ML20147B998
| ML20147B998 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8801190045 | |
| Download: ML20147B998 (85) | |
Text
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C' UNITED STATES OF AMERICA NUCLEAR REGULATOR.Y COMMISSION .
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Title:
Briefing on Status of Maintenance Program and Policy l Statement / Advanced Notice of Proposed Rulemaking !
Location: Washington, D. C.
Date: -
Thursday, January 7, 1988
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PageS: 1 - 75 Ann Riley & Associates Court Reporters 1625 i Street, N.W., Suite 921
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Washington, D.C. 20006 .
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G This is an unofficial transcript of a meeting of the 7 United State's Nuclear Regulatory Commission held on 3 1/07/88 ..
In the Commission's office at 1717 H Street, 9 'I4 . W . , Washington, D.C. The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain
? -
g 12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.103, *
, it is 15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of : pinion in this transcript 17 do not necessarily reflect final determination or beliefs. No 10 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed t o' any s t a t emen t 20 or argument contained herein, except as the Cemmission may 21 authorize.
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UNITED STATES'OF AMERICA .
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2 NUCLEAR REGULATORY COMMISSION .
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4 BRIEFING ON STATUS OF MAINTENANCE 5
PROGRAM AND POLICY STATEMENT / ADVANCED 6
NOTICE OF PROPOSED RULEMAKING 7 ***
8 PUBLIC MEETIMG 9
10 Nuclear Regulatory Commission 11 Room 1130 12 1717 H Street, Northwest 13 Washington, D.C.
14 15 Thursday, January 7, 1988 16 17 The Commission met in open session, pursuant to 18 notice, at 2:00 P.m., the Honorable LANDO W. 2ECH, Chairman of 19 the Commission, presiding. .
20 COMMISSIONERS PRESENT:
21 LkNDO W. ZECH, JR., Chairman 22 THOMAS M. ROBERTS, Commissioner 23 FREDERICK M. BERNTHAL, Commissioner 24 KENNETH M. CARR, Commissioner .
k,) 25 VINNETH C. ROGERS, Commissioner - '
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STAFF AND PRESENTERS SEATED AT' COMMISSION TABLE: .
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SAMUEL J. CHILK, Secretary 3 WILLIAM C. PARLER, General Counsel 4 VICTOR STELLO, JR., Executive Director-5 for Operations 6 ED JORDAN 7 JAMES SZNIEZEK 8 JACK ROE 9 .TOHN ZWOLINSKI 10 11 12 -
13 14 15
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18 19 20 21 22 23 24 C-' 25
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I 1 PROCEEDINGS '
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2 CHAIRMAN ZECH: Good afternoon ladies and gentlemen. l 3, the purpose of today's meeting is for the NRC staff 1 4 to brief the Commission concern'ing the interim policy statement
, 5 on maintenance of nuclear power' plants. I personally believe 6 that the safe nuclear facilities are reliable nuclear 7 facilities, and reliable nuclear facilities are economic I I
B nuclear facilities. Proper maintenance programs that are f 9 vigorously executed, in my view, make a substantial 4 10 contribution to safety. They are reliable, and it just makes 1 11 good economic sense, too. {
I 12 The results of the staff's maintenance and 3 13 surveillance program, combined with the events at operating 14 reactors, plus my own visits. and those visits of my fellow l
15 Commissioners to the power plants in our country and abroad, l i
16 i
have convinced us that maintenance is one area where some power !
17 ;
reactor licensees could improve substantially, and where 18 virtually every licensee can improve to some degree.
19 We at the Con 51ssion have recently received a paper 20 q
from our Secretariat that transmits the staff's recommendation
) 21 concerning an interim policy statement on maintenance of 1
1 22 nuclear power plants. I believe that this briefing today will 23 be valuable in assisting us in our review of that policy 24 statement and be useful in our preparation of our action to
( ) 25 take on this statement.
l-i
0 4 1 During the presentation today, I would like.the staff
! 2 to discuss also their intentions and their schedule for 3 preparing a maintenance rule. I understand that copies of the 4
staff's slides to be used during the presentation today and 5
other papers are available on the table at the back of the 6 room.
7 Do my fellow Commissioners have any opening comments 8 to make?
9 (No response.)
10 CHAIRMAN ZECH: If not, Mr. Stello, would you proceed 11 please.
12 MR. STELLO: Thank you, Mr. Cha'irman.
13 I would like to address onet issue that you raised in 14 your opening comments, and then I will quickly turn to Mr.
15 Sanie:ek and Jack Ro,e for a briefing on the policy statement.
16 That is, the idea of when and how to come forward 17 with a rule on maintenance. Our schedule at the moment is to 18 provide to the Commission in March an advance notice for 19 proposed rulemaking for a maintenance program.
20 The reason for wanting to go to an advance notice is 21 we are not really sure we know how to structure a. proposed rule 22 that will do the job that needs to be done and be convinced 23 that we're right, and an advance notice will allow us the 24 opportunity to make sure that that rule is constructed 25
(_ correctly.
