ML20136E590
| ML20136E590 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1997 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9703130243 | |
| Download: ML20136E590 (91) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
BRIEFING ON IMPLEMENTATION OF l MAINTENANCE RULE, REVISED REGULATORY GUIDE, AND CONSEQUENCES - PUBLIC MEETING Location: Rockville, Maryland Date: Monday, March 10,1997 i
Pages: 1 - 71 ,
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- DISCLAIMER l This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on i March 10, 1997 in the Commission's office at one White Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected or edited, and it may !
contain inaccuracies.
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The transcript is intended solely for general informational purposes. As provided by 10 CFR 9.103, it is f
not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final . determination or beliefs. No pleading or other paper may be filed with the 4
Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION l 3 - - -
4 BRIEFING ON IMPLEMENTATION OF MAINTENANCE l 5 RULE, REVISED REGULATORY GUIDE, AND CONSEQUENCES 6 - - -
7 PUBLIC MEETING 8
9 Nuclear Regulatory Commission 10 One White Flint North 11 Rockville, Maryland 12 13 Monday, March 10, 1997 14 15 The Commission met in open session, pursuant to 16 notice, at 2:42 p.m., Shirley A. Jackson, Chairman, l
17 presiding. '
18 19 COMMISSIONERS PRESENT:
1 20 SHIRLEY A. JACKSON, Chairman che Commission 21 KENNETH C. ROGERS, Commiss a r ; ar 22 GRETA J. DICUS, Commissioner 23 NILS J. DIAZ, Commissioner 24 EDWARD McGAFFIGAN, JR., Commissioner 25 ANN RILEY & ASSOCIATES, LTD.
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2 1- STAFF PRESENT AND PRESENTERS' SEATED AT THE COMMISSION TABLE: .
2 JOHN C. HOYLE, Secretary of the Commission 3 KAREN D. CYR, General Counsel-4 JOE CALLAN, EDO 5 ASHOK THADANI, Associate Director for Inspection &
6 Technical Assessment, NRR 7 JEFFREY SHACKELFORD, Senior Reactor Analyst',' PRA 8 Branch 9- SAM' COLLINS, Director, NRR 10 SUZANNE BLACK,-Chief, Quality Assurance &
11 Maintenance Branch,-NRR 12 RICHARD CORREIA, Section Chief, NRR 13 i
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, 1 PROCEEDINGS 2 [2:42 p.m.]
3 CHAIRMAN JACKSON: Good afternoon, ladies and 4 gentlemen. We are pleased to have the NRC Staff here this 5 afternoon to brief the Commission.on the maintenance rule 6 implementation.
7 But before we begin, I'd like to ask for a moment i 1
8 of silence for Nelson Sievering. About two hours ago, this 9 good friend and outstanding public servant, his funeral was 10 held in Chevy Chase a few miles from here.
11 Now, many of you knew Nelson Sievering who served l 12 in many important positions with the United States ,
13 Government in the nuclear field. Most recently, he was our 14 governor to the IAEA. He served for many years at the IAEA 15 as Deputy Director General for Management.
16 His career began, like many of you, in the NRC in 17 the nuclear Navy, but he soon used his impressive technical 18 skills to advance vital United States policy objectives in 19 non-proliferation and the peaceful uses of nuclear energy, 20 first in Brussels and later with the State Department in 21 Washington.
22 I would like to salute Nelson Sievering for his 23 tremendous contribution to nuclear affairs. He fought a 24 courageous battle against the cancer which 'ventually e took 25 his life this past Thursday morning.
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1 I had an opportunity in my short tenure at NRC to .
2 in fact interface with Nelson on a number of IAEA issues, 3 and we will all miss a true gentleman and nuclear statesman 4 of the highest caliber.
5 So I would like you, before we begin, to join me 6 in a moment of silence in recognition of Nelson Sievering.
7 [A moment of silence was observed.]
8 CHAIRMAN JACKSON: Thank you.
9 As you know, the maintenance rule was issued 10 because the Commission believed that proper maintenance is 11 essential to plant safety, and that there was a clear link 12 between effective maintenance and safety as it relates to 13 the number of transients and challenges of the safety 14 system. The rule became effective in July of 1996.
15 During this meeting, the Staff will discuss the 16 status and the results of maintenance rule implementation to 17 date, the changes to regulatory guide 1.160, and any
- 18 implications that these changes have on future maintenance 19 rule implementation activities.
20 Copies of the slide presentation are available at 21 the entrances to the meeting and also available are copies 22 of SECY 97-055, Maintenance Rule Status Results, and Lessons 23 Learned, which contains a copy of regulatory guide 1.160, 24 Revision 2.
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. 1 introductory comments, Mr. Callan, please proceed.
2 MR. CALLAN: Good afternoon. With me.today at the 3 table are' Sam Collins, the Director of the Office of Nuclear 4 Reactor Regulation, on my right; and on my left is Ashok 5 Thadani, the Associate Director of Technical Assessment in 6 NRR.
7 To Sam's right, Suzanne Black, the Chief of the 8 Quality Assurance and Maintenance Branch in NRR; to her 9 right, Richard'Correia, the Chief of the Reliability and 10 Maint?nsnce Section in Suzie's branch; and then at Ashok's 11 left, Jeff Shackelford, a senior reactor analyst in the 12 Probabilistic Safety Assessment Branch. And just as an 13 aside, Jeff will be heading to Region IV next week. One of 14 my last official' acts in Region IV was to recruit him.
15 CHAIRMAN JACKSON: It was only fair.
16 MR. CALLAN: It was only fair. Region IV comes 17 out ahead in that trade, j 18' CHAIRMAN JACKSON: By the way, I would like to R
19 welcome Mr. Collins in his first appearance before the 20 Commission as Director of NRR.
21 MR. COLLINS: Thank you.
22 CHAIRMAN JACKSON: And I didn't get a chance to 23 say that kind of thing to you. You even have a real 24 nameplate. So welcome.
25 MR. CALLAN: Sam and I are used to sitting next to l
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6 1 -- each other. .
2 We last briefed the Commission on the maintenance !
3 rule status almost two years ago on July 26th, 1995. At !
4 that time, we had completed our pilot inspection program and- -
l 5 issued the Lessons Learned in new reg 1526.
6 We were also finalizing a revision to the 7 maintenance rule inspection procedure and were about to 8 begin training inspectors on the rule in preparation for the l
9 July 10th, 1996 effective date. I 10 Our presentation this afternoon is on the status !
11 of the Staff's activities regarding the maintenance rule and i 12 the results and lessons learned from our inspection efforts '
13 to date.
4 14 And'now, I'll turn the presentation over to Mr.
- 15 Thadani.
1
- 16 MR. THADANI: Thank you. Good afternoon. May I l 17- have viewgraph number 2, please? 1 1
18 [ Slide.]
19 MR. THADANI: Our intention is to cover some of 20 the background and rule requirements specifically, results !
21 of the activities that we have been involved in since the !
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- 22 last Commission brief, and implications of -- at least our -
23 ~ understanding of what the implications might be of 24' performance-based rules, how it might impac~t some other !
25 considerations. We will catch up on some of the issues that I
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. 1 develop as a result of our actions. l l
2 And then finally, we will summarize our future I i
3 actions to complete the inspections.
4 May I have the next viewgraph, please?
5 [ Slide.)
6 MR. THADANI: I thought I'd make just a few i
7 general remarks, and then the presentation by Susan Black 8 and Richard Correia will provide additional information and 9 more details. I l
10 The Chairman noted the need for the rule and some l 11 of the reasons that led to development of the maintenance 1
12 rule, so I will not repeat that.
13 Our thinking over the years has clearly evolved as I 14 to what kind of rules one should be writing. Some of the I 15 attributes that are very important, will the rule be clear, 16 that it can be and should be consistently implemented, the 17 requirements and meeting those requirements be inspectable, 18 that the rule include consideration of risk information and i
19 be performance based. l 20 A lot of attributes one would like to look for. l 21 That's quite a challenge, as we're finding out, to insure .
I 22 that these attributes are being satisfied by a given rule.
23 In fact, the maintenance rule is one of the first 24 risk-informed and performance-based regulations.
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As you 25 know, most of our recent regulations have been risk-l l
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8 1 informed. 50.62 is anticipated transients without scram, is .
2 clearly based on a fair amount of risk analysis done by the 3 Staff, and the requirements are deterministic and fairly 4 proscriptive, but those requirements are, in fact, based on 5 considerations of risk.
6 50.63 is station blackout. Once again, a similar 7 approach was followed. Because there has been considerable 8 interest in the subject matter of the importance of safety, 9 and safety related, I will note that for these regulations, 10 the Staff clearly indicated that non-safety-related 11 components would be acceptable but the focus was on 12 reliability and availability. So these areas were laid out 13 in regulatory guides in terms of what would be acceptable to 14 meet these regulations.
15 As far as the maintenance rule is concerned, risk 16 information is used in a number of ways. First, since each 17 plant has done an individual plant examination based on the 18 inspections we have done to date, each licensee has in fact 19 utilized this IPE, although that is not required by the 20 rule. But that is the practice and that was the 21 encouragement provided both in NUMARC's document as well as 22 our regulatory guide.
23- Areas where they have used the IPE was, first of 24 all, to try to understand what structures,' systems, and 25 components have higher safety significance and which ones l
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. 1 have lower safety significance. And in some cases, if the 2 licensees choose to establish goals for performance of these 3- components,.those goals could be numerical and, if 4 numerical, consistent with what was done in the IPE.
5 The third area that utilizes risk techniques is 6 assessing impact of removing any equipment out of service 7 for preveritive maintenance. You recall the issue of on-8- line maintenance where we were quite concerned about what 9 some of the practices might be, the need to pay close 10 attention to configuration control.
11 Having IPE provides an opportunity for the 12- licensees to understand impact on risk before.taking any 13 components out for preventive maintenance.
14 .In the fourth area, we are -- '
15- CHAIRMAN JACKSON: So let me just ask a question.
.6 This use of IPE in the context of the maintenance rule 17 implies, then, a high degree of competence.on our part in 18 the use of IPE for identifying systems and within the 19 configuration and control methodology for on-line 20 maintenance as opposed to specific numbers?
21 MR. THADANI: I think in relative terms, that's 22 exactly right, but I might add, it's more than the IPE 23 itself. IPE is one input.
24 The maintenance rule really -- implementation 25 calls for a panel. First, there's information coming from 1
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i 10 j-i various sources, one of them being the individual plant .
2 examination, and this interdisciplinary group takes a look 3 at the information and prioritizes it in terms of what is 4 high safety significance, what is low safety significance, 1 5 so it's more than just the use of the IPE in the -- as far 6 as the implementation is concerned. !
7 CHAIRMAN JACKSON: Mr. Shackelford looks like he 8 . wanted to say something. No?
l l 9 MR. SHACKELFORD: I can just say that we've seen a I 10 variety of approaches to using IPE, in particular in 11 assessing equipment out of service for maintenance, and it's l
12 not always quantitative. In the spirit of the risk-based, i i
13 performance-based approach, we entertained a number of l 14 approaches and we evaluate them on a case-by-case basis.
15 MR. THADANI: And the fourth area where risk 16 information is utilized is in trying to understand the !
17 unavailability due to maintenance at periodic intervals l 1
18 trying'to make sure there's some balance in terms of
.19 availability and reliability of structures, systems, and 20 components.
21 So those are areas where the implementation does ;
22 rely on risk assessments, at least as one input to those 23 decisions.
24 From a performance-based perspective, the 25 maintenance rule does give a great deal of flexibility to ANN RILEY & ASSOCIATES, LTD. !
