the training.
But in the accreditation process, you 5
can find out a lot more easily everything you need to know, we 6
think, about the process and about the ability of that group 7
to be accredited through the other process.
8 COMMISSIONER ZECH:
Well, all I'm saying i's 9
MR. MILLER:
With a lot less impact on us.
is that we need a mechanism.
10 COMMISSIONER ZECH:
11 And certainly, I think, should have a mechanism to' assure 12 ourselves that the accreditation process is working properly.
13 MR. OWEN:
We have no 14 COMMISSIONER ZECH:
That's important.
15 MR. MILLER:
No problem at all.
16 MR. OWEN:
We have no problem with that at all.
17 MR. MILLER:
And we think there's a better way and 18 we're asking you to look at it.
And that is, just send your 19 one or two people over 20 COMMISSIONER ZECH:
And I'd ask you to keep working 21 with the Statt on this because I think it can be solved.
22 MR. MILLER:
All right, sir, we'll try.
23 COMMISSIONER ZECH:
You mentioned 35 utilities, I 24 believe, have a relationship with a college / university 25 program.
And I think that's a very, very commendable thing to
2 77 l
1 do.
And I would oncourago all tho utilitios to -- I knew semo 2
are, because of their geographic location have more 3
ditticulties.
But it's certainly a commendable thing to do.
4 You should be encouraging your operational people to go on 5
with their education.
6 And that leads me to engineering expertise on 7
shift.
First of all, let me say that my experience has shown B
that the operators are doing a very fine job in our plants 9
throughout the country.
In most cases they are high school 10 graduates.
They're not college graduates.
I'm well aware of 11 that.
That doesn't mean though that we shouldn't, for the 12 long haul, try to improve the education level of our 13 operators, and all the people involved in this industry.
14 And my problem with the proposal that you brought 15 forth very specifically is, that it is my perception anyway 16 that we're backing away from the requirements we already 17 have.
We do have in place now that one individual in the is that his name, 18 control room, the shift technical advisor is required to have a college degree.
19 the STA 20 Now the new program, as I understood it, that worked a
that you presented to the Stati removed that necessity 21 out 22 for a degree.
To me, that's a step backwards.
Now I think 23 for the long haul, excepting the fact that the operators are 24 now doing a good job, I appreciate that and recognize that.
25 But for the long haul I think we should be moving towards more
a 78 l
1 education as well as better training.
2 And so that's my only problem with that.
And that's 3
a perception that I'm given with what you've presented to us, 4
and I give it to you just for what it's worth here today.
5 Fitness for duty program, we've talked enough about 6
that perhaps, but let me just say, you know, drugs is a 7
problem in our country.
We all appreciate that.
And anybody any utility executive that doesn't think he have a B
that 9
drug problem is mistaken.
So it*s something that is very 10 serious.
11 And I think the fact that the Commission has agreed 12 with NUMARC to proceed in the fitness for duty program is the 13 right thing to do, because results are what counts.
We really 14 do indeed want to make our whole industry drug-free.
That's 15 our goal, recognizing that there's difficulty involved.
16 But on the other hand, I think we're better ett 17 allowing you to supervise that program and to take charge of 18 it and to make sure it works than we are to put out a rule.
on the other hand, enforcement is a 19 On the other hand 20 problem.
And what we're saying when we do this is that 21 you will provide enforcement; strong, tough enforcement.
11 22 you do that I'll be satisfied.
If you don't, I won't.
And we'll have to have a rule, I guess.
I'm hoping 23 then I'll I think, you know, from what I can 24 you'll have a strong 25 tell, that's exactly what you're doing, the direction you're
79 I
moving in.
But I think there*s a few, perhaps loose ends on 2
that that need to be tightened up.,
3 But it we essentially give enforcement to you, then 4
you*ve really got a big responsibility.
And I would expect it 5
to be enforced.
I for one think that we, as a Commission, 11 6
you don *t do it right, have plenty of authority to do what we 7
have to do to shut *you down 11 necessary, or whatever else we 8
have to do.