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5 1 But more significantly, what we would like to-be able.
s 2 to do is to have the policy statement in place and have that 3 policy statement followed, which we believe-will add 4 significantly'to our ability to understand how to frams.a rule 5 that would be useful for the long term. WL aer that needs.to 6 be very proscriptive in its nature, or whether it ought to be 7 very general--something as simple as just simply saying that 8 the industry shall develop a comprehensive maintenance plan for 9 the year and submit it to the NRC for its approval, to a rule 10 that describes particular detailed elements of the maintenance 11 plan, is one that we want to consider very carefully, because 12 proscriptive rules very often are a problem. I would rather '
13 not take that step now, unless it really turns out to be 14 necessary.
15 We think we will have the information we need, if the 16 Commission goes forward and agrees to move forward with this 17 policy statement, that will do a good job and, hopefully, if 18 everything goes well we may be able to advance substantially 19 our sc'hedule for getting a rule. Whether that comes to pass or 20 not of course is conjecture at the moment, but I think if the 21 industry is responsive and does do a very good job, which I 22 expect that they ought, the motive--as you've already 23 indicated, in just capacity and reliability of the plants' 24 overall performance--is there,~I think we may be able to move
() 25 much faster. Of course' we will have to wait and see.
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I would rather have been able to propose something
( 2 definitive. I really think it would be a mistake to try to 3 move too quickly and make the decision on how to frame that 4 rule right now.
5 With that, let me turn to Mr. Szniezek to give you a !
6 broad overview of where we are, and then we will get into the l 7 details of the policy more with Mr. Roe. I l
8 CHAIRMAN ZECH: Before you begin, let me just make 9 one brief comment on that statement. I would just ask that 1
l 10 you, in the next months, keep an open mind to the possibility 11 of going directly to a rule rather than advance notice for 12 proposed rulemaking, if it does seem like that is the 13 appropriate thing to do, 14 MR. STELLO: We will do everything we can to try to '
15 take that step.
16 CHAIRMAN ZECH: You will consider it.
17 MR. STELLO: Yes, we will.
18 CHAIRMAN ZECH: All right. Thank you, very much.
19 Mr. Szniezek, you may proceed. ,
20 MR. SZNIEZEK: Before Jack Roe begins his detailed 21 briefing on the policy statement, I would like to mention just 22 a few key points.
23 Historically the NRC hasn't put a great deal of 24 attention and emphasis on integrated maintenance programs. We
,(_,) 25 believe this has been reflec'edt in the status of maintenance in
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7 1 .the nuclear indu3try today. We believe that from'a safety
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, 2 standpoint it is time for us to change that. It is time for us 3 to start exercising a leadership role in the maintenance area.
4 This leadership ro2e involves a coordinated effort 5 betweer many NRC offices--NRR, AEOD, Research, and of course -
6 the Regions--and we have received'this cooperation in going 7 forward up to this point, and we expect it to continue.
i 8 In exercising this leadership role, we intend to be !
9 the impetus behind a changed maintenance ethic in'the nuclear 10 industry, one that we believe will enhance safety and would i 11 have the side benefits of increased reliability and increased 12- availability of the plants.
- 13 The first step we see in this impetus is telling thu 14 industry what we expect. That is, that we expect the plant 15 equipment to be maintained so that it is available to perform 16 its intended function; and if for some reason it does break, to !
17 1 repair it promptly. That is what we really expect out of the I 18 industry.
19 ,
To reinforce this, we believe it is necessary to go 20 out and do multi-discipline maintenance team inspections at the 21 sites to see what is really working out there, to see the 22 extent of safety problems, if.any exist, and then to take 23 whatever actions are necessary to correct any safety problems l 24 and to make dure that the maintenance was working effectively.
( ) 25 -
. COMMISSIONER BERNTHAL: Does that mean.that you don't 9
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. 8 1 feel we have a good understanding of the current status of h 2 maintenance in the plants? In other words, doesn't our normal 3
SALP program and normal on-site inspectors and inspections get 4 a good picture of that? Or what are you saying?
5 MR. SZNIEZEK: I don't believe our normal program 6 today gets a good, integrated picture. Now as part of our 7 inspection program today, inspectors look at maintenance 8 activities. We don't have an integrated program in place to 9 look at everything that impacts on maintenance activities--the 10 health physics interface, the design interface, the interface 11 with operations, things of that nature--and that is what we are 12 - really goir.g to be taking a disciplined look at with the multi-13 discipline team inspections: the interfaces, what really makes 14 maintenance effective at a plant, and see what the utilities 15 have.
16 COMMISSIONER BERNTHAL: So you are talking more not 17 about the hardware evaluation but about management and systems' 18 evaluation.
19 MR. SZNIEZEK: And looking at the status of the 20 actual equipment in the plant--how much is broken, if there are 21 leaks.
22 COMMISSIONER BERNTHAL: I think you just said the 23 opposite of what I said.
It sounded like you were saying that 24 we did focus on specific hardware problems in our normal
( J 25 inspections in SALP processes, but that it was'the overall 9
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9 1 integrated picture, including na'nagement and systems anal sis,
( 2 that we didn't do that we were going to do in this program.
3 MR. SZNIEZEK:- We're doing both in the program that 4 we're going to. We focus more on the hardware today. For 5 example, our inspector goes out and watches a maintenance 6 activity being performed to see if the right procedures are 7 followed, but they don't necessarily look at all the planning 8 and the interfaces that went on before that. We are going to 9 correct that in our new program to really make sure we have a 10 good understanding of what makes maintenance tick at a plant.