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. 1 the licensees and, in fact, the definition of what is 2 required can vary from plant to plant because its 3 flexibility is provided, and I'll give you some examples and 4 then you'll hear some more details.
5 And this flexibility does make it challenging-for l 6 inspectors to get some assurance that the maintenance rule l J
7 is consistently implemented and enforced. This allowed i
8 flexibility leads to differences among plants in many areas.
9 Differences can be driven by plant-unique design 10 considerations, different levels in terms of some emergency 1 11 operating procedures, as well as perhaps even different i 12 definitions of system boundaries and so on, which leads to 13 the sense that the scope of the SSCs can be a variable from 14 plant to plant, and in fact is. Performance criteria can 15 vary from plant to plant.
16 If I may use an example, if one is interested in 17 focusing attention on, say, a pump, an identical pump, high-18 pressure safety injection pump or some other in these 19 plants, performance criterion could be pressure drop across j 20 the pump, could be flow, could be vibration or some other j 21 . indicator of performance of the pump.
I 22 One licensee could choose -- let's use vibration 23 as an example. One licensee could choose performance I
L 24 criterion of 5 mills vibration as a trigger' point, saying l
l 25 maybe something's wrong if that vibration level is exceeded i
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- f. 12 1 and taking further actions. . .
2 'Another licensee may use 7 mills as a trigger 3 point, as a performance criterion. Both of them are 4 perfectly okay depending on the pump performance, and the 5 pump can very likely perform its= function even beyond a 6 vibration level'of 7 mills, but there are differences. i 7 As a result of these differences, the inspectors-8 need to really understand what is the fundamental reason for 9 looking at that component, and that takes additional effort 10 by and'large.
11 This was recognized up front, and because of that, 12 we have really expended significant resources up front in 13 the development of the guidance documents.
14 When we have a performance-based regulation, the 15 intent --
at least one element of that certainly is to give 16 . licensees flexibility. It is very important to get up front 17 the. industry input in terms of guidance, criteria, f
18 understanding of. criteria and so on. It does become 19 somewhat of an iterative process, and it was, indeed, very ,
20 important to allow a fairly long time period for these 21 interactions to take place. Naturally, this iterative 22 procese also means expenditure of higher resources.
23 The training of inspectors becomes absolutely 24 eseential and we'll come back and touch on what we mean by 25 that.
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. 1 In order to make sure there is consistency in the 2 -early inspections, we make sure that there is -- all the 3 regions'were. participating in the inspection.
4 We have also a panel at NRR. Every time there are 5 issues coming up, the panel evaluates these issues and makes 6 decisions in terms of what enforcement actions, if any, are 7 to be pursued. This is, again, to make sure that issues are 8 being looked at in a consistent manner.
9 To be able to do these things, it's clear that we 10 have to expend significant resources and'we have spent a lot 11 of resources on the maintenance rule.
12 CHAIRMAN JACKSON: I think Commissioner McGaffigan 13 has a question.
14 COMMISSIONER McGAFFIGAN: I just want to break in f 15 at.some point. At the very outset, you talked about the 16 ideal rule, clear, consistently implemented, inspectable and 17 enforceable, risk-informed, performance-based.
18 You've talked about the risk-informed aspects of 19 this rule and t'he performance-based aspects of this rule so 20 far, but ti:e paper also goes in to point out that there is 21 also -- this is less than a pure risk-informed rule, because 21 of the term risk-informed, the PRA implementation plan 23 followed four years later, and so there are elements that 24 aren't risk-informed.
25 And then on the perfccmance-based, there's a lot ANN RILEY & ASSOCIATES, LTD.
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14 1 of deterministic / proscriptive elements to the rule, and .
2 there'obviously are tradeoffs. If we're headed -- if this 3
is the goal, there are tradeoffs that one faces among these l
4 various items. Resources, you've just been mentioning.
1 5
Performance-based rules, at least this one has been very, I 6 very resource i'ntensive.
7 What advice do you have to the Commission with 8 regard to balancing these various things, and should we 9 recognize that it's a spectrum, that there's no -- we have l
10 to tailor it to each circumstance? !
l 11 MR. THADANI: I think, broadly speaking, this 12 approach is quite reasonable to go forward if we recognize 13 that, until we get a lot of experience, there may be some 14 return down in later years. Having gone through this 15 ' intensive interaction up front, these intensive -- these 16 inspections are programmatic inspections. These are not 17 performance-based inspections.
18 So I think we have to wait and see, are there
' 19 other issues that are going to develop. Once we truly get 20 into inspections for cause, that is, performance criteria 21 are established, and our intention is not to get involved 22 unless the performance criteria are tripped, some trigger 23 initiates NRC involvement, that there may be a problem.
24 COMMISSIONER McGAFFIGAN: But you" have to get 25 somewhat proscriptive. You're going through this level of l
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. 1 inspections now, and I don't want to preempt the whole j 2 briefing, but you're going through this level of inspection 3 now, which is somewhat prescriptive or programmatic, in l l
4 order to establish a baseline from which you can then judge 5 later and hopefully get some resource benefits, both to the 6 Commission and to the licensee, but we're not there and we 7 won't be there for some time.
8 MR. THADANI: I think it will be difficult to l 9 predict. We need some experience to see how it comes out, l 10 what kinds of problems we run into at a future date. .;
11 But you are quite right. Some elements ultimately l
12 will end up being proscriptive. And again, let me use an ;
13 again. i '
14 I indicated that the performance criteria could be i 1
15 probabilistic, numerical, or deterministic, like I used the '
16 flows, vibration level. I 17 , Now, it's very difficult if one is looking for an 18 unreliability of, let's say, failure of 1 in 1,000 demands.
19 One needs a fair amount of data, and data in terms of 20 challenges, successes to be able to make some estimates of 21 what the underlying reliability might be.
22 And in fact, there may be yet another concern. )
23 Can we wait until that component fails before we take 24 action?
25 One of the attributes we were looking for was l
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16 1 early indication of failure so that one does not take action .
l 2 after a failure has taken place, but rather, degradation is 3 taking place, to be able to identify some trigger points in 4 terms of degradation. That necessarily, I think, has to be 5 deterministic.
1 6 So it seems to me that the approach that is being 7 utilized is a mixed approach, probabilistic in terms of, as 8 I said, looking to see where one ought to be doing more and 9 where one ought to be doing less.
10 In terms of components, structures, and systems 11 that come up in the most safety significance category, one 12 could perhaps tolerate failures, but I think in the high {
13 safety significance category, very likely you would have to 14 have a mixture of the two.
15 We'll wait and see once we get more experience in l 16 terms of our reaction, industry actions, can they maintain 17 the performance criteria, how often do they get tripped, 18 what our involvement will be. I think time will tell how 19 that playe out.
l 20 COMMISSIONER McGAFFIGAN: My only comment is, this i 21 paper, the SECY 97-055 that they're basically briefing on 1
22 today, it's very informative for somebody coming to the 23 Commission as I did six months ago in terms of laying out 24 the nuances here. i l
25 We tend to use risk-informed and performance-ANN RILEY & ASSOCIATES, LTD.
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. is based all the time, and when you get into the nuances of I
l .2 actually looking at probably the most risk-informed, i
3 performance-based rule we have, it's -- we're well into gray 4 areas. We're well into the continuum. ;
l 5 -And several pages go through the examples of where '
6 we're being less than pure if we're headed towards a pure i 7 model, which we probably won't because life is not --
8 doesn't allow us to work --
j 9 CHAIRMAN JACKSON: Purity is an ideal.
10 MR. THADANI: Yeah, it's an ideal.
11 CHAIRMAN JACKSON: Why don't you go on.
I 12 MR. THADANI: But in any case, the 20 inspections i
13 that we have conducted so far, and I want to make sure I J 14 don't overstate this, they indicate that, generally, the 15 programs that the utilities have in place are adequate.
16 That's not to say that we haven't found problems.
17 We've found problems, a range of issues, and we 18 would come back to one issue that relates to the language in 19 the rule itself in the -- what we have found in terms of the 20 industry actions in that area, and we'll talk about, is 21 there need to revise the regulation proposal, at least for 22 ~ the Commission to revise the regulation or not, but we'll 23 come back and indicate to you our thinking at this point.
24 By and large,-I think the languag'e in the rule has 25 had some impact in terms of licensees having taken that part l
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18 1 of the rule less seriously than the other parts. .
2 COMMISSIONER McGAFFIGAN: That's the configuration 3 control part?
4 MR. THADANI: That's basically the configuration 5 control on-line maintenance issue where the rule does not ,
6 say that the licensee shall have those programs. It says
- 7. they should, and so OGC will say it's very difficult to 8 enforce that part of the rule.
9 And I might as well note that we did identify --
10 in fact, Jeff was actively involved -- did identify a number 11 of concerns, and these concerns have been relayed to the 12 licensees. They appear to be receptive to those comments.
13 We intend to go back, take a look to see what's 14 actually being done and come back to the Commission with a 15 recommendation subsequent to that once we get all that 16 information together. We're not prepared at this time to 17 say we propose changing the regulation, at least at this 18 time.
19 Since the last briefing, we have trained, as I 20 said, a number of other inspectors and other Staff. Total 21 number of people -- we have three levels of training and 22 we'll go into that. The number of people we have at least 23 trained or given them some sense of what the maintenance 24 rule calls for is 900, and a fairly large number of people 25 have had fairly thorough training in the maintenance rule ANN RILEY & ASSOCIATES, LTD.
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,- 1 itself.
2 We'have developed enforcement' guidance and 3- established an enforcement panel. We work with the industry 4 to revise guidance documents, and, as I said, we have 5 completed 20 inspections so far.
6 Suzie Black will cover the rule background _and 7 then Rich Correia has been on every inspection --
8 MR. CORREIA: Half.
9 MR. THADANI: Half of them, okay -- most of the 10 inspections, is going to go through the status and some of 11 the details.
12 MS. BLACK: Thank you. As a way of background, 13 the rule was issued on July 10th, 1991 and it was to take 14 effect on July 10th, 1996. This was giving two years for 15 the guidance documents to be issued, as well as three years 16 for licensees to establish their programs and have them in 17 place by the effective date of the rule. They were to !
18 gather two cycles of data.
19 The industry guidance document is NUMARC 93-01.
20 It was -- it provides one acceptable method of implementing 21 the rule. Currently, to date, all licensees are using that 22 method.
23 Revision 2 was issued in April 1996, and that was 24 after our pilot program. It included the l'essons learned l
25 from our pilot program.
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20 1 Regulatory Guide 1.160 endorses 93-01. Revision 2 .
2 was just completed a couple weeks ago and is attached to 3 your Commission paper.
4 Our Inspection Procedure 62706 provides guidance 5 for our inspectors for the baseline inspections.
6 We.also have an Inspection Procedure 62707'which 7 is used by our residents as'part of the core program.
8 This is more what you would call performance-9 based inspection procedure. It's used to observe 10 maintenance activities as well as follow up on events.
11 Now, the maintenance rule itself, if you use the 12 guidance in 93-01 to implement it, first what you do is ]
13 determine which structure, systems, and components are 14 within the scope of the rule. I hope you won't mind if I j
15 start saying SSCs because it gets to be quite a tongue i 16 twister after the 15th time.
17 But anyway, the scope of the maintenance rule is 18 safety-related structures, systems, and components, as well 19 as some non-safety-related.
20 The first category is those that are relied on to 21 mitigate accidents or transients or used in the emergency 22 operating procedures. An example of that would be a startup j 23 feedwater pump or perhaps gas turbines.