But that*s a big step, and we shouldn*t have to 9
do that.
10 We should have the confidence that you're going to 11 have a program in place that takes care of any kind of a drug 12 or alcohol abuse situation that we can be confident that is 13 being enforced.
You're enforcing it.
But we simply need -- I 14 need that kind of confidence in that program.
15 In maintenance, I think maintenance in this industry 16 is making considerable progress, and I'm very encouraged by 17 tne emphasis you're giving it.
But I must confess, my 15 or 18 16 months on the Commission and that plants I*ve visited leads 19 me to believe there's much room for improvement.
20 I think maintenance as well as chemistry -- which is 21 another thing I*ve noticed is also getting attention now --
but 22 both are what I would term, rather long overdue.
And and I do think, although you told us some very good things 23 24 about maintenance, and I certainly support that.
There are 25 there is room for improvement.
Plenty of room for
f; 00 1
improvement.
2 MR. OWEN:
We acknowledge that.
3 COMMISSIONER ZECH:
And I think that the maintenance I'm just glad it's got executive 4
area is one that really 5
attention.
Because I think in the past it was considered not 6
too important, and don't fix it until it breaks down type 7
theory.
And ta me that*s really not the right way to look at 8
these complicated plants.
9 So I'm encouraged by your emphasis on maintenance.
10 One thing I would say in your maintenance program that you 11 touched on very lightly, but I would hope that would be a part 12 of your package, and that is, to emphasize cutage planning.
13 Some utilities in my judgment have very fine outage 14 planning programs.
Not all of them.
Some are not as good as 15 others.
And I think you'd be making a great contribution to 16 those utilities who perhaps have not taken this on as 17 aggressively as others to pass out the lessons learned that 18 are taking place in -- and some utilities are devoting 19 considerable resources, dollars and people to plan their not only is it dollars and cents for them, 20 outages so that 21 in my judgment, the right thing to do as far as your business if you include it with 22 concerns, but it makes the plant 23 maintenance, you're affecting safety.
You're affecting safety 24 as well as reliability.
25 So it's such a powerful tool, I think, that outage
I r
81 l
1 planning combined with maintenanco can mako a stop grado 2
improvement in professionalism in utilities across the board, 3
in my judgment.
4 MR. WOODY:
Let me give you some assurance of one of 5
the things we are doing.
INFO, of course, is gearing down 6
from their construction monitoring program they've had.
And 7
much of that resource is now being assigned to the evaluation 8
and assistance division with the specific mission of finding 9
ways to communicate improved outage planning techniques, 10 seminars.
11 They're bringing people from the industry in who 12 appear to be doing it well and picking their brain to how they 13 do it.
And we'll be trying to transfer that technology in an 14 accelerated way to the other utilities.
15 It's getting a lot of attention in the INFO area 16 just now.
17 COMMISSIONER ZECH:
Very good.
Well, let me just 18 conclude by saying what I said at the beginning is that we're 19 making a lot of progress.
And INFO and NUMARC are making a 20 significant' contribution.
And even the areas that we still 21 perhaps have some work together on, they're being focused 22 now.
To me that's a very important thing.
23 I recognize that you have very real responsibilities.
But so do we, You recognize our 24 l
t
[
25 responsibilities too.
And even though you come up with
~
0-82
.,e '
1 something as a united' front on the industry sometimes and it still has to 2
even it our Statt agrees with you on it 3
come to us.
We do have the ultimate responsibility.
4 I think all of us here deeply respect the 5
professionalism that is being put into NUMARC and INFO.
But 6
the ultimate responsibility for public health and safety, in a 7
sense, does rest with the Commission.
You are involved in it, B
of course, always from the operational standpoint.
9 So I just want to emphasize that although we've 10 tocused on some of the issues and problems, I think there's so 11 much good coming from this that we should really put that at 12 the top of the list.
NUMARC and INFO are indeed contributing 13 to public health and safety and to improved plant operation 14 across the board.
Citizens of our country are benefiting from 15 your organization and I commend you for that.