11 Also as part of the effort we are going to monitor is 12 what the industry has underway. We are going to monitor them 13 to see if they are effective, and we are going to monitor them 14 through how are they being implemented at the plant; not just
- 15 paper reviews, but are they actually taking hold in the plant.
16 In addition, it will be in the process to develop a 17 rule and put a rule in place at the appropriate time, and we 13 believe that we will set the stage with the policy statement.
19 We will start doing these team inspections, which we expect to 20 have underway in about the April time frame, to start them, and 21 that will give us a lot of insights into how we should develop 22 a rule.
23 With that, I would like to turn it over to Jack Roe 24' who will lead us through a discussion of the details of the .
-( ) . 2 5 policy statement itself.
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. 10 1 CHAIRMAN ZECH: Thank you,,very much.
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2 Mr. Roe, you may proceed.
3 MR. ROE: Thank you, Mr. Chairman.
4 I would like to start first with the background 5 slide.
6 (Slide.No. 1.)
7 (Slide No. 2.)
8 MR. ROE: It is important to note that the industry 9
has several initiatives that have been implemented. The most 10 noteworthy for the staff are those conducted by INPO. Of their 11 several initiatives, we find the most interesting are the 12 Guidelines for the Conduct of Maintenance at Nuclear Power 13 Plants, an INPO document that has been sent to~all plants, and 14 our understanding is that all plants have committed to conduct 15 a self-assessment against that particular document, or selected 16 portions of that document at their selection.
17 In addition--
18 COMMISSIONER CARR: How long has that been in place?
19 MR. ROE:
, I believe, sir, that started off in 1985.
20 In the area of assistance
- visits, INPO has a special 21 team, a Maintenance Assistance and Review Team, yhere they have 22 a two-week visit of approximately eight members, of which one 23 is a peer evaluator, one or more could be a peer evaluator, 24 someone who actually conducts maintenance at a plant. So far,
(_) -2 5 we have knowledge that they have conducted 12 of these' '
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. 11 1 particular ass'istance visits. ,
( 2 In addition, INPO reviews maintenance during their 3 periodic plant evaluations. The staff, from'the period of 4 approximately 1985 to 1987, has reviewed the effectiveness of 5 maintenance by 10 site visits, 10 plant visits, and obtaining 6 66 questionnaires from other operating plants.
7 From those particular reviews we have found a wide
- 8 variation in effectiveness. We have determined that needed 9 maintenance is not being accomplished at some of the 10 facilities. For example, overall statistics show that 64 11 percent of the total forced outage time is due to component 12 failure; 48 percent of 1985 LERs were maintenance-related.
13 We found a high percentage of failures from improper 14 performance of maintenance. It is noteworthy that 30 percent of' 15 the abnormal occurrences since 1975 are maintenance-related.
16 Since 1983, the proportion of maintenance-related and LERs ha's !
17 increased.
18 We see that the maintenance / operation interface is 19 inadequate in many areas. For example, statistically 65 20 percent of the loss of safety system functional events were due 21 to human errors--many related to maintenance.
22 We believe that maintenance-related challenges to t i
23 safety systems are very excessive. Statistically we found that 24 75 percent of ESF actuations in 1984 and 1985 were maintenance-() 25 related.
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1 '(Slide N,o. 3.)
r ~m' Next I would like to discuss the content of 1
1 2 MR. ROE:
3 the policy statement and a little bit of the philosophy behind 1
4 the way it was developed.
5 This particular p~olicy statement was developed to be 6 concise--
7 COMMISSIONER BERNTHAL: Let me ask one question. I l
8 am trying to think of a case where any breakdown of any' kind in !
9 a plant would not, first of all, be management-related of 10 course, but beyond that--because ultimately everything is 11 !
management related; .if you've got bad maintenance, you could 12 argue it's bad management--but let's get one step down, now. !
13 What kind of events, when you say numbers like 75 14 percent maintenance-related, what kind of events where there is 15 a failure could you not ultimately always ascribe to a 16 maintenance breakdown, for example? What kind of failures of 17 hardware of any kind would not be ascribed to maintenance?
18 MR. STELLO: You're looking for examples of things I 19 would say clearly you can't blame maintenance?
20 COMMISSIONER BERNTRAL: Yes.
21 MR. STELLO: Recent events at Palo Verde, the pump 22 .. Aft.
23 COMMISSIONER BERNTRAL: Okay, design structural.
24 flaws.
( ,) 25 NR. STELLO: Cracked shafts'at some of the hig'h head ~
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2 problems.
i The channel box failures in BWRs, vibration 3 problems-- COMMISSIONER BERNTHAL: Design flaws, basically, 4 and manufacturing flaws.
5 MR. ROE: And some of them a combination of both.
6 MR. STELLO: The point being clearly that there are a 7 lot of things that no matter what you do with maintenance, you l 8 can't preclude the failure. BWR pipe crack problems. You '
9 could do maintenance as much as you Want. You're going to have 10 them.
I 11 MR. ROE: Steam generator tubes are one that can be l
12 non-maintenance related. 1 l
13 MR. STELLO: A lot of them are from the design. !
14 CHAIRMAN ZECH: Personnel erroro. ,
Don't forget that.