24 The second category is those whos'e failure could 25 prevent safety-related SSCs from fulfilling their safety 1
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, 1 function. An example would be perhaps instrument error or 2 heating, ventilating, or air-conditioning systems.
3 The third category would be those whose' failures 4 could cause a reactor scram or actuation of a safety-related 5 system, for example, feedwater or circulating water.
6 CHAIRMAN JACKSON: And that would be an example of 7 perhaps what would not be in what we call safety related?
8 MS. BLACK: Right. ,
9 CHAIRMAN JACKSON: But it has safety significance 10 within the scope of this rule?
11 MS. BLACK: True, because they initiate 12 transients, and that was one of the purposes of the rule.
13 CHAIRMAN JACKSON: Right.
14 Commissioner Diaz.
15 COMMISSIONER DIAZ: I'm glad to see that the EDO 16 came with reinforcements this afternoon. I'll go back to my 17 original point this morning and I'm sure you're. ready for it
- 18 now.
19 Let's look at the definitionz of safety-related 20 system or components, and I -- you know, I am puzzled. It 21 is not a complete definition. It essentially excludes all 22 those SSCs that have no relationship to a design-basis 23 event.
24 You can say, which ones are those? Well, we used !
25 to really be very specific in detailing any SSC that was ANN RILEY & ASSOCIATES, LTD.
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22 1 part of the fuel, the primaryfcoolant, you know, pressure .
2 boundary, every one of those things that we relied.upon to 3 prevent the consequences of an accident that are outside of 4 the design basis.
5 Well, the rule, of course, specifically, I'm 6 talking about the SSCs that are inside of an envelope of a '
7 design basis and excludes the systems that are used or put 8 to use or normally used for normal and anticipated 9 transients, and I'm sorry, but I don't understand it.
10 There is something in here that is implied in the 11 word, and I'm sure it was meant.to be included, but I don't 12 see it. And it's not there anymore.
13 And, you know, you look back at Appendix B, you 14 look back at.whatever you want to, you see, you know, 15 structure -- SSCs, not repeated, that prevent or mitigate, 16 and that includes all of the systems. But in'this 17- definition, they're excluded.
18 We only are dealing with -- the scope of the rule 1
19 is dealing exclusively with systems that are inside of the i l
20 design basis accident envelope and no other system 21 structures, and we deal with those that are safety related 22 and those that are not safety related.
23 Those that are non-safety related but are required 24 to function for the function of the safety related are of 25 course what we used to call safety significant. It's just l
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23 1 _one level below. safety related, safety related being one 2 level below important to safety, and -- but it's out of 3 there. Where are they? I don't see where these systems 4 are. I'm sorry.
5 CHAIRMAN JACKSON: Let me ask a question in this 6 the generic way. Where is " safety significant" defined for 7 the_ purposes of this rule?
8 MS. BLACK: Well, that goes beyond the scope 9 issue. Safety significance goes into how you monitor, and 10 so safety -- once you get the scope of what's under the 11 rule, then you determine what's safety significant and what 12 isn't, and that's done by the expert panel that Ashok was 13 mentioning before.
14 They do use PRA insights and performance -- or 15 importance measures that are defined in 93-01, but that --
16 it doesn't relate back to what's in our "outside of scopes."
17 COMMISSIONER DIAZ: You know, it's easy to fix.
18 Now, it might take two years, but all you have get to do is, 19 when you get into the definition, are relied on to remain 20 functional during normal operations, anticipated transients, 21 and following design postulated events to insure the 22 integrity of the reactor cooler. And those are the kinds of 23 things we always said, but it doesn't say it.
24 MR. THADANI: By and large -- I may be getting 25 into this and regret it later on, but by and large --
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24 1 COMMISSIONER DIAZ: I assure ycu,.you will. .
- 2. MR. TRADANI: Safety-related struct.ures, systems, 3 and components are clearly a subset of what is important to 4 safety. Those languages appear in different regulations, as 5 you well know. Appendix B applies to safety-related 6 structures, systems, and components.
7 COMMISSIONER DIAZ: I'm sorry. I need to 8 interrupt you. Appendix B specifically goes and says those 9 systems to prevent or mitigate, and then it goes and says, 10 those systems are needed during normal operations, 11 maintenance.
12 And this doesn't say that. This specifically says 13 that those systems are only -- they are in the envelope of 14 the design basis, and we have left all the other systems
-15 out.
16 MR. THADANI: When you say "this," you mean the 17 maintenance rule?
18 COMMISSIONER DIAZ: Absolutely.
19 MR. THADANI: No. I think the maintenance rule's 4
20 scope is much broader than that and it's broken down in 21 parts. One part says all safety-related structures, 22 systems, and components. That's one part.
23 Another part is --
24 COMMISSIONER DIAZ: No , sir. Rea'd the defining 25 paragraph above it. It doesn't say that. It says, means ANN RILEY & ASSOCIATES, LTD.
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25
. 1 those safety -- those SSCs that are relied on to remain 2 functional during our --
3 CHAIRMAN JACKSON: I think that we're not going to 4 resolve this issue in this meeting. I think it is more 5 important for us to try to understand where the Staff is at 6 this stage o! the game and then we can come back and 7 consider, you know, how that is affected by lack of clarity 8 with respect to the definitions.
9 Perhaps once they've gone through it, we can have 10 a clearer understanding, so why don't you go ahead.
11 MS. BLACK: As I was saying, the scope of the j 12 maintenance rule usually is about 60 percent of plant 13 structures, systems, and components, although that can vary ,
1 14 a lot depending on how licensees do their scoping. It can 15 be as low as 50 percent and I've seen it almost 80 percent 16 at some plants. ,
1 17 Then the expert panel determines the safety 18 significance or makes that cut between high safety 19 significant and low safety significant, and that is usually 20 about 30 percent of the in-scope systems end up being high 21 safety significant.
22 The monitoring then varies depending on the safety 23 significance of the structure, system, or component. High-24 safety significant SSCs are monitored at the system or train 25 level and reliability and availability are both monitored.
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> 1 For low safety significant, normally operating 2 system, they are monitored at the plant level, monitoring
.3 scram safety system actuations or unplanned capability loss.
4 Standby systems are monitored like they were high >
5 safety significant. They're monitored at the train level 61 and at least reliability is monitored.
7 COMMISSIONER ROGERS: Excuse me. Could you just 8 . explain what you mean by monitored at the plant level?
9 MS. BLACK: Monitored at the plant level would be, 10 you would set performance criteria of no more than two 11 scrams per cycle or no more than X number of safety system 12 actuations, and then when'you reach that trigger, you would 13 go and look at shat components were causing that and monitor 14 it more closely under (a)'(1) .
15 But if you monitored all the systems under the 16 maintenance rule like you do the high safety.significant, 17 .the monitoring requirements would be pretty extensive.
18 And also,. monitoring varies with performance.
19 - Most -- using 93-01, licensces before the date of the rule 1 20 are supposed to go back and look at their data to see if 21 they meet the performance criteria.
22 You can monitor your SSCs under paragraph (a) (2) 23 but you have to demonstrate effective preventive 24 maintenance, and this you do by meeting you'r performance 25 criteria that the licensees set for themselves. And if ANN RILEY & ASSOCIATES, LTD, Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
27 I 1 these standards aren't met, then the SSCs must be monitored
.i 2- under (a) (1) or licensees must take corrective actions and 3 set. goals and monitor against those goals.
4 And the final part of the rule is the periodic 5 assessment in which the program must be assessed every j 6 refueling cycle to evaluate the overall effectiveness of 7 maintenance at the plant. And also, they must balance at 8 that point reliability and availability'to determine if 9 they're not doing too much preventive maintenance and 10 causing too much unavailability of the system.
1 11 COMMISSIONER McGAFFIGAN: Could I clarify if this 12 is the right time? The Staff has clarified to the industry j 13 that it is not a problem to be under (a) (1) .
14 MS. BLACK: Right.
15 COMMISSIONER McGAFFIGAN: There is nothing you're 16 going to hold against them if they're in paragraph (a) (1) as 17 opposed to paragraph (a) (2) ? There was apparently at the 18 outset some misgiving with regard to the staff's intentions 19 on that, but you have clarified that?
20 MS. BLACK: We hope so, and I'll do it again right 21 now. Having systems in (a) (1) is not looked upon as a 22 problem by the NRC and won't be considered in the self-23 grades and that type of thing.
24 And the other part of (a) (3) , which Ashok talked 25 about, was the part that encourages licensees, when i
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28 l' performing preventive maintenance, to assess the total plant .
2 equipment that's=out of service to determine the effect on 3 safety functions.
4 COMMISSIONER DIAZ: Excuse me. Is there a 5 difference between performance goals in (a) (1) and 6 performance criteria in (a) (2) ?
7 MS. BLACK: Yes.
8 COMMISSIONER DIAZ: Could you --
9 MS. BLACK: A lot of times the goals that are set 10 when somebody goes into (a) (1) can aave the performance 11 criteria .from (a) (2) as the goals,-but we like to see a goal 12 that is specific to the problem.
13 For instance, if there was a -- one of the plants 14 we went to had a reactor coolant pump shaft' problem and one
.15 shaft had actually broken and they were concerned that the 16 other shafts which had the same material were going to 17 perhaps fail, and so they set a goal of a certain level of 18 vibration. If they hit that level of vibration, they 19 thought there was a greater chance of that shaft breaking 20 too and so they were going to shut down and replace it.
21 So we like to see the goal specific to the 22 corrective action or the problem and have them monitor it 23 more specifically under (a) (1) than it is under (a) (2) .
24 COMMISSIONER DIAZ: So there is a" difference in 25 actually the level of specificity or the -- I ANN RILEY &. ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
29 1 MS. BLACK: Usually.
2 COMMISSIONER DIAZ: -- level of demanded safety 3 usually between --
4 MS. BLACK: We like to say usually because of the 5 flexibility in the rule, but, yes. If there hasn't been a 6 problem identified, specific corrective actions that have 7 been taken for that problem should be monitored to make sure i
8 that the problem has been corrected before you go back into 9 (a) (2) .
10 COMMISSIONER DIAZ: Have there been problems 11 between performance goals and performance criteria, or that 12 is very well understood by everybody?
13 MS. BLACK: Has there been a problem? I think 14 that during-the pilots there was a problem because we had to l
l 15 put out more clarification on that specific issue that we l
l 16 expected the goals to be more specific to the problem than 17 the performance criteria, yes. ,
1 18 And now Rich will, discuss the results of the 19 baseline inspections and the clarifications in the 20 regulatory guide.
21 MR. CORREIA: Thank you, Suzie.
22 Could you go to slide 6, please?
23 [ Slide.)
24 MR. CORREIA: As Ashok said earli'er, we have just 25 completed the 20th baseline inspection last week. Each ANN RILEY & ASSOCIATES, LTD.
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4 30 1 inspection, we're finding, is unique because of this 2 flexibility licensees are given to develop and implement 3 their program.
4 Each time the inspectors prepare, they have to 5 start fresh with a new program, the different ideas, and 6 evaluate those as to whether or not they meet the 7 regulation.
8 For examples one of the differences we have seen 9 is how licensees scope SSCs into the rule. Some have done 10 it by systems, some have done it by function, which tends to l l
11 increase the overall number. We have determined that both 12 are p,rfectly acceptable but, again, it causes you to step l I
13 back and evaluate these programs in more detail.
1 14 You can't necessarily take what you learn from a 15 previous inspection on to the next because it may be quite l 16 different. l l
17 overall, I believe licensees are doing an adequate 18 job implementing the rule. As Ashok said, we have seen 19 problems; we have issued many violations, but the violations 20 tend to be specific to a particular part of the requirement, 21 not that they did not meet a requirement.