16 COMMISSIONER ROBERTS:
I think I speak for all of us 17 in thanking you for coming.
We appreciate this.
We'll 18 continue this dialogue.
And thank all your colleagues for 19 coming.
20
[Whereupon, at 11: 35 a.m.,
the commission meeting 21 was adjourned.]
22 23 24 25
(
C l
~
1 CERTIFICATE OF OFFICIAL REPORTER 2
3 4
5 This is to certify that the attached proceedings 6
before the United States Nuclear Regulatory Commission in the 7
matter of; COMMISSION MEETING e
9 Name of Proceeding:
Briefing on NUMARC Initiatives (Public Meeting) 10 11 Docket No.*
12 Place:
Washington, D.
C.
1s Date:
Wednesday, November 6, 1985.
14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
13 (Signature) ggk
[
(Typed Name of Reporter,) sw(/PanelaBriggl&-
20 l
21 22 23 Ann Riley & Associates, Ltd.
24 j
25
E
./
SCHEDULING NOTES TITLE:
BRIEFING ON NUMARC INITIATIVES SCHEDULED:
9:30 A.M., WEDNESDAY, NOVEMBER 6, 1985 (OPEN)
" DURATION:'
APPROX l-1/2 HRS TENTATIVE
- NUMARC COMMITMENTS REGARDING AGENDA:
- ENGINEERING EXPERTISE ON SHIFT
- MAINTENANCE l
- NUMARC INITIATIVES IN TECHNICAL HARDWARE AREAS
- FUTURE NRC/NUMARC INTERACTION l
SPEAKERS:
J.H. MILLER, PRESIDENT l
GEORGIA POWER COMPANY l
WARREN OWEN, EXECUTIVE VICE-PRESIDENT DUKE POWER COMPANY l
l C.O. WOODY, VICE PRESIDENT l
FLORIDA POWER AND LIGHT COMPANY
y AGENDA NUMARC MAINTENANCE INFORMATION EXCHANGE MEETING OCTOBER 16, 1985 9:00 Introductory remarks by Mr. E. Morris Howard - Director, Site Nuclear Operations 9:10 Opening remarks by Mr. C. O. Woody - Chairman NUMARC Working Croup No. 4 9:20 Presentation - Predictive Maintenance Techniques at St.Lucie Nuclear Plant - Presented by Barry Sculthorpe, Florida Power & Light 10:00 Break 10:15 Presentation - Performance Monitoring and Trending at Susquehanna Nuclear Plant - Presented by Lou 0'Neil, PFL 11:00 Presentation - Vibration Analysis Program at Zion Station -
Presented by Kurt Kofron, CECO 11:45 Discussion Period 12:00 Lunch 1:00 Presentation - Predictive / Preventive Maintenance at Crystal River Nuclear Plant - Presented by Roger Murgatroyd, FPC, and Bill Cleveland, PMA 1:45 Brief plant tour and Predictive Maintenance demonstration by Crystal River personnel 2:45 Discussion Period 3:30 Meeting Adjourn
l o,
_f
- i NUMARC/NRC Maintenance Information Exchange Meeting Attendees Name Organization L. D. O'Neil Pennsylvania Power & Light K. C. Kofron Commonwealth Edison J. D. Blosser Union Electric James J. Thomas Florida Power & Light Walt Albold Northern States Power Willard Anderson Northern States Power Don H. Gabriel Duke Power Tom A. Ippolito AE00 - NRC Gus C. Lainas NRC/DL Tom Telford Florida Power Ken Wilson Florida Power Gary Westafer Florida Power
~
Domenic B. Vassallo NRC/DL Hoyt Koon Florida Power Robert Baer NRC/IE/DEPER Lee Spessard NRC/IE/DI William H. Regan NRC/DHFS/HFEB Dan Smith Florida Power Donald S. Brinkman NRC/IE James A. Isom NRC/IE Harry Keiser Pennsylvania Power & Light Richard Grant Georgia Power James Sutphin Georgia Power Victor Benaroya NRC/NRR/DE l
J. H. Taylor AIF/B&W l
Gary Boldt Florida Power Roger Murgatroyd Florida Power E. Morris Howard Florida Power C. O. Woody Florida Power & Light Pat Beard INP0 l
i
e a
Name Organization Paul Wagner INP0 Frank Schroeder NRC/NRR Hal B. Tucker Duke Power Dave Cruden Virginia Power Hal Booher NRC Greg Cwalina NRC Gordon Shugars EPRI Don Edwards Yankee Atomic Warren Mutz Kansas Gas & Electric Hugh L. Thompson, Jr.