15 MR. STELLO: Pers.onnel errors, just pure personnel.
16 COMMISSIONER BERNTHAL: Okay.
17 MR. ROE: Back to the content of the policy ,
18 statement. It is important to note that staff's intention of 19 developing this policy statement is to make it to the point, 20 crisp, and make it straightforward.
21 I would like to address two parts of the policy 22 statement in summary fashion and go into the details of the 23 policy section in the additional information section.
24 The summary section of the policy statement
(,) 25 emphasizes the importance that the Commission places on 4
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. 14 1 maintena'ce n to nuclear safety. .
O i 2 Secondly, it states that we will evaluate industry 1
3 initiatives' for approximately a two-year period. During'this 4 two-year period, as Mr. Stello has indicated, the staff intends 5 to issue an advanced notice of proposed rulemaking and, if l l
6 appropriate, follow it up with a draft rule, and also if l
7 appropriate and necessary, to continue with the final rule.
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8 Another point I would like to mention overall in the i 9 content of the policy statement is the statement that we have 10 made associated with enforcement. The reason I bring this out i
11 is that some of our policy statements recently comes to mind i i
12 the one on training accreditation, our policy on~ enforcement l 13 was that we would modify in some cases while the industry was j 14 improving.
15 The staff's position in this particular policy 16 statement is that we will continue our particular enforcement 17 policy--that is, that we will take vigorous enforcement action 18 where we find noncompliances with the Commission's regulations.
19 (Slide No. 4.]
20 MR. ROE: I would like to go on now to address the 21 actual policy.
22 MR. PARLER: I have a question, Mr. Chairman. I 23 don't understand that statement that was just made. May I ask 24 a question?
(_,/ '2 5 CHAIRMAN ZECH: Certainly. do ahoad.
. '15 1 MR. PARLER: ,If'there are no' regulations on -
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(~NI i i 2 maintenance, what is the enforcement going to be' based against? l 3 I don't understand the. statement that was just made. I l 4 apologize for asking the question. l
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5 CHAIRMAN ZECH: No, that is a good question. Let's 1 6 have an answer. i 7 MR. PARLER: I have had to testify to that in past i 8 sessions. '
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9 CHAIRMAN ZECH: I know. What is the response. '
10 MR. ROE: I would not agree with General Counsel's 11 comment that there are no regulations associated with 12 maintenance. There are a mul'tituda of regulations associated 13 with maintenance. Let..me give you a few examples:
14 The tech specs require a significant amount of 15 surveillance activities, and they are based on many. industry 1
16 standards. There is a well ' defined program of in-service 17 inspection of nuclear power plant. components and in-service 18 testing of nuclear power plant structures and components. .
19 CHAIRMAN ZECH: So you are saying there are 20 regulations.
21 MR. ROE: Yes, sir; and there are requirements in 22 Appendix B, our quality assurance, that would require certain 23 activity to be taken commensurate with an item's importance to 24 safety.
( .y 25 CHAIRMAN ZECH: I am sure the General Counsel would 0
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l I 2 MR. PARLER: Well, Mr. Chairman, I appreciate the 3 clarification to remove the ambiguity that exists at least in 4 my mind that we are operating completely under a policy I 5 statement and we're thinking about some time over the next two 6 years coming out with an advanced notice, perhaps a proposed 7 rule, perhaps a final rule.
8 The fact is, apparently, that there are a lot of 9 regulations that are already applicable that are codified and 10 that could be enforced. I regret the misunderstanding, and I 11 appreciate the clarification.
12 MR'. ROE: We feel I think that the status of the l
13 Commission's regulations on maintenance are fragmented. They 14 are in various sections. There is not an integrated approach l
15 to the overall subject of maintenance conducted at nuclear l 16 power plants. l 17 CHAIRMAN ZECH: But when you say they're not 18 integrated and that they're fragmented, that's an important 19 differentiation because there are regulations. I think that's 20 the General Counsel's point.
21 MR. ROE: Yes, there are, but they're fragmented.
22 CHAIRMAN ZECH: All right.
23 COMMISSIONER BERNTRAL: Let's see. Is the point.then l t
24 that--it is certainly a useful management thing for us to pull
( 25 our managing efforts'here, our regulat'ory efforts'together to d *
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provide'a focus on the perceived problem.
, Would it also be the f
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2 objective here in a rule to pull together all these fragmented
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3 maintenance things so that they all appear in one place in a l 1
4 tidier list so we know what we are trying to do? l 5 MR. STELLO: That was the reason I said at the 6 .beginning of this meeting.What I said. It isn't clear which 1
7 approach we ought to follow during the rule, whether we ought 8 to try to get that very detailed proscriptive kind of rule that 9 integrates all of that, or a very simplistic rule that just 10 says develop a maintenance program plan for your facility using 11 this philosophy, submit it to us for our review, and then we 12 will make binding through some mechanism, whether a license 13 amendment or whatever r a requirement that you follow and adhere 14 to that maintenance plan. That is a very simplistic kind of a 15 rule.
16 The integration in all of that stuff, then,. takes 17 place somehow, but you evolve the actual maintenance program l 18 plan. I Then that's the thing you make a requirement, and try to 19 develop a way to weave together all of these pieces in our 20 regulations that deal with the issue, and trying to make sure 21 that they are all integrated.