22 For example, high safety significant SSCs should 23 be monitored against both availability and reliability. In 24 some cases, we found that one of the two was not being 25 monitored, so they established the (a) (2) programs, but how l
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. 1
. 1 they were monitoring a particular' system or group of systems l 2 varied and that was one example.
3 Two of the sites have had no violations. One site 4 had a Level 3 violation with no civil penalty, and the rest, 5 a combination of some varied Level 4 violations.
6 COMMISSIONER.DIAZ: Any program that was not {
l 7 acceptable, not adequate of the 20 that you could say -- i 8 MR. CORREIA: No. They've all implemented 9 programs, developed programs. The problems we've seen are 10 specific to a certain part of the rule.
11 l One of the problems that seems to be related to I i
12 some of these violations are that some licensees did take I 13 full advantage of the three years that the Commission gave 14 them to implement the rule. They got late' starts -- they
.I 15 all developed the programs but took longer times to actually I 16 implement them and resulted in some of the problems we've i i
l 17 seen.
18 Next slide, slide 7, please.
19 [ Slide.] I 20 MR. CORREIA: Two of the common findings we have 21 seen on these baseline inspections, one is inadequate 22 reliability performance criteria / goals. Some licensees were 23 monitoring reliability by counting the number of MPFFs, 24 which is a maintenance preventable function ~al failure, 25 failure of the function that placed the SSC in the scope of 1
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32 1 the rule. .
$ 2 Without an adequate technical basis -- for 3 example, if they chose to monitor unavailability for the 4 high-risk system, high-safety system, there may not have l 5 been a link back to the PSA assumption, for example.
6 COMMISSIONER DIAZ: So this implies that everybody 1
'7 monitored availability in an adequate fashion, because the ,
l 8 only inadequate was reliability?
- 9. MR. CORREIA: In this particular case I was citing 10 here, it related to reliability, using a number of failures 11 over a period of time without considering demands or a link
)
12- back to the PSA assumption. !
13 CHAIRMAN JACKSON: How do the inspectors judge the l 14 adequacy of reliability, performance criteria or goals, and ]
15 what role does the licensee's PRA play in setting the goals?
16 MR. CORREIA: Typically the inspector would ask, 17 what is the basis for this particular value you've chosen? I 18 In,most cases for high safety significant SSCs,.there is a ,
l 19 link back to the assumption in the PSA, and based on that 20 assumption or some sensitivity analysis that they've chosen 21 to do, the inspectors determine whether or not this I 22 performance criteria is acceptable.
23 For example, if they chose 95 percent reliability 24 for their emergency use generators, you would expect to see
~25 a reliability criteria that was equal to that, or if it was ANN RILEY & ASSOCIATES, LTD.
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different, some basis for why that difference was 2 acceptable. And it may be some type of. sensitivity analysis L
l 3 to show that perhaps 90 percent is acceptable and -- for
[
4 particular reasons.
p 5 MR. THADANI: If I may, assessing underlying 6 reliability for any given component requires a fair amount 7 of data, demand information, and'one can use estimators 8 rather than regular statistical assessments because then the j 9 need for data goes up quite significantly.
10 So like diesel generators, there may be enough 11 information on -- that includes testing and actual demands.
12 It would be' difficult if the expected reliability is much l 13 better than what we demand for emergency diesel generators.
14 For example, if it's a passive structure, one 15 would demand fairly high reliability. It wouldn't be very 16 -- one can establish numerical criterion, but it doesn't 17 really mean very much. So one has to then go back to 18 something else to assess.
19 For. example, structure may depend on, is it i l
20 anchored properly, are the bolts in place, are some of them '
21 loose, et cetera, is there a lock-down necessary?
i-22 So I think all these facets sort of have to be 23 considered as one goes forward in these inspections, 24 particularly when one looks at reliability performance l
l 25 against what was assumed in the probabilistic safety ANN RILEY & ASSOCIATES, LTD.
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34 l- 1 assessment. ,
2 I think it's going to continually be an issue we j 3 have to watch, see how well it works. l l
4 MR. CORREIA: Another area that the inspections l 5 have focused on is scoping. Certain SSCs were not included 6 in the scope of the rule, and one example we found fairly 7 commonly are non-safety-related SSCs that are relied upon to 8 mitigate accidents or transients or use the EOPs, such as 9 emergency lighting and communication systems.
'10 And one could say, well, they do not perform a 11 mitigating function, but I think history tells us that these 12 systems are very important to the -- to assure that the 13 mitigation functions are achieved for use in EOPs.
14 CHAIRMAN JACKSON: Was that an issue where the 15 guidance was not clear enough?
I 16 MR. CORREIA: I believe it was discussed during 17 the pilot programs. I think we probably didn't make it a 18 big issue at that time. It certainly was covered during all 19- the pilots, but it is important and it is in our regulatory 9 20 guide now.
21 A similar issue we've seen recently in the 22 baselines is a reluctance to identify maintenance 23 preventable functional failures. I'm not quite sure why.
24- It may be something similar to why there wa's reluctance to 25 put things in (a) (1) during the pilot programs. It may be l~
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35 ;
. l' seen as an indication of poor maintenance programs. We 2 don't view it as that. It's an indication that there's a 3 problem that needs attention and corrective actions, and 4 there's certainly no penalty on our part.
5 Structural monitoring. As we recognized during 6 the pilot program, structures cannot be monitored using 7 performance. criteria as active systems. They need more of a
- 8 condition monitoring approach.
1 9 We all agreed, though, with industry that more 10 guidance was necessary. NUMARC NEI did add guidance to 93-L 11 01, and we have added additional guidance in our reg guide 12 also to address this issue.
13 And the main problem we've seen during the
! -14 baselines is that licensees have established criteria that 15 would move something from the (a) (2) category to the (a) (1) 16 category after a failure. I think for a structure, that's 17 unacceptable, something -- the problem needs to be 18 identified as a -- if left alone, would result in a failure; 19 at that time moved to the (a) (1) category for corrective 20 action.
21 The (a) (3) safety assessments we have discussed 22 somewhat.already. All licensees are doing something. They 23 vary from using a fixed deterministic blend with PRA matrix 24 of combinations of systems that cannot be taken out of 25 service simultaneously.
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1 Some licensees have an on-line safety monitor or -
l 2 risk monitor that they use to determine what configurations ;
3 are acceptable or not. As Ashok said, they are all treating 4 the "should" in the regulation like a "shall." They are all !
5 doing something. The question comes up is, are these 1
6 weaknesses we are seeing in their methods such that we need l
l 7 to change the rule? We don't believe we do at this time. I 8 COMMISSIONER McGAFFIGAN: Could I follow up on 9 that? You don't believe you need to at this time, but on l
10 page 17, I think, of the paper, you say you're going to l l
11 continue to assess that. And what you just said, they're 12 treating the "should" as a "shall" is -- at a briefing last 13 week -- you were present -- I didn't hear that then. They 14 are doing something. They aren't doing,as much, was my 15 impression, as if the word "shall" was there rather than 16 "should."
17 And it strikes me, in the PRA implementation plan, 18 we're talking about in-service inspection and in-service 19 testing, at some point being able to do this configuration 20 control is going to be important and have consequences in 21 other areas. Isn't that the case?
22 When will we or when should we get you guys to 23 come back to us and tell us whether we need to change 24 "should" to "shall"? What's the proper tim'e period in which 25 to get that assessment out of you?
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.- 1 MR. TRADANI: Let me comment on that. I think the 2 concern is real. The issue of configuration control, on-3 line maintenance, I think is a safety significant matter.
4 We have to deal with it very carefully.
5 As Rich mentioned, we have identified problems, 6 weaknesses is what we call them, and what we're finding is L
7 that the licensees are listening to our concerns and would 8 like to take a crack and see as feedback, are they actually l 9 'taking advice and comment they're getting and implementing l
10 changes. We would like to be able to get that information 11 before coming with a proposal to change the regulation or 12 not.
l 13 As far as other activities are concerned, as you i
14 know, we've been working and using risk insights in ,
l 15 technical specification activities. South Texas is an i
16 example, have come to us and proposed changes to'their i l
17 technical specifications, to high-pressure safety injection j L
l l -18 and on-site AC power source.
L 19 We have made it a practice basically to make sure l 20 that for those cases, at least that configuration control ;
t
! 21 becomes part of the technical specification changes, that l
l 22 is, while you can grant longer outage time for some l 23 components, that is not allowed if another component that 24 might appear in a sequence is also out for preventive or 25 corrective maintenance. So that concept we're applying in
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38 1 other areas makes sure that that's built in. But that's .
2 sort of ad hoc.
3 CHAIRMAN JACKSON: So if it's ad hoc, it begs the 4 answer to his question.
5 MR. THADANI: Absolutely. What I was getting to 6 was, in the pilot studies, we're certainly looking at that 7- element. What I was saying was that even within the 8 maintenance rule itself, we need to get some level of 9 confidence tha't the utilities are actually paying close 10 attention to on-line maintenance even though the rule itself 11 says "should." That relates to enforcement activities.
-12 CHAIRMAN JACKSON: Well, but on page 17 -- now I'm 13 going to play Commissioner McGaffigan -- it says that 14 because -- this is under the conclusions, "Because the is provision in paragraph (a) (3) that states that licensees 116 should assess the impact on safety when removing equipment 17 from service is not a requirement, this provision is 18- unenforceable. But at this time the Staff doesn't believe a 19 rule change is necessary." '
20 MR. COLLINS: Chairman, I think perhaps this is l
21 just a matter of a level of expectations, and I think there '
l 22 is probably some history that goes with this wording that it 23 might behoove us to understand better.
24 But in any case, clearly, if we are going out and l
25 inspecting with the premonition that we want this done and ANN RILEY & ASSOCIATES, LTD.
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l 39
, I we're satisfied because licensnes are doing it, but at the l
l 2 same time the licensees have the option perhaps not to do L
3 it, and we need to reevaluate whether we need to change the
- 4 rule.
5 And I believe, based on the inspections that we l'
6 have, we should be able to derive a fairly good database of, 7 is this provision necessary for us to have confidence in the 8 overall implementation of the rule? And if it is, then we 9 need to be willing to make a recommendation to the 10 Commission on whether the word should be changed.
11 CHAIRMAN JACKSON: Commissioner McGaffigan.
12 COMMISSIONER McGAFFIGAN: I don't want to keep 13 beating a dead horse here, but the South Texas example is 14 one where it's sort of unique. They have an extra train or 15 an extra half a train or whatever that allows you somewhat f 16 more flexibility to get a spec change there, but even there 17 you're sort of, through the back door, requiring 18 configuration control. I think it's going to come out, I'll i
19 bet, in an in-service inspection and several of the other 20 initiatives that are underway.
l 21 So all I'm urging is that you continue to think 22 about being up front about it rather than having it come in 23 the back door. If you all think it is necessary, let's put 24 it in through the front door.
25 CHAIRMAN JACKSON: When do you anticipate having i
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l 1 all of your inspections done? .
2 MR. CORREIA: The goal is July 1998, two years to 3 do all sites.
4 COMMISSIONER ROGERS: Just before we leave this 5 dead horse, I think it's important to understand why they're 6 not doing this if they're not doing it.
7 It seems to me -- it's very puzzling to me. It 8 seems to me this is so fundamental that we better understand 9 why they're not just accepting this without any question in 10 doing it because it's -- you know, it's as plain as the nose 11 on your face how important it is.