NRC/DL/NRR William J. Russell NRC/0HFS/DHFT Albert F. Gibson NRC 9
(.
9 Status Revised 10/25/85 ACTION PLAN FOR EETING INDUSTRY COMITMENTS MADE THROUGH NUMARC 1.
NRC PROP 05ED RULEMAKING FOR TRAINING AND QUALIFICATIONS OF CIVILIAN NUCLEAR POWER PLANT PERSONNEL COMMITMENTS Utilities will exert best efforts to have training programs for plants that are operating (as of December 31,1984) ready for accreditation by the end of 1986.
Utilities will exert best efforts to have programs for other plants ready for accreditation within two years after startup.
As the accreditation program progresses, INPO will review additional plant positions f
for possible future inclusion in the accreditation program.
Utilities will have additional training programs ready for accreditation within two years after they are added to the scope of INP0 accreditation.
Action Items Responsibility Due By Status 1.1 Conduct self-evaluations, improve Utility on-going on-going programs to meet accreditation criteria, and submit reports to INP0 in accordance with previously submitted schedules I
1.2 Continue to track utility progress INP0 on-going on-going toward accreditation i
l 1.3 Review accreditation status during INPO on-going on-going plant evalutions 1.4 Review accreditation status during INP0 on-going on-going NT0L readiness to operate reviews 1.5 Review additional plant positions INP0 12/85 for possible inclusion in the accreditation program (none will be added during first round) 1.6 Prepare additional programs for Utility to be accreditation during the second determined round. -. -.
9 Status Revised 10/25/85 2.
ENHANCING THE PERFORMANCE OF CORPORATE NUCLEAR MANAGEMENT INVOLVING THE DIRECTION AND SUPPORT OF POWER PLANT ACTIVITIES COMMITMENTS INP0 will enhance its corporate assistance program to include corporate evaluations.
Each utility will provide executive or senior level managers to participate in INP0 corporate evaluations; typically, two utility executives / managers will participate in each evaluation.
Based on experience gained in conducting corporate evaluations and input from executives and senior managers who participate in these evaluations, INPO will enhance the corporate criteria.
Action Items Responsibility Due By Status 2.1 Convert corporate assistance visits INP0 completed completed to corporate evaluations 10/84 2.2 Identify utility executives and senior INP0 completed completed managers for participation in corporate 9/84 evaluations 2.3 Make best qualified utility executives Utility on-going on-going available for one full week when request-ed to participate in corporate evaluations 2.4 Schedule utility executives and senior INP0 on-going on-going managers to participate in each INP0 corporate evaluation 2.5 Publish enhanced corporate criteria INP0 8/85 completed based on input from ad-hoc group of 8/85 utility executives and the E&A IRG 3.
LICENSED OPERATOR PERFORMANCE AND PROFESSIONALISM COMMITMENTS INP0 will include utility senior reactor operators from other utilities (typically two) on each plant evaluation team to assist in evaluating on-the-job and simulator performance of licensed operator activities, including operating team effectiveness. Their participation will contribute to the effectiveness of the evaluation process and will provide a learning opportunity for those senior reactor operators.
Each utility will make available at least one senior reactor operator per operating unit to participate in INP0 evaluations at other utilities.