22 I am not sure which way we ought to go. If I were 23 required to do anything to do anything today, I think I would 24 take the very high road, simplistic road, and just simply say:
25 Develop me a maintenance plan, submit it, and make it.a part of O
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. 18 1 the license. ,
( 2 CHAIRMAN ZECH: But isn't that somewhat similar to 3 the approach that FAA has now?
4 MR. STELLO: It would be precisely that approach.
5 CHAIRMAN ZECH: So that is one approach that we could 6 take.
7 COMMISSIONER CARR: That is the same as we have got 8 for quality control now in Appendix B.
9 MR. STELLO: In terms of--
10 COMMISSIONER CARR: Have a program, 11 MR. STELLO: Yes.
12 CHAIRHAN ZECH: And let us approve it.
13 MR. STELLO: But what it would require is the actual 14 maintenance program plan, the details., to be submitted in a )
l 15 document for our approval.
16 COMMISSIONER CARR: i Let me ask a question on j 17 enforcement. Are you talking about th,is last page that says l
18 "Nothing in the policy statement shall limit the authority of 19 the NRC to conduct inspections or take appropriate enforcement 20 action when regulatory requirements are not met?
21 MR. ROE: That is correct, sir.
22 COMMISSIONER CARR: Well, that sounds reasonable 23 enough.
24 MR. ROE: And the reason why we put it in there was
( ). 25 .to'be sure that there was no confus' ion'that some of the actions .
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1 that the Commission had.tak.en in the past during two-year l f "\
s 2 evaluations, or other similar evaluation periods, was to modify 3 enforcement actions based on an improvement period. I 4 COMMISSIONER CARR: All right. ;
I 5 CHAIRMAN ZECH: All right, you may proceed. l 6 MR. ROE: I would like to address the policy now.
i
. 7 The policy is straightforward. We believe and have an 8 expectation that nuclear power plants--that all components, 9 systems, and structures should be available to perform their lo intended function and, if they are not available to perform 11 their intended function, they should be promptly repaired.
12 I have to stress that in th's policy statement the !
\
13 Commission expects that all the components, systems and 14 structures, nct just those that may be in a category associated 1
15 with some other of the Commission's determinations such as l 16 safety-related, important to safety, or other 17 characterizations. They should be all the systems. ;
18 They should include those systems that are associated '
i 19 with the nuclear steam supply system through the balance of 20 plant, and even auxiliary equipment. Today, as an example, in 21 the morning report from the regions there was an item that-22 would seem not to be that important to the functioning of the 23 plant to someone who did not have the proper perspective. It 24 was a report where at one of our boiling water reactors the
(_) 25 operators noticed that two of the recirculation pump seal
9 0
20 1 ' press'ure gauges increased from their normal operating .
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temperature--pardon me, normal operating pressure of about 520 s
2 3 up to about 800 pounds per square inch gauge, and the reason 4 was that there was found to be close to freezing temperatures 5 in the areas where these gauges were; there seemed to be an 6 effect on the line; and the reason was that the auxiliary 7 boiler providing heating to that particular space was not in 8 service.
9 You can see the importance of having a proper 10 maintenance program for all systems, structures, and components 11 in a nuclear power plant.
12' The second part of the policy is that the commission 13 expects that each plant should have a prescribed maintenance 14 program that is developed and implemented to include such items 15 as repair, surveillance, diagnostic examinations, preventative 16 measures, post-maintenance testing, and that the program should )
17 be developed commensurate with the prescribed functions of the 18 e'quipment. '
19 When we speak of "prescribed functions," we are-20 really addressing as that the plant, the utility, should take a 21 reasoned approach and analysis of the design basis of that 22 particular item, its mode of operation, the recommendations 23 from the vendor, the designer, the supplier, consider the role 24 that that particular piece of equipment plays in the safety
, ( ,) 25 and/or the pro' duction'of power of the facility, and tho, failure t
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21 1 modes, effects, and records of that particular equipment to
(', R t 2 establish a maintenance program that considers those particular '
3 points.
4 For example, in modes of operation areas that should 5 be considered are its actuation. Does it run continuously? Is 6 it intermittent? Is it standby? Taken into consideration 7 should be its environs. Is it in a relatively uncontrolled 8 environment? A controlled environment? Or one that is harsh? I 9 obviously vendor recommendations should be considered.
10 Analysis should be conducted to see if they are adequate, or if 11 they are even available at this particular stage in the p]?.nt's {
I 12 life.
13 obviously taken into consideratio.n should be the role 14 that it plays in the production of power, and in safety.
15 Consideration should be given to whether it has normal or 16 emergency use. And lastly, consideration should be taken of 17
, the failure records to determine whether it has frequent '
18 failure history which might indicate an improper design, or a 19 design improvement needed; whether it is failing on a premature 20 basis earlier than it was thought to that might indicate a 21 design fault or an improper maintenance program; and other.
22 aspects of its failure.
23 The next part of the policy statement is one that 24 addresses additional.informations In this particular area, we
(_) 25 desire to provide.the industry additiona'I information on 4
6
22 i several areas. '
2 The first thing is the definition of maintenance. I 3 The second is the framework. 1 1
4 Third, is some more information about compone tn s, '
l 5 systems, and structures--and especially in that particular 6 area, the NRC's regulatory perspective and regulatory primary 7 approach. !