12 So if they're not doing it, I think we ought to 13 really understand what the reasons are that they are 14 apparently not doing it, because I think they're going to be 15 as important as making the change in the rule, understanding 16 what the underlying problem is, if there is a problem.
17 MR. THADANI: I hope we're not leaving you with 18 the impression that the licensees are not doing it. I think 19 the issue is how good an evaluation are they conducting, 20 have they got the right scope when they look at, for 21 example, a matrix. Let's say they cannot take certain --
22 two trains out simultaneously, one from system A and one 23 from system B.
24 COMMISSIONER ROGERS: I don't want to go on with 25 this, but if it's -- for this purpose, if it's an incomplete ANN RILEY & ASSOCIATES, LTD.
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l 41
. . 1 and inadequate job, it might as well not be done at all. I l
2 mean, you've got to do it right, and so I think that the 4
r 3 notion that something less than an adequate job is even J
4 contemplatable is troublesome to me. I think that somehow
- 5 we have to get at that. i 4
6 COMMISSIONER DIAZ: If I could beat on the dead 7 horse --
) 8 CHAIRMAN JACKSON: Well --
9 COMMISSIONER ROGERS:
[ Put a saddle on it and ride
- 10 it.
i 11 COMMISSIONER DIAZ: I understood from the coraments 4
l 12 that, you know -- and I -- obviously it is true, that the i
13 issue of reliability is more complex and requires much more 4 14 data, and obviously that's true.
c !
15 However, the issue of availability should be i
- 16 simpler and therefore more enforceable, and I think that I 17 definitely should give us the line saying we will not 18 require you to start looking at reliability up to the last 19 significant place, but we do require that you maintain a 20 configuration that operates under conditions.
21 Is that correct?
22 MR. THADANI: Yes.
23 CHAIRMAN JACKSON: Do you know any of the "why's"?
24 COMMISSIONER McGAFFIGAN: Why the""shall" and the 25 "should"?
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42 1 CHAIRMAN JACKSON: No. .
2 COMMISSIONER ROGERS: No. Why an inadequate job.
3' MR. SHACKELFORD: I don't think we've found any 4
4 that are inadequate at this point. We found a wide variety 5 of what I should call weaknesses. As I said, they go from 6 --
risk monitor for a licensee is really an endeavor to 7 monitor their entire plant on a real-time basis right down ,
8 to what you might call business as usual.
9 I think licensees have always assessed the impact 10 of taking equipment out for maintenance. The control room 11 SRO, that's part of his job description, but we don't 12 necessarily think that that's probably the most 13 comprehensive way to do it, given the tools that they may 14 have now. So we are looking harder at that than we may have 15 in the past. '
16 The maintenance rule requires-them to look at all 17 equipment out of maintenance, not just safety significant,-
18 frontline systems, and those are the types of weaknesses 19 that we're pointing out, that while you still have to keep 20 track of the tech spec outages, you also need to look at 21 these other systems that may challenge your plant.
22 And those are really the issues we're talking 23 about here. And I think the industry has been receptive to 24 that. They haven't necessarily been happy to hear our 25 comments, but I don't think we've had a disagreement that ANN RILEY &' ASSOCIATES, LTD.
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43
. 1 those are important issues to address, 2 CHAIRMAN JACKSON: In saying that you don't hear 3 disagreement that these are important issues to address, 4 does that mean, then, that you see a change?
5 MR. SHACKELFORD: As I said, I don't think you'd 6 find a single utility who would say we're not going to do 7 assessments before we take the equipment out of service. I 8 think they will all tell you they've always done it and they l 9 will continue to do so.
10 The exact nature by which they do them and the 11 level of specificity I think is what the issue is, and 12 that's where the weaknesses which we have identified are 13 coming into play. l 14 CHAIRMAN JACKSON: Why don't you go on.
15 MR. CORREIA: Slide 8, please.
16 [ Slide.]
17 MR. CORREIA: I mentioned earlier enforcement on 18 11 of the 20 inspections are complete. Two had no 19 violations at all. One had a Severity Level III but no 20 civil penalty, and eight had one or multiple Severity Level-21 IV violations, and the remaining inspection findings are 22 still under Staff evaluation.
23 CHAIRMAN JACKSON: Let me ask you a question.
24 Have any of the violations or enforcement a'ctions been 25 related to what you might call the performance aspect of the l
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i 2 44 1 rule? .
]
1 2 MR. CORREIA: I would say not as many as more of 3 the programmatic problems that we've seen.
4 CRAIRMAN JACKSON: Let me ask you this second
'5 question. Can we make a statement yet as to whether 6 maintenance, in fact, or equipment performance ~has improved 7 since the implementation of the rule? Becau'se in the end, 8 that's what we want, right?
9 MR. CORREIA: Right. I think several plants have 10- told me -- managers have told me that they're much more 11 aware of equipment performance now than they were 12- previously.
13 CHAIRMAN JACKSON: Well, I guess I'm asking a 14 different question.
15 Do we have an inspection program that does, in 16 fact, look at maintenance, and it looks at various things in 17 terms of equipment failures, whatever? 'Have we done a 18 marriage to know, or just in general, do we see any '
19 improvement in equipment performance?
20 MR. CORREI3: I think the latest data from AEOD 21 still shows a high number of reactor scrams initiated from a 22 balance of plant, which is one of the main reasons that the 23 Commission wrote the rule. So in that aspect, I guess we 24 have not seen a change. ,
25 CHAIRMAN JACKSON: So in the end, performance is i
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. 1 as performance does, my favorite phraseology. And the l
2 question is, if we still don't see any change, what are we 3 getting?
4 MS. BLACK: I think one of the benefits we're 5 getting is the understanding of unavailability that wasn't 6 there before, either in non-tech spec systems or tech spec 7 systems that the licensees were in and out of, but never 8 tracked total unavailability throughout the year.
l 9 MR. THADANI: Also, I might note that it's L 10 probably going to take quite some time before we can get I 11 objective information to see if there is a big difference.
l l
12 How we can send out the awareness is the issue.
13 CHAIRMAN JACKSON: So the awareness has increased l
14 but we don't know yet?
15 MR. THADANI: And I think it will take quite some 16 time before we will know with objective information.
17 CHAIRMAN JACKSON: All right, j
! i l 18 MR. CORREIA: Slide 9, please.
l 19 (Slide.]
l 20 MR. CORREIA: Slides 9 and 10 contain the 21 clarifications we've made to regulatory guide 1.160. The 22 ones I have listed on the slide are the ones we feel are the l 23 more significant ones, and I'd like to review those. And 24 then if the Commission would like to talk about any on slide 25 10, we can do that also, if that's acceptable.
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46 1 Regulatory guide -- Rev. 2 to regulatory guide .
2 1.160 endorses NUMARC 93-01, Rev. 2, with clarifications.
3 For example, one of the clarifications we have 4 made are those non-safety-related SSCs whose failure could 5 cause a scram. We've tried to clarify when one of those i
6 systems should be in the scope of the rule, to say that if 7 it has failed at a particular site and caused the scram, 8 obviously it's in the scope.
9 Then, if it has caused a problem at a similarly 10 configured plant, the licensee should seriously look at 11 whether or not that system in his plant or her plant should 12 be within the scope of the rule.
13 Or if there's an existing analysis that said, if 14 this system fails, it will result in a scram, that would 15 place that within the scope of the rule.
16 I talked earlier about certain SSCs that are used 17 in EOPs and they're used to mitigate accidents and 18 transients, such as emergency lighting and communications 19 are very important, even though they directly are not used 20 to mitigate the action functions.
21 We talked before about MPFFs as a reliability 22 indicator. We have now concluded on a regulatory guide that 23 this is acceptable provided that there is a sound technical 24 basis for whatever number of MPFFs the licensee chooses as a 25 means of monitoring' reliability.
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- , 1 Structures, we touched on earlier. We've added i
2 some additional guidance in our reg guide, in' addition to l 3 What changes were made to 93-01, to say that structures
- 4 should be monitored differently than active mechanical and 5- electrical systems and that condition is a better process or 6 method of monitoring the condition of structures, and that l
7 actions need to be taken to correct the problem before 8 failure occurs, if there should be an indication of a
'9 problem, corrective action taken and placed in (a) (1) with 10 goals in monitoring before a failure.
11 COMMISSIONER DIAZ: Excuse me. Could you give me 12 an example of a non-safety-related SSC that is relied upon 13 to mitigate accidents?
l L
14 MR. CORREIA: That could be -- feedwater systems 15 or condensate systems typically are non-safety related.
16 They could be used as a core cooling system. I think the 17 condensate system was the non-safety system at Saint Brown's 18 Ferry when they had their fire. That's one example that 19 comes to mind.
20 COMMISSIONER DIAZ: And we classify them as a non-21 safety system'because it's not in the Q list? Is that --
22 MR. CORREIA: It doesn't meet the definition of-23 .50.65 for safety related, yes.
24 . COMMISSIONER DIAZ: Is that the clear interface?
25 Is it in the Q list or it's not?.
l l
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4 48 1 MR. CORREIA: Quite often, Q lists contain more .
2 than just safety-related SSCs. Most licensees are fairly 3 conservative with the Q lists.
4 Normally operating SSCs of low safety 5 significance, the clarifications to the reg guide.
6 Typic. ally these systems are monitored at the plant level, 7 again, such things as plant scrams. Some licensees are only 8 monitoring against automatic scrams. We wanted to clarify 9 that unplanned manual scrams are just as important also and 10 should be monitored for these types of systems.
.11 Are there any particular items on slide 10?
12 COMMISSIONER DIAZ. Number one.
13 MR. CORREIA: Number one, safety-significance 14 categorization process. The only point we wanted to make l 15 here is that the process used to implement the maintenance 16 rule, to categorize SSCs, is either high or low safety 17 significance. It's specific to the maintenance rule and 18 doesn't necessarily -- or cannot necessarily be used in i
19 other applications, for example, greater QA or ISI or IST 20 approaches.
21 We do recognize, though, that we are doing a lot 22 of work in this area and if at a future time there is ,
l 23 information that is developed in the SRPs or the reg guides 24 for the PRA implementation plan that could be beneficial, we 25 would again revise the reg guide to reflect that.
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49 1
, 1 COMMISSIONER ROGERS: It's really not a question, '
2 but it's an observation, that is that in this definition of '
3 maintenance, we are focusing very much on what we regard as 4 related. I don't want to use the terminology incorrectly, 5 but it has some connection with safety. Let's put it that 6 way.
7 And I wonder whether you've seen any effect or you 8 think there might be any effect as the plant focuses its 9 resources this way, on plant housekeeping, whether, for 10 example, the place starts to look worn out, even though the 11 important equipment is in good shape. I'm not going to 12 comment on whether that's good or bad.
13 I think it may relate somewhat to a general state 14 of attitude and safety culture, but I wonder if that is 15 something that one might expect to happen in the future as a 16 result of our move in this direction and the economic 17 stresses that are coming to bear on licensees.
18 MR. CORREIA: Certainly material condition is one 19 of the items that all baseline inspections cover, and I 20 think, to date, generally the reports are fairly good, that 21 material condition is generally good, that I think there 22 have been certain cases that on a certain particular piece 23 of equipment, that it may be less than desirable. But it 24 may be for a very good reason. Perhaps they just finished a 25 major overhaul and haven't had a chance to bring it back up ANN RILEY & ASSOCIATES, LTD.
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50 1 to some specification. .
2 I really don't know if we will see changes in that 3 area because of the stresses you mentioned.
4 COMMISSIONER ROGERS: I wouldn't be surprised. I 5 think we may have to decide what our position is in that 6 case, if any.