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~ t Status Revised 10/25/85 Action Items Responsibility Due By Status 3.1 Develop and implement an SR0 peer INP0 completed completed evaluator program for including senior 10/84 reactor operators on each plant evaluation and NT0L assistance team 3.2 Conduct training session / workshop for INP0 completed completed SR0s selected to particip2ce in the 8/84 SRO peer evaluator program 3.3 Make best qualifled SR0s available Utility on-going on-going for three full weeks when requested to participate in plant evaluations (Each SR0 should be currently assigned to shift operations.
If an SR0 currently on shift is not available or is not the best qualifled, the SR0 selected should have recent shift experience.)
4.
READINESS OF NT0L PLANTS FOR OPERATION COMMITMENTS INP0 will visit each NTOL plant and corporate office several months prior to fuel loading to assess and enhance the staff's readiness to operate their plant. These visits will include all phases of the staff's preparations to operate and support the plant with emphasis on operator knowledge and skill and management's readiness to supervise operations. Observation of shift team effectiveness in simulator exercises will be included. The plant teams will include utility senior reactor operator (typically two); corporate teams will include utility executives and/or senior managers (typically two).
The corporate executives and senior operators involved in this effort will come from the same pool of people involved in the two previous areas (2 and 3). As a result, they will have not only current operational knowledge, but the benefit of participating in other evaluations.
Action Items Responsibility Due By Status 4.1 Conduct enhanced NTOL visits INPO on-going on-going 4.2 Review and revise corporate criteria INPO 8/85 completed to include all phases of staff 8/85 preparation for plant operation.
Status Revised 10/25/85 5.
IMPROVING THE DIAGNOSTIC ABILITIES OF SHIFT OPERATING PERSONNEL COMMITMENTS In order to ensure that all senior shift operations personnel are knowledgeable of appropriate engineering fundamentals, each utility will review the training provided to its senior operators in heat transfer, fluid flow, thermodynamics, core damage recognition and mitigation, and transient and accident analysis to ensure that operators develop and maintain a high degree of diagnostic ability.
INP0 has agreed to examine Senior Control Room Operator and Shift Supervisor l
training programs (separate from control room operator training) during plant j
evaluations with emphasis on accident diagnosis and response training.
INP0 has agreed to provide for increased emphasis on shift supervisor and SR0 training programs as part of the accreditation of licensed operator programs.
Action Items Responsibility Due By Status 5.1 Provide to INPO a description Utility 2/85 completed of existing diagnostics training 2/85 program (for use in developing guideline or good practice) 5.2 Review and revise, as necessary, INP0 2/85 completed performance objectives and criteria 2/85 to include evaluation of fundamental and practical diagnostic training during plant evaluations 5.3 Review and revise, as necessary, the INP0 2/85 completed accreditation criteria to ensure 2/85 diagnostics training is included in l
the licensed operator program content 5.4 Provide for increased emphasis on INPO 2/85 completed shift supervisor and SR0 training 2/85 programs as part of the accreditation of licensed operator programs 5.5 Review and revise, as necessary, INP0 6/85 completed licensed operator training guidelines 6/85 I
to ensure proper emphasis is placed on both fundamental and practical diagnostics training.
5.6 Develop and publish an INP0 INP0 6/85 completed Good Practice on diagnostics 6/85 training for plant operations 5.7 Train evaluators to evaluate the INP0 7/85 completed content and effectiveness of training 7/85 programs in accident diagnostics 4
Status Revised 10/25/85 k
5.8 Review adequacy of utility training Utility 9/85 on-going related to accident diagnosis that is provided to senior control room operators and shift supervisors and beg _in implementing improvements as necessary I
5.9 Complete implementation of Utility 12/85 diagnostics training 5.10 Emphasizt accident diagnosis and INP0 12/85 response training based on revised criteria during plant evaluations of senior control room operator and shift supervisor training programs 6.
UTILITf NUCLEAR MANAGEMENT EXPERIENCE DEVELOPMENT COMMITMENTS l
Individual nuclear utilities will establish and maintain nuclear management experience development programs that prepare candidates for openings in designated line operating positions.
l INP0 has agreed to review each utility's nuclear management experience development program as part of its periodic corporate evalutions.