8 The definition of "maintenance." As you see, the 9 staff has proposed a broad definition of maintenance, one that 10 probably is going to touch about 70 percent of the activities 11 of the nuclear power plant. This particular definition of 12 "maintenance" does not focus on the classical maintenance 13 department, but includes supporting functions. t l
14 ,
It goes all the way, in my mind, from design to 15 support of radiation protection during maintenance activities.
16 1 In the additional information section, we should some elements 17 that have broad applicability to effective maintenance )
18 programs.
These are the four that are stated on the slide.
19 The first one is straightforward: A program should ,
20 be established with objectives based on an analysis of th.e ,
21 maintenance requirements for that particular plant.
22 The program should be developed and implemented that 23 addresses corrective, preventative, predictive, surveillance, 24 post-maintenance, testing, and other supporting actions. In
(]) 25' ' 'this' particular area, you,should.strongly consider the vendor e
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re' commendations.
(~h t 2 In the next area th' era should be a program evaluation 3
where you develop methods and criteria to evaluate the program.
4 And lastly, there should be a feedback mechanism.
5 This seems so simple and straightforward, almost academic; 6
however, in our evaluations we found that sometimes very 7
important missing elements of this type of framework are 8 missing. That is why we are going to focus to be sure that 9
each one of these particular areas are covered in a maintenance 10 program.
11 The next area that we address is the component, 12 systems, and structures. Here, you see that we state that a 13 maintenance program should be developed and implemented for a7.1 14 component, systems, and structure,s. We wanted to make that 15 point very, very clear. We do not want people to believe that 16 because there are certain categories that we have placed 17 equipment in, that there is an area where you can stop 18, maintenance, where there are no maintenance programs required.
19 The example I would give; wlilcn was a perfect example 20 this morning, is the boiler. The boiler is important.
21 Everything in that particular plant should receive the proper 22 maintenance attention.
23 COMMISSIONER ROBERTS: I don't want to draw this out, 24 but,you say that the gauges were registering a high pressure
(,) 25 because? -
~
O 4
. 24 1 MR. ROE: There was' freezing in the lines. '
(3 2 i
s COMMISSIONER ROBERTS: Because the auxiliary boiler 3 was not lit off?
4 MR. ROE: Because the heat was not- supplied to the 5 rooms where these gauges where the lines were located, and the 6 temperature went to the freezing point and solidified the 7 lines.
1 8 COMMISSIONER ROBERTS: Was the source of heat I 9 inoperable? Or had it not been turned on? !
10 MR. ROE: It was inoperable. It was not in service, 11 sir.
12 COMMISSIONER ROBERTS: Thank you.
13 MR. ROE: We have discussed the next point, which is 14 commensurate with its function. We should note that in our 15 policy statement we talk about a priority, and we use the 16 approach here that the priority of maintenance activities 17 should be commensurate with its importance to safety.
18 Next, we show'in this particular policy statement 19 where the NRC's primary focus will be. Our primary focus is 20 going to be on those structures, system,s, and components that 21 have the most regulatory or safety significance. However, we 22 are going to follow through art. our secondary attention is 23 1
. going to be placed on those p?rticular items which don'.t fall 24 into that particular category. We plan to look at both
() 25 particular areas.
. . . j e
o e 1
- 25 1
I think the most important part of the program in -
(m. . .
\ 2 maintenance that the staff desi'res to undertake is the 3 leadership program, which Mr. Szniezek and Mr. Stello have 4 addressed. This is where the NRC staff is going to conduct 5 special team-type inspections at selected sites. Our current 6 thinking on selected sites is probably the majority of sites 7 may be even greater than 75 percent of those throughout the 8 Nation. ,
9 We hope to conduct these particular special team 10 inspections with emphasis on maintenance in approximately two 11 years. We plan to start with a pilot program in the April time 12 frame. We would like to take an opportunity to try th'e program 13 out, to develop the guidance, to utilize the guidance, and also 14 to have an opportunity for the industry to see how we are 15 carrying out this first stage of the program, and give them an 16 opportunity to address what we have done at that particular 17 site, the guidance that we've used, so that we can get their 18 input when we go on to implement the program--a very similar 19 approach as we are taking in the operator requalification 20 issue, allowing there to be an appropriate amount of industry 21 comment into the process. After we have completed our pilot 22 pregram, we plan to implement throughout the Nation in all the 23 regions team leaders and team members--team leaders' essentially 24 from the regional organization, team members from various
. (,) 25 components of the NRC, including the NRR h'eadquarters, the 9
% n. . _ . . _ . - . - _ , ___ ,- ,7 - -
W 26 1 other regional offices, AEOD, and research. .
( 2 We plan to have a significant amount of advance 3 preparation for these particular visits. We plan to have-4 approximately seven or so days on site on inspection time, and 5 we are going to provide the results of these particular 6 assessments and inspections in formalized reports so that when 7 the time is appropriate staff will have a firm basis for their 8 findings, and the recommendations to the commission on going 9 forward with a rule or not.
10 In these particular assessments,. you can see that in 11 the next slide, that we've got several areas that we plan to 12 focus on.
13 (Slide No. 5.] -
14 MR. ROE: As I indicated, we are developing an ,
15 assessment plan and guidance at this point. I would like to 16 point out some of the areas that we would be focusing on in the 17 specific areas of review.