7 CHAIRMAN JACKSON: How do we deal with the issue 8 of living PRAs and their effect on categorization of systems 9 and performance requirements? You know what I mean when I 10 say living PRAs?
11 MR. THADANI: Yes, yes. That is one of the 12 elements in the various pilots that we're working on, and 13 the concern we have -- first of all, as one makes changes, 14 one needs to keep track of those changes and needs to know 15 on a real-time basis the plant as is versus reflection of 16 the study itself.
17 So we are looking at finding ways for those 18 licensees who want to use these techniques to make changes 19 or seek relief in some areas, that they do need to keep 20 track of those changes, that that would basically be a 21 living PRA, so that at any given time, we know the PRA does 22 reflect the plant as is rather than what it might have been 23 Jike six years earlier.
24 So that's the path we're on as pa'rt of the PRA 25 implementation plan.
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,. 1 In this case, they have to make an assessment -- I l
2 believe it's every two years -- to see what the plant 3 performance was and, in fact, whether it might change their 4 initial judgments. They have to revise their earlier 5 decisions. They do have to make an overall assessment, I 6 believe, every two years for the program.
7 CHAIRMAN JACKSON: And that includes looking at an
~
8 updated risk profile? I l
9 MR. SHACKELFORD: We have been looking at that 10 issue in the inspections. We've asked that question. Those l 11 licensees are using the PRA to derive performance criteria 12 or ranking.
1 13 We typically ask them questions about their plans 14 to update and go even further about how their current PRA, i l i 15 what's the time frame of the data in the model that they're !
16 using for that.
17 In those situations where we find problems, we l 18 certainly. document them. We're not enforcing a living PRA l
19 requirement on anyone, of course, but I think the biggest 20 issue in that area we've seen are a lot of licensees may be l
21 using what you might call outdated data as opposed to 22 outdated models.
l 23 I mean, they pretty much reflect the configuration 24 of the plant, but they may be using generic' data or data 25 that hasn't been updated in several years.
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52 1 In those cases, on a case-by-case basis, where we .
2 think there might be a problem, we'll make challenges on a 3 specific point, but that is part of the inspection process.
4 MR. THADANI: We would expect, as, for example, if 5 new information comes out -- and it could be NRC issues 6 generic communication because we learn something new --
7 clearly those factors have to be considered by the utility 8 in the assessment of its program.
9 CHAIRMAN JACKSON: You were asking about page 10.
10 Tell me about MPPFs related to the design deficiencies.
11 What do you mean by this? Can you give an example?
12 MR. CORREIA: As a point of clarification, that 13 should have been MPFF. I apologize.
14 The issue came up during the pilots, I believe, 15 where licensees, for economic reasons, had decided not to 16 change the design that was -- of a piece of equipment that 17 was giving them performance problems.
18 Understanding that, we said our expectation was, 19 you should enhance your preventive maintenance program as 20 much as reasonable to assure that future failures don't 21 occur, increased frequency of tests or surveillances or changes to consumables or whatever, but just to live with a 1
22 l I
23 bad design and walk away with it without some type of change l 24 to the maintenance program we didn't think'was acceptable.
25 We just wanted to clarify that point in the regulatory 1 I
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i 53
, 1 -guide.
2 COMMISSIONER DIAZ: Number of SSCs in category 3 (a) (1) ?
l
-4 MR. CORREIA: That's what Suzie mentioned earlier.
4 5 During the pilots, for some reason, some licensees felt that 4
6 (a) (1) was a penalty box. It might trigger some huge NRC 7 inspection if they had too many SSCs in (a) (1) . We just 8 want to make sure everyone understands that that is not the 9 case, (a) (1) is a requirement. As long as they meet the 10 requirements, there's no problem.
11 Any others?
12 Slide 11, please.
13 [ Slide.)
14 MR. CORREIA: I believe we've touched on all of 15 these items. Certainly Ashok did. We mentioned 16 communications was very critical during the developing 17 phases, and we still believe it is today. We continue to 18 believe that open and effective communications with the 19 industry and the public is essential to the success of i
20 implementing the rule.
21 Pilot programs, we believe, are very important.
22 We learned an awful lot, and it was also easier to do during 23 a non-enforceable environment. It was easy to discuss 24 issues openly with licensees.
25 Ashok mentioned that guidance was developed ANN RILEY & ASSOCIATES, LTD.
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54 1 through the iterative process. The industry developed 93- .
2 01. We discussed it over a two-year period. We did the l 3 pilot programs; it changed somewhat..again. We revised our i 1
4 regulatory guide'twice since then, all through information 5 that we gathered during each phase of the implementation of 6 the rule.
7 Ashok mentioned training. Also, we've trained in 8 varying degrees over 900 people in the NRC on the 9 maintenance rule.
10 COMMISSIONER DIAZ: Is that -- do you have a 11 breakdown whether that's regions or quarters?
1 12 MR. CORREIA: By regions, I don't. By far, most 13 of the inspectors are in the regions. I think we've trained 14 over 130 inspectors that do the baseline inspections, close 15 to 400 other inspectors that may have some involvement with 16 the rule, like resident inspectors, though I have to admit, 17 Region IV did have every resident -- or one resident at 18 every site take the full three-day course, and the rest are 19 NRR Staff that may have some dealing with the maintenance
. 20 rule.
21 Ashok mentioned earlier that we believe the rule 22 can be consistently inspected and enforced through the 23 communications that we've had with the regions and licensees 24 and to the enforcement panel that's established.
25 Resource requirements have been high through the ANN RILEY & ASSOCIATES, LTD.
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55
. 1 . iterative process of developing guidance, inspection 1 1 2 procedures, meetings with the public, workshops, and what ;
3 we're doing on the baselines to maintain oversight.
4 CHAIRMAN JACKSON: Do you expect that to continue 5 at that level?
l l 6 MR. CORREIA: I believe until the baseline --
l l 7 basalines are complete, it will. They will, 1
I l 8 MR.~ COLLINS: Madam Chairman, I think it's l
9 important to note here that we're dealing with history also, i
10 This is one'of.the first inspections of this type. We're 1
- 11 taking 30 to 40 years of agency momentum as far as types of' 12 inspections, qualification of inspectors, enforcement 13 approach, and we're trying to turn the corner with the 14 initial inspection here, and it takes some time. i 15 It takes some orientation; it takes some t
l 16 recalibration and sorting through the results and ;
17 understanding where we are, and adjustments, as indicated by l 18 the revisions to the guidance. )
l 19 So I would anticipate, if we continue on this type l
l- 20 of track, that the initial resources as far as the l
21 development might be somewhat the same, maybe even a little 22 less, but the actual practitioner application and the 23 thought process that it takes to shift gears from l 24 deterministic to performance-based will be ' easier as to I 25 generations of inspections continue on.
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l 56 1 There will always be, in our mind, initially a .
l 2 programmatic inspection for the application of the rule, and 3 any more performance-based routine follow-up, typically by 4 the residents. In the maintenance rule here, it is more 5 event driven than it is programmatic.
6 The real insights to the maintenance rule, I l 7 believe, will be forthcoming as a result of challenges to 8 the plant that result from component malfunctions, and using 9 the programmatic inspections, we'll go out and take that cut 10 and look back into the rule based on a malfunction and
- 11 determine whether the rule is being applied appropriately.
l l 12 That will be the real insights into the long-term 13 application of the rule.
14 COMMISSIONER ROGERS: Well, it also may be that 15 you want to look and see what the effect is on the license l 16 renewal activities that we get into, that this may be partly l 17 an investment in a sense, unrecognized at this point, but as
! 18 licensees come forward with applications for license 19 renewal, it may be that this investment will pay off in that l 20 area.
21 MR. THADANI: Absolutely. In fact, for past 22 structures and so on, this becomes critical for license 23 renewal activities, and that's why the procedures that Rich I l
l 24 mentioned earlier in terms of. guidance, we have tried to i
1
! 25 make sure that the guidance we're using here would be l 1
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57 1 sufficient even when we get to license renewal activities so 2 we don't have to come up with yet different guidance to look 3 ,
at the same structures.
4 So you are quite right, and our internal 5 activities we have integrated that way.
6 COMMISSIONER DICUS: Mr. Collins may have -- may 7 have answered this question, but it is on the resource 8 commitments. I want to pose the question in terms of future 9 resource commitments, particularly in light of the fact that 10 we may well continue down this road of looking at 11 regulations that are risk-informed, performance-based and 12 new kinds of regulations that may be written.
13 And in the lessons learned here, and particularly --
14 -- and it's referenced a bit I think in the paper itself, 15 are we to assume that future regulations of this nature 16 might also be very resource intensive, certainly on the 17 front end of those regulations, or are there lessons learned 18 that perhaps future regulations might not have to be so 19 resource intensive on the front end of the regulation?
20 I raise the issue in terms of long-term budgetary 21 planning, because if this is a course that the Commission 22 may well be going down, we have to continue -- concern 23 ourselves with the year '99 and 2000 and so forth budgets, '
24 are we going to need to consider these thin'gs as well?
25 CHAIRMAN JACKSON: Before you answer it, I'd like l
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- 1. for you to answer it in the context of what kind of resource ,
i
-2 requirements go into our initial implementation of any new 3 rule that's of significance. ,
4 MR. THADANI: I'll give you a judgment. It seems 5 to me that the maintenance rule is quite broad. It's our 6 first -- by and large, it's our first truly performance-7 based rule, and therefore, probably we have had to expend l 8 more resources than we might have for future changes in the 9' regulations.
l 10 But I think the real issue is the degree of l
l 1
11 increase in resources is going to depend on the type of rule 12 we have in front of us. This affects the whole plant and 13 it's pretty complex. If it's a fairly simple rule, I don't 14 know that there would be much impact.
15 But if we were to, let's say, revamp fire 16 protection radically to go to performance-based, I would 17- anticipate that, again, the initial resource commitments 18 could be pretty high, because the idea behind these 19 approaches is: let's agree on what kind of a program makes 20 sense up front and then we'll walk away.
21 The agency basically would say, okay, we will not
~
22 get involved unless there are some signal indicators that 23 there may be a problem, and then we will react to that.
24 CHAIRMAN JACKSON: You don't really mean we're 25 going to walk away?
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59 l
. 1 MR. COLLINS: No, we don't..
2 -MR. THADANI: What I meant was, we have placed our 3 residence in other people watching. When I say walk away, a 4 significant intervention on our part would come if we-have '
5 reason to believe that there may be a problem. l l
6 It seems to me that it is very important that the '
7 ground rules be agreed to up front and both sides need to 8 understand, and because there is so much -- because the 9 whole idea is to provide flexibility, one-should have some l 1
10 agreement on what does that really mean up-front. i 11 So it seems to me that one would have to'do early 12 performance -- for performance-based rules, programmatic 1
13 inspections very likely would have to be done. !
1 14 And if I use this experience, then that says you-15 probably have to spend more resources. How much more, I 16 think, is going to be determined by the scope and range of l 17 activity we're talking about. l 18 But I think it does mean, up front, an increased j 19 resource commitment.
.20 CHAIRMAN JACKSON: But isn't it also a function of 21 the expertise of the Staff going in?
22 MR. THADANI: Definitely. And because the 23 concepts utilized are pretty multidisciplinary -- and that 24 .means you'have to get all those resources together and go 25 take a look, and it's -- quite frankly, it's been very tough ANN RILEY & ASSOCIATES, LTD.
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60 1 on us to support these inspections. .