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Action Items Responsibility Due By Status
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6.1 Form NUMARC ad-hoc group to provide NUMARC 5/85 completed a resource to utilities with questions 5/85 l
on management experience development 6.2 Review and revise, as necessary, INP0 8/85 completed the corporate evaluation performance 8/85 objectives and criteria to include evaluation of nuclear utility manage-ment experience development programs 6.3 Review and upgrade or formalize, as Utility 10/85 on-going necessary, programs designed to develop candidates for nuclear management positions 6.4 Begin reviewing nuclear utility INP0 10/85 on-going management experience development programs in all corporate evaluations _ - _ _ _ - _ - _ _ _ _ _ _ _
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Status Revised 10/25/85 7.
SHORTAGE OF QUALIFIED PERSONNEL COMMITMENTS Each utility will adopt policies and practices designed to increase the stability of its nuclear staff and the availability of qualified personnel, such as the following:
o establish a human resource management system covering personnel activities relevant to nuclear staffing o
support and encourage efforts of area educational institutions to enhance technology, engineering, and crafts training and education to increase availability of local personnel with solid basic training at the entry level o
work with area educational institutions to develop continuing educational / training programs for utility employees that are directly relevant to nuclear staff qualifications and job progress Each utility will strive toward significant reduction of contractor utilization on permanent professional and technical staff by replacement with qualified permanent personnel.
Each utility will develop plans to minimize the use of contracted personnel in permanent positions.
Each utility will, to the maximum extent practical, participate in cooperative programs designed to provide operating experience for NT0L plant staff members, thus reducing the need for utilities to hire or contract for experienced personnel from other utilities. Each NT0L utility will train its permanent staff to acquire experience, thus minimizing the need for advisors during the startup phase.
INPO has agreed, as a part of the corporate evaluation program, to review utilities
- human resource management activities that impact on nuclear organization staffing.
Action Items Responsibility Due By Status 7.1 Continue participation in industry Utility ongoing on-going program to provide experience to NT0L personnel; and continue providing SR0s to NT0L utilities for use as advisors (coordinated by CP&L for BWRs, and Duke for PWRs) 7.2 Provide shift operators with NT0L 3/85 on-going sufficient operating experience to Utility for NTOL eliminate the need for shift advisors plants (as presented to NRC on 2/24/84 and approved in Generic Letter 84-16) 7.3 Review and improve, as necessary, Utility 4/85 completed efforts designed to reduce use of 10/85 contracted personnel in permanent positions; provide report to NUMARC on effort and status Status Revised 10/25/85 7.4 Review and improve, as necessary, Utility 5/85 completed 9/85 support for and involvement with appropriate educational institu-tions; provide report to INP0 that can be shared with other utilf tfes 7.5 Review and formalize, as necessary, Utility 8/85 on-going human resource management activities related to nuclear staffing (The EEI human resource management manuals published in July and November 1983 should be useful in this effort.)
7.6 Review and revise, as necessary, the INP0 8/85 completed corporate evaluation performance 8/85 objectives and criteria to include utility human resource management activities that impact nuclear organization staffing 7.7 Train evaluators to evaluate human INP0 9/85 completed 8/85 resource management systems 7.8 Begin reviewing utilities' human INP0 10/85 on-going resource management activities' impact on nuclear organization staffing during corporate evaluations 8.
FITNESS FOR DUTY COMMITMENTS Each utility that has not already done so will implement a fitness for duty program by January 31, 1985.
As part of the plant and corporate evaluation programs, INP0 will continue to evaluate utility implementation of fitness for duty programs, note deficiencies, and l
make recommendations for improvement.