18
- For example, and not to be all-inclusive, in the 19 management commitment area we would be looking at the corporate i i
20 level oversight, the tracking of performance, and the funds and j 21 focus allocated by management.
22 In work control we would be looking at such areas as 23 procedure, job approval, and' maintenance backlog probably with 24 the focus on what we believe is the proper priority. Is the
( ) 25 , maintenance b'eing addressed and worked off associated with the 4
, 27 1 most important safety functions? ' -
~ '
(%
.2 In the area of facilities and equipment, we pay 3 particular attention to the material condition of the plan, and 4 also to such areas as the spare parts and material management 5 and facilities such as shops.
6 In the personnel area, we plan to look at such things 7 as training and qualification, and performance, communication, 8 and actual staffing. As you are aware, there has been a ,
9 significant INPO effort in the training and qualification of 10 the maintenance-oriented crafts.
11 In the area of technical support, we plan to 12 specifically focus on th'e utilization of the facility of the 13 NPRDS system. Is it actually working there? Is it being 14 ,
utilized? Is it an effective system? I 15 We also plan to take a look at how they carry out i I
16 their preventive maintenance, their predictive maintenance, how I 17 they keep their maintenance history, how they go about post-18 maintenance testing and design changes.
19 That concludes the briefing on the maintenance policy 20 statement and the staff's assessment activities, sir. '
21 CHAIRMAN ZECH: All right. Thank you very much.
22 Questions from my fellow Commissioners? Commissioner 23 Roberts?
24 COMMISSIONER ROBERTS: No.
.Q 25 4
CHAIRMAN ZECH:' Commissioner Bernthal.
6 d
. 28 1 -
COMMISSIONER.BERNTRAL's I' don't really'have very many P,
.s -
2 questions, I guess. Gee, this could be a short meeting.
3 Two questions, short ones. If you decided--and this .
4 is speculative at this point--but if you should decide that, !
5 based on public comment, or based on your own observations as 6 you go through some of these inspections, that the rule that we 7 might consider here should be a rather detailed rule, as !
8 opposed to the rule that Mr. Stello apparently' prefers at this 9 point, how would that differ in fact from what we used to refer 10 to as "General Operating. Criteria" here? !
i 11 Now I realize that General Operating Criteria would 12 have been a more inclusive volume, by far, but presumably l 13 General Operating Criteria would also have encompassed this !
14 kind of detail with respect to maintenance, would they have 15 not? !
16 MR. STELLO: For maintenance itself, yes. i 17 MR. ROE: Yes, sir.
18 MR. STELLO: But it obviously wouldn't include all of 19 their aspects.
20 COMMISSIONER BERNTRAL:
No. I understand that.
21 MR. STELLO: This would be one element of that, if 22 you try to get into that great detail. -
23 COMMISSION,ER BERNTRAL: So as you go back and look at 24 what I gather was a fairly extensive study and program laid
(_) 25 down for General Operating Criteria, are you suggesting that we
. d
- . , , - - - - -y
o ,
. 29 1 could almost lift the' maintenance ele'ments of.that and you (s-
! 2 would'have a very strong running start on a detailed 3 maintenance rule?
4 MR. ROE: I don't know if we know enough at this i 5 point to make that judgment. -
6 MR. STELLO: That study that you're talking about 7 detailed all of those things which are already a part of our -
8 requirements, and what you,would be looking at is,what to fill ;
9 in. Remember, that study said we already have quite a bit that i
- 10 we require, 11 COMMISSIONER BERNTRAL
l That's what you just told us
! 12 here, though, about maintenance, as well.
i 13 l MR. STELLO: Now what is it that you have to' fill in?
14 COMMISSIONER BERNTRAL: Right. '
15 MR. STELLO: And how do you have to integrate that in ,
16 its detail? So there would be quite a bit.to add to that.
I 17 COMMISSIONER BERNTHAL: So it would go beyond the 18 proposed operating criteria in detail. I l
l 19 MR. SZNIEZEK: Very possibly. I 20 COMMISSIONER CARR: What you've told us is they're 21 meeting the requirements now, and it is not satisfactory.
22 MR. STELLO: Well, I don't think they're all meeting 23 it.
I 24 MR. ROE We're not convinced that they're meeting 1
(}) 25
~
them. *
- 1 J
e .
30 1 , MR.'STELLO: There are a lot of plants that we really
(~%' .
are having--have cited them for maintenance problems.
1 2 But even 3 those that we aren't citing that are meeting them, it is clear 4 that substantial improvement can be made. I think a lot of it 5 has to do with where we have put our emphasis. We have put so 6 much of that emphasis on the nuclear steam supply part of the 7 plant that you do see an awful lot of the balance of plant that l
8 just simply--the industry I th' ink has followed the regulatory !
9 lead. Where we have put emphasis, they have; and where we
{:
10 haven't, they haven't.
11 Okay.
COMMISSIONER BERNTHAL: Well that answers the 12 first question.
13 .
The second one, getting back to the other scenario )
14 where we do something very, very simple, which I gather would 15 be similar in intent, if not in detail, to what we did for the .