2 The gentleman sitting to my left can tell you how 3 often we called him, because the PRA resources are tight.
4 There's no question. We have a lot of activities that are 5 going on, and we.had to beg, borrow, and do everything we ,
6 could to support these inspections, and I anticipate similar 7 challenges if we have major rules that are revised.
8 MR. COLLINS: Really, I think the most efficient i
9 way is very similar to the way-the maintenance rule was 10 handled in that there's.a performance-based, fairly brief 11 rule with stated goals -- we can argue about the one, and 12 that's our last bullet -- that the industry provides some 13 measure of input as far as the guidelines.for application.
14 And that's recognized by the staff and in fact 15 endorsed-by the Staff, and that's a fairly clear-cut process 16 which I think in the future we should continue to embrace l 17 whenever it's appropriate.
I
- 18 The resources, to my mind, come in when you're-i 19 trying to inspect a performance-based rule at each site, 20 where each site has options for implementation, have perhaps 21 very different structures and resources available to them, 22 so you cannot go out and do the same inspection on each 23 site.
24 So to gain confidence that the performance-based 25 rule does have enough of a platform for us to then turn to 1
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61
+
, 1 measure only performance of that rule, we have to do a very 2 in-depth, very focused inspection on each site, and that's 3 difficult.
4 ,I don't see that changing very much. I think we 5 still have to do those types of inspections on the 6 performance-based rule.
7 The payback, hopefully, is on the back end of the I 8 process where we free up our on-site resources to look at 9 other issues or to redirect them in other areas, and then we' I 10 allow the licensees in their performance-based realm to 11 focus on what they believe is important, not what the agency 1
12 --
l 13 CHAIRMAN JACKSON: -- has agreed with them is '
14 important? I l
15 MR. COLLINS: Right. I 16 CHAIRMAN JACKSON: So how do you measure those?
17 MR._ COLLINS: I think that's a good question.
18 It's a fair question that was stated, Madam Chairman, and I l- 19 wrote it down. We have to be able over a period of time to 20 measure that this rule has met the mutual goals that warrant 21 the type of investment that was made. And we owe you that 22 answer.
I 23 CHAIRMAN JACKSON: Anything else?
24 MR. CORREIA: The last item I think we've talked 25 about quite a bit, but from an enforcement perspective, the l
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62 F 1 rules must only contain recuirements. . 1 2 The last slide, please, number 12.
3 CHAIRMAN JACKSON: I'm confused. Is this new 4 information? You say rules should only.contain 5 requirements.
6 MR. CORREIA: We're referring to the (a) (3) part 7 of the rule that says they should do safety assessments 8 versus shall do safety assessments.
9 MR. COLLINS: We covered it earlier in the 10 discussion.
11 -CHAIRMAN JACKSON: Not exhortations but 12 requirements?
13 MR. CORREIA: Yes.
14 MR. THADANI: There's something in the rule, but 15 the rule itself says should be done, but we're having a hard 16 time enforcing it, so it's the language in the rule.
17 CHAIRMAN JACKSON: I think there's a lesson there 18 in terms of, A, what gets propagated to the Commission in 19 terms of a proposed rule, and B, the scrutiny the Commission 20 gives_to a rule and what it signs off on or may, in fact, 21 modify, okay, to make an exhortation as opposed to a 22 requirement. So I think there's a lesson for all concerned 23 in that regard.
24 [ Slide.)
25 MR. CORREIA: Slide 12, status of future ANN RILEY & ASSOCIATES, LTD.
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r 63
. 1 activities we're working on or planning on working on.
2 Again, we plan to -- our goal is to complete.all baseline 3 inspections by July 1998.
4 We have drafted an information notice based on 5 lessons we've learned from the baseline so far. :We expect 6 that to be issued next month, and, again, communicate to the 7 industry what we found,'what kind of information they should 8 be considering.
9 We will now revise our baseline inspection 10 procedure to reflect changes to our regulatory guide. If we i
11 keep it current, we think we can have that done by this l
12 July.
13 We are also working on a Home Page to share with 14 industry, maintenance rule documents and information-that -
15 are already publicly available but haven't been easily ;
16 accessible through the Internet. Our goal is to have that 17 completed by this June.
18 The Office of Enforcement plans to revise the EGM 1
I
'19 that we_are currently using for the maintenance rule. We 1 20 have discussed with them options on how soon that could be 21 done. We basically feel we have enough experience now with 22 the baselines to go ahead and clarify some of the guidance 23 that's in'the EGM at this time.
24 We are also working with the Technical Training
'1 25 Division at TTC to transfer the training program from NRR i-
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64 1 now to TTD for them to -- for future training. We hope to .
2 have that transition completed by the end of the year.
3 CHAIRMAN JACKSON: Let me ask you a more mundane 4 question. What's the typical makeup of the expert panel, 5 and is there consistency or does it vary from plant to 6 plant?
7 MR. CORREIA: Typically, there's representatives 8 there from plant operations, maintenance, engineering, 9 certainly the PSA area, and most licensees will bring in the 10 system engineers for the particular system they may be 11 evaluating. I think most are pretty consistent with that 12 makeup. Some involve quality assurance personnel also.
13 CHAIRMAN JACKSON: Any further comments?
14 COMMISSIONER DICUS: One last question. We 15 consider this basically a fairly successful rule. I think 16 that's a fair statement. Some members of the nuclear power 17 plant industry have raised some criticisms of the rule and I 18 would ask if those -- if you believe those criticisms are 19 fair or reasonable or valid, and if so, what are we doing to 20 address them.
21 MR. CORREIA: One of the issues that came up early 22 on was this issue of using MPFFs as a measure of 23 reliability. We felt the guidance was clear. It was 24 discussed during the development stages of~the guidance 25 document in the '91, '92 time frame, and we responded to the ANN RILEY & ASSOCIATES, LTD.
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65
. 1 industry concern that way, what our expectations were in 2 that area.
3 Another concern of some licensees is that the 4 baseline inspections are very programmatic, as Sam l 5 mentioned. We need to do programmatic inspections to gain l
i 6 the confidence that licensees have established programs that 7 will effectively monitor the effectiveness of maintenance, 8 and until such time, I think we need to evaluate very 9 broadly, horizontally, the programs they've ,stablished to l 10 implement the rule.
11 Once we have confidence that the programs are in 12 place, it's stable, then I believe we can focus more on
! 13 performance issues than the programmatic issues.
14 CHAIRMAN JACKSON: Okay. Commissioner. l l
15 COMMISSIONER ROGERS: Well, just one -- I'm sorry, i 16 COMMISSIONER DIAZ: Go ahead.
17 COMMISSIONER ROGERS: Just one point, and that is 18 --
a general observation, and that is that in trying to 19 develop measures of how successful or not this is, I think 20 there are both quantitative measures, failures, scrams, so 21 on and so forth, but there's also the impact on what I'll 22 call the safety culture of the plant.
23 Right now, I think it's sort of an article of 24 faith with me that the more ownership that'the plant people ,
1 l
25 actually feel towards their plant, ultimately the better ANN RILEY & ASSOCIATES, LTD.
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66 1 results and the more safe plant you're going to get. .
l l
2 But that's really an article of faith more than 1 3 demonstration, and I think that it's something to watch, 4 that whether this -- this approach of a performance-based 5 rule which ultimately looks at results -- that's the idea in 6 the end -- looks at results more than methods, although we 7 have to go through our programmatic inspection program to !
8 make sure that we have some confidence that they can deliver l 9 what they may -- what their objective -- performance l 10 objectives turn out to be.
1 11 Once you get through that, and that will take some l
- 12 time, whether one then finds that the general attitudes l 13 within the plant are strong with respect to taking 1 l
l 14 initiatives to do things the best way themselves and to use 1 15 their resources in the best way, and that's a subtle I 1
16 measure, but I think it is something to watch for because, 17 to me, that's one of the long-term benefits that I would 18 hope to see come out of this general approach.
19 CHAIRMAN JACKSON: Commissioner Diaz.
20 COMMISSIONER DIAZ: Thank you, Madam Chairman.
21 Although it might not be obvious from my previous 22 comments, I do love the maintenance rule, and let me tell 23 you why I love it.
l 24 Rather than just looking at the rule and the l 25 language and the problems, I think for the first time, we ANN RILEY & ASSOCIATES, LTD.
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. 1 took a risk and went out there with something that was not 2 completely known, and probably for the first time, in
]
3 writing, we went and said, those known safety-related 4 systems which might be cafety related, okay, that we know 1
5 about and you know about have to be treated in an equal part 6 'with safety-rel._.ed systems.
7 That was a great thing to do, because we have 8 known they're there. Everybody has known they're there, and 9 we keep feeling around, as it were, and we say, look, it 10 doesn't matter what we call it. If they are really, you
-11 know, important to the safety of the plant, they have to be 12 addressed, and I think that was a major thing.
13 on the other hand, there are some words in here 14 that do need to be fixed, and I think-you realize that there 15 is a little bit more specificity that needs to be described, 16 that the rule actually does apply to all those systems, 17 structures, and components that are in the plant during not 18 only the design basis and so forth.
19 I do think that we have done some great strides in 20 that availability should be clearly and further,'you know, 21 analyzed and enforced if necessary, while we need to go on 22 our own learning curve on reliability, but I really commend 23 you. I think it's just going the right way.
24 CHAIRMAN JACKSON: u Well, thank yo~. I'd like to 25 thank the Staff.
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68 1 MR. CALLAN: Chairman, I think I'd like to just ,
2 make one comment and remind you, Chairman, of the June 1996 3 senior -- Staff briefing at the senior manager meeting 4 before the Commission at which time you, in closing, went to
.5 each of the four regional administrators and asked us our 6 opinion. This is a month before the rule was implemented, 7 and asked us our opinion, our prognosis of how we thought 0- the rule -- how we thought it would go.
9 And as you know, regional administrators are a tough audience, a skeptical audience, and I think you heard 10 l
11 -- if you remember, you heard a lot of concern from each of 12 us, a lot of trepidation from each of us. 1 l
13 It was not a scientific survey, but my sense is,
]
14 speaking for my colleagues, I think if you were to poll each 15 of the regional administrators now, I think you'd get a 1 16 sense from them that certainly their worst fears weren't 17 realized and probably that they view the implementation as 18 one of our more successful endeavors. I think it's gone 19 quite well.
20 And one final comment. When you look at resource I 21 expenditure in implementing a rule of this nature, I think 22 you have to also consider that if those resources weren't 23 used in implementing the maintenance rule, a lot of 24 resources would still be poured into maintenance in a l
25 different way, and it wasn't that long ago, how many years ANN.RILEY & ASSOCIATES, LTD.
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, 1 ago, we expended significant resources doing maintenance l 2 team inspections.
l l 3 MR. THADANI: Right.
i 1
! 4 MR. CALLAN: I think the resources we spent doing 5 maintenance team inspections as an initiative would rival 6 the resources that we spent implementing this rule, and I 7 think -- in all candor, I think we would all agree that the j 8 results of the maintenance team inspections were probably a 9 disappointment, given the resource expenditure.
10 So maintenance is one-fourth of the process. We ;
! 11 do inspect maintenance, and I think certainly the regions do 12 not begrudge the resources spent implementing the rule, and 13 those-resources would have been spent doing maintenance
- t. 14 anyway.
! 15 So I don't know how you parse that, how you split l 16 that away and just look at the delta resources of overhead l 17- in implementing the rule and not the total resources, and so l 18 that's it.
l 19 CHAIRMAN JACKSON: That's the important point.
20 Well, thank you again and it's been a very l .,
21 informative briefing. I thank all of you.