Action Items Responsibility Due By Status 8.1 Continue to evaluate utility " fitness INP0 ongoing on-going for duty" programs and make recommen-dations for their ipprovement 8.2 Add fitness for duty to plant INP0 2/85 completed 10/84 evaluation criteria 8.3 Implement a basic fitness for duty Utility 2/85 completed 2/85 program if not already done 1
Status Revised 10/25/85 8.4 Review the EEI " Guide to Effective' EEI 5/85 completed Drug and Alcohol Policy Development" (published 8/85) and provide additional guidance to i_ndustry, as necessary 8.5 Review and revise, as necessary, the INP0 8/85 completed performance objectives and criteria for 8/85 corporate evaluations to emphasize and strengthen " fitness for duty" programs 8.6 Review and upgrade as necessary the Utility 3/86 program to ensure that nuclear plant personnel are fit for duty, using the EEI Guide and INP0 corporate and plant criteria 9.
REDUCING AUTOMATIC REACTOR TRIPS COMMITMENTS Each utility will adopt practices and pol'icies designed to reduce the number of automatic reactor scrams by taking actions including the following:
o in-depth and thorough follow-up on all automatic scrams o
it.itification of root causes of all automatic scrams o
developient of action plans to correct those root causes and thereby to reduce the probability of future automatic scrams INP0 has agreed to develop and implement an industrywide program to accomplish the following:
o collect and analyze data on automatic reactor trips root causes to identify trends and opportunities for improvement o
provide feedback to utilities on industrywide reactor trip data Utilities will strive to reduce auto.natic trips to three per year per unit for calendar year 1985 for plants in commercial operation greater than three years.
This goal applies to any unplanned automatic protection system trips at any time when the reactor is critical.
INP0 has agreed to perform analyses to determine the number of reactor trips to use as a basis for long-term trip reduction goals.
Action Items Responsibility Due By Status 9.1 Conduct visits to plants that have INP0 completed completed good scram records, and issue lessons 5/85 learned to the industry; include data for first half of 1984
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Status Revised 10/25/85 9.2 Analyze available data on automatic INP0 on-going on-going reactor scrams' root causes; issue event analysis reports as appropriate 9.3 Begin evaluating post-scram proce-INP0 on-going on-going durbs during plant evaluations with (started emphasis on identification and 12/84) correction of root causes 9.4 Review and revise, as necessary INP0 plant completed the performance objectives and 2/85 2/85 criteria to emphasize evaluation of utility post-trip analysis corporate completed programs 8/85 8/85 9.5 Review and improve, as necessary, Utility 3/85 on-going activities designed to reduce automatic reactor trips, making use of information furnished by INP0 9.6 Publish 1984 reactor scrams INP0 4/85 completed industry data 5/85 9.7 Analyze and determine the number of INP0 4/85 completed reactor trips per year to use as 8/85 a long-term goal
- 10. MANAGEMENT EFFECTIVENESS COMMITMENTS Each utility will develop and promulgate goals and objectives that reflect a commitment to excellence in the operations of its nuclear plant (s).
Each utility will develop and use a nuclear plant performance indicator system to monitor the performance of its nuclear plant (s).
INP0 has agreed, as part of the corporate evaluation program, to place stronger emphasis in its evaluations on management involvement in operations and management effectiveness.
Action Items Responsibility Due By Status 10.1 Collect selected performance INP0 12/84 on-going indicator data and publish (first report published 12/84 industrywide results (averages, second report published 5/85) medians, quartiles,etc.)
10.2 Evaluate utilities' goals and INP0 on-going on-going objectives during plant and corporate evaluations
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Status Revised 10/25/85 10.3 Review and emphasize the selective INP0 on-going on-going use of plant performance indicators during corporate evaluations 10.4 Provide copies of current goals and Utility 2/85 completed objectives related to excellence in 8/85 operations to INP0 that can be shared with other utilities 10.5 Develop description of INP0 activi-INP0 3/85 completed ties that encourage management 3/85 involvement and that assess manage-ment effectiveness 10.6 Review use of plant performance Utility 4/85 completed indicators; provide to INP0 a 7/85 description of the performance indicators that are used that can be shared with other utilities 10.7 Distribute information and selected INP0 5/85 completed 5/85 examples of utility goals and objectives related to excellence in operations 10.8 Review and revise, as necessary, Utility 1/86 goals and objectives related to the pursuit of excellence in nuclear plant operations; provide a copy to INP0 that can be shared with other utilities h
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