22 I think that considerable progress, in fact, has 23 been made in implementing the maintenance rule, and, Mr.
l 24 Callan, your comments relative to the opinion of the 25 regional administrators helps to reinforce that perspective.
f
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I 70 1 And as you've heard, obviously the Staff should .
2 continue to focus on insuring consistency in the 3 implementation and enforcement across the industry. As many 4 of us have said, the maintenance rule is often referred to 5 as an example, maybe the first real one of a risk-informed,
- 6. performance-based regulation. That's certainly the way I've 7 been advertising it.
8 1md because of that, the lessons learned from its 9 implementation should serve and must serve as a useful guide 10 to assist NRC in the future development and implementation 11 of risk-informed, performance-based regulation.
12 And in that regard, I will bring three things to 13 your attention. One has to do with this issue of -- and 14 Commissioner McGaffigan made this point before he left, is ;
15 asking you to consider again this question of whether the 16 category (a) (3) safety assessments, whether there needs to 17 be some clarification in terms of the language.
18 What you said about requirements should be in the 19 rules as opposed to exhortations, and I think you need to 20 come back to us on as short a time scale as we can work out 21 her'e with some more definitive statement in that regard, "
22 because we've had histories in the past of saying, well, we 23 don't think we need to do anything, and then -- I won't be 24 here, but 15 years from now, we'll be talki~ng about what we 25 could have done and should have done.
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l 71
, 1 And in the meantime, I think you should -- as you 2 1g0 forward, I'd like to see some sense of how you're going 3 to track the efficacy of configuration control a la the rule 4 in our regular inspection program, even as we get
- information through these baseline inspections from the ,
6 ' plants that haven't had them so far.
l 7 And secondly, I think it is very important that 8 this issue of being able to measure how efficacious the rule 9 is in terms of the net effect of the quality of maintenance, L 10 that is, on equipment performance -- and again, I think this 11 is rooted in a basic inspection program, but it has to be i
12 tied into the judgments we are making on the efficacy of the 13 rule itself, and then the issue of clarification of language
-14. used is always out there.
15 So unless there are any further comments, 16 adjourned. Thank you. ;
l '
l 17 (Whereupon, at 4:27 p.m., the briefing was l
18 adj ourned. ]
19 20 21 22 23 24 25 i
l ANN RILEY & ASSOCIATES, LTD.
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. CERTIFICATE This is to certify that the attached description of a meeting of the'U.S. Nuclear Regulatory Commission entitled:
TITLE OF MEETING: BRIEFING ON IMPLEMENTATION OF MAINTENANCE RULE, REVISED REGULATORY GUIDE, AND CONSEQUENCES - PUBLIC MEETING PLACE OF MEETING: Rockville, Maryland DATE OF MEETING: Monday, March 10, 1997 was held as herein appears, is a true and accurate record of the meeting, and that this is the original transcript thereof taken stenographically by me, thereafter reduced to typewriting by me or under the direction of the court reporting company Transcriber: k (1L4// n p Reporter: Jody Goettlich
o
,pa ae vy,
. e STATUS OFTHE MAINTENANCE RULE Ashok C.Thadani i Suzanne C. Black Richard P. Correia
Contact:
Rich Correia Phone: 415-1009 March 10,1997 1
i f
AGENDA '
e Maintenance Rule Background
- Baseline inspection Program Results !
- Clarifications in Regulatory Guide (RG) 1.160' Revision 2
- Lessons Learned and insights t
e tFuture Activities i
2 - ~
i OVERVIEW '
- Need for a Rule
- Number of Transients and Scrams
- MaintenanceTeam inspections
- Developed Risk-informed, Performance-Based Rule
- Give Licensees Flexibility
- Can Inspect and Enforce
- Challenges
- Variation Between Licensees
- NRC Resources Required are High
~
- Completed Staff Activities ,
t BACKGROUND
- Rule issued 7/10/91, in Effect 7/10/96 t
- Industry Guideline Document NUMARC 93-01 r
e RG 1.160 '
s Inspection Procedure (IP) 62706
- IP 62707 l
[
4 - '
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BACKGROUND - IMPLEMENTATION USING NUMARC 93-01
- i
- Determine SSCs Within Scope
- Determine Safety Significance of SSCs
, Within Scope e Monitoring Varies With Safety Significance
- Monitoring Varies With Performance 5
t
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[
v BASELINE INSPECTION RESULTS
- 20 inspections i i
e Each inspection Unique !
- Overall Licensees Adequately implementing the Rule
- Some Licensees implemented Late :
c i i
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i' BASELINE INSPECTION RESULTS -
CONTINUED i
- Two Common Findings
- Inadequate Reliability Performance Criteria / Goals
- Failure to Monitor Both Reliability and Availability
- Scoping l
e Reluctance to identify Maintenance Preventable Functional Failures I,'MPFFs)
- Structural Monitoring
- (aX3) Safety Assessments .
t 7 ',
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t i
t BASELINE INSPECTION RESULTS -
CONTINUED
- Enforcement Complete on 11 Inspections
- Two Had No Maintenance Rule Violations
- One Had One Severity Level lli But No Civil Penalty
- Eight Had One or Multiple Severity Level IV
- Remaining Inspection Findings Under Staff Evaluation 8
CLARIFICATIONS IN RG 1.160, REVISION 2
- Scoping
- MPFFs as Reliability Indicator
- Monitoring Structures i e Normally Operating SSCs of Low Safety Significance L_- _ - A
CLARIFICATIONS IN RG, CONTINUED
- Safety-Significance Categorization Process
- Reflect Changes to Rule Since Revision 1
- Definition of Maintenance
!
- Timeliness
- Definition of Standby 1
- MpPFs Related to Design Deficiencies
- Number of SSCs in Category I;a)i:1? l 10 ' '
LESSONS LEARNED AND INSIGHTS
- Importance of Communication
- Value of the Pilot Program
- Guidance Developed Through iterative Process
- Importance of Training i
- May Need Programmatic Baseline inspection Program
- Can Consistently inspect and Enforce
- Resource Requirements High
- Rules Must Only Contain Requirements 11
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STATUS - FUTURE ACTIVITIES
- Complete Baseline inspection Program
- Issue Information Notice j e Revise IP 62706
- Make"Home Page" Publicly Accessible
- Revise Enforcement Guidance 1
e Develop ContinuingTraining Program i
12 , .
Maintenance Rule (MR) Baseline Inspection Results Plant Palo Verde Units 1. Peach Bottom 2 & 3 Prairie Island Donald C. Cook 2&3 Units 1 & 2 Units 1 & 2 Total SSCs 128 326 100 228
- SSCs in Scope 89 133 75 173
- of High Safety 35 42 Significant SSCs 30 64 i
- of SSCs in 10 3 (a)(1) Category 4 30 Risk Determination RAW. FVI. 90% of RAW. RRW. 85% of Methods RAW. RRW. 90% of RAW. RRW 90% of CDF Cutsets. & CDF Cutsets, & CDF Cutsets, & C0F Cutsets. &
Expert Panel Expert Panel Expert Panel Expert Panel Living PRA & Yes. Every Other Update Frequency Not Updated Since Yes. Every Other Yes. Every Other Refueling Cycle 1991 Refueling Cycle Refueling Cycle On-Line Pre-Analyzed Risk Maintenance Safety AG-43. SA Proce- SAIC E00S Software. Pre-Analyzed Risk Matrix dure. Consults On line risk Assessment (SA) Matrix with PSA group for Methods monitor planning and scheduling Inspection No Violations. A Findings One Level III MR Three level IV MR Two level IV MR few program weak- violation. No CP.
nesses noted.
violations identi- violations identi- '
Licensee did not fied fied justify exceptions ;
to NUMARC 93-01.
i
Maintenance Rule (MR) Baseline Inspection Results Plant St Lucie Units 1 & Sequoyah Units 1 & Perry 2 2 Hatch Units 1 & 2 Total SSCs 106 172 SSC Functions 233 256 SSC Functions
- High Safety 31 Significant SSCs Unknown. Ten SSCs 46 55 SSC Functions downgraded by EP from high risk to low risk.
- of SSCs in the 6 6 (a)(1) Category 16 5 Risk Determination RAW. RRW. 90% of Methods RAW. RRW. 90% of RAW. RRW. 90% of RAW. RRW. & Expert CDF Cutsets. & CDF Cutsets, & CDF Cutsets, &
Expert Panel Expert Panel Panel Expert Panel Living PRA &
Yes. Unknown Update Yes. September.
Upda.te Frequency Frequency. Bayesian No. Last Updated in Yes. Some Data Updating Used 1995. Unknown July 1992 Updating. No Update Frequency Bayesian updating On-Line in sample taken .
Pre-Analyzed Risk Pre-Analyzed Risk Maintenance Safety Matrix On line Maintenance Pre-Analyzed Risk Assessment Methods Matrix E00S Procedure Matrix Inspection Findings Three level IV MR No MR Violations.
violations identi- No MR Violations. Three Level IV MR fied. A few weaknesses One Level IV Tech violations identi-were noted. Spec 6.8.1 viola- fied.
tion for failure to follow Safety Assessment (SA) OA i procedure when taking E00S for maintenance.
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4 Maintenance Rule (MR) Baseline Inspection Results Plant Cooper Nine Mile Point Surry Units 1 & 2 WNP-2 Unit 1 -
Total # SSCs 447 SSC Functions 296 SSC Functions 101 Unknown
! # SSCs in the 4 SSC Functions on (a)(1) Category 2 Systems 3 3 Systems 4 Risk Determination RAW. FVI. 90% of ,
Methods RAW. RRW. 90% of RAW. RRW 90% of RAW. RRW, FVI. 90%
Expert Panel Expert Panel CDF Cutsets & of CDF.Cutsets. & :
Expert Panel Expert Panel Living PRA &
Unknown Update Frequency No. Last Updated in No. Last Update in June. 1992 No. Last Update 1994 Unknown On-Line Pre-Analyzed Risk Maintenance Safety Two procedures used Pre-Analyzed Risk Matrix for performing SAs. Weak Procedure for Assessment Methods Matrix with only 12 performing SAs on Both use PRA to of 44 risk unanalyzed evaluate risk. significant SSCs. configurations. ;
Inspection Findings Six level IV MR Four apparent MR violations were Six apparent MR Two Level IV MR violations were violations were violations were identified. One identified. An level IV Appendix identi fled. One identi fied. i Enforcement Confer- apparent Appendix B. Criterion V ence was held on
! violation for 2/25/97 B. Criterion V failure to follow Violation identi-OA SA procedure fled for failure to i i
when taking E005 follow QA SA proce-for maintenance. dure when taking E00S for mainte- ;
l nance.
I ,
4 Plant Indian Point 3 CDF Cc;e Damage Frequency Total # SSCs 227 CP Civil Penalty E005 Equipment Out Of Service
- SSCs in Scope 118 FV1 Fussell Vesely Importance
- High Safety MR 27 Maintenance Rule Significant SSCs PRA Probabilistic Risk Assessment" OA Quality Assurance
- SSCs in the 11 RAW Risk Achievement Worth (a)(1) category RRW Risk Reductien Worth SA Safety Assessment Risk Determination RAW. RRW. 90% of Methods.
CDF Cutsets. &
Expert Panel Living PRA &
Yes. Every two Update Frequency years On-Line PRA based procedure Maintenance Safety used to perform SA.
Assessment Methods Licensee in process of 17 stalling NUS E00S Software Inspection Findings Two Level IV MR violations were identified.
- . _ - . _ . . . _ _ _ _ _ - _ _ - _ _ _ _ . - - _ _ . _ _ _ - . _ _ _ _ _ - _ _ - _ _ - _ _ _ _ _ . . . =