16 proposed fitness for duty policy statement, more or less you 17 say that you shall be drug and alcohol free, and in some sense 18 be able to show it. That was sort of the sum r . astance, 19 and you would propose something similar here.
20 What about the Japanese model?
. Ho . 'fou cons. 'ered 21 what benefits might accrue from the commission sio ' .. ndati'g n 22 a periodic shutdown for maintenance? That seems to have 23 worked--
24 MR. STELLO: What I have described is the Japanese
' ( ) 25 system.
e
- - - ~m , , -4 4 , - , - ,n - - . , - n - a w-. - . - - -,---,m- . er-
\
31 1 '
COMMISSIONER BERNTRAL: The Japanese, by law, require' (TS
- i
( ! 2 a shut down of three months per year. !
l 3 MR. STELLO: Forget that.
4 (Laughter.]
1 5 COMMISSIONER BERNTHAL: Why should I forget'that? '
i 6 MR. STELLO: Because what they also require is what !
7 you do during those three months. You will do this maintenance 1
8 stuff that we agree with.
l 1
9 COMMISSIONER BERNTHAL: And how detailed, then-~ j 10 MR. STELLO: And that is what I am describing.
11 COMMISSIONER BERNTRAL: How detailed--
12 MP. STELLO: How long it takes is another matter.
13 COMMISSIONER BERNTHAL: Ho'w detailed are the 14 prescriptive requirements that Japan has for those three months 1S of maintenance?
16 MR. STELLO: Very.
17 COMMISSIONER BERNTRAL: And so you would propose to la emulate something like that?
19 MR. STELLO: i And that is similar to the FAA system,- 'i 20 where the FAA goes to the airline and gets the airline to get 21 from the air frame manufacturer, get from the engine 22 manufacturer, give me a complete maintenance program for all of 23 this equipment, and gets the airline to propose that in a 24 document, and then the FAA incorporates it into its . i
~
Q_) 25 regulations. .
4 4
4
. _ , . . - _ -m- , , _ , - - . , , - - , . -
' 32 l l' COMMISSIONER BERNTHAL: Okay. I want to get back to
("5 ! 2 the question, though, and'I am not going to forget the three .
3 months' shutdown. Why wouldn't we, then, do something like 4 that do, however prescriptive it gets in dotail?
5 MR. STELLO: Because they don't care how long it ,
6 takes. What you want is to get the program--
7 COMMISSIONER BERNTHAL: We don't care how long it !
8 takes?
9 MR. STELLO: No. We want a good maintenance program.
10 COMMISSIONER BERNTHAL: Why do the Japanese care !
11 about how long it takes?
12 MR. STL'LLO : Well, they are also caring enough now to '
13 come back and ask the question whether they ought to be cutting 14 back, and they're loching to cut back on it.
15 COMMISSIONER BERNTHAL: And indeed they were very 16 conservative, but they apparently are not about to change the 17 requirement for a fixed shutdown time.
18 MR. STELLO: Well, they're looking at it right now.
i 19 COMMISSIONER BERNTHAL: A change in the time, but not 20 the overall requirement for a period of time. !
l 21 MR. STELLO: Oh, no. It is how long. That is what I 22 said. .
23 COMMISSIONER BERNTHAL: Right.
24 MR. STELLO: It isn't so much of a concern as to how
(_) 25 long it ought to be to do this maintenance.
4 9 9 d
33 l l
) 1 COMMISSIONER BERNTHAL: Maybe I am not making myself
\ 2 clear. Why would we not propose a required, howiner long it l 3 is, a required period of time for shutdown as a reasonaole time 4 to perform the required maintenance?
I 5 MR. STELLO: I guess I'm not communicating. I am i
6 answering your question. If you in fact prescribe a particular !
7 maintenance program plan that Thou Sha3t Follow, it will tell I 8 you that you have got to shut down the plant and do this amount 9
of maintenance, and however long that is is however long that 10 is. You have got to do the maintenance in that program plan.
11 A. great deal of it will require the plant to be shut 12 down to do it. When you have to overhaul the feedwater pump, '
13 would you have to pull out the isolation valves and lap valves 14 and tear the valves down? All that 3s going to be spellud out 15 in the naintenance plan. .
16 COMMISSIONER BERNTHAL: Okay. Presumably--
17 MR. STELLO: However long it takes is how long it 18 takes.
19 COMMISSIONER BERNTHAL: Of course.
20 MR. ROE: Commissioner, I think I can give you an 21 answer that shows the approach that the NRC has taken versus l 22 the approach that the Japanese have taken.
23 The Japanese have taken, from what my understanding 24 is, a time period. After so many calendar months or days,
(_) 25 hhere is a shut down. And there are.certain types of e
34 1 surveillance testing and other maintenance activities conducted
<~s'
! 2 during 'that time period shut down.
3 The NRC has not as much in that particular. area of ,
4 when the plant shuts down requirements. We do have 5 requirements that necessitate the plants being shut down to 6 accomplish them. But we allow it to take place on the normal 7 refueling cycle. There are a considerable amount of
'8 requirements in the Standard Technical Specifications that have 9 to be conducted at the refueling outages.
10 COMMISSIONER BERNTHAL: So you think what the 11 Japanese are doing is unnecessary; that they should simply 12 require their list.of things, and not, require a specified 13 period of time? Isn't that what you're telling me, that if 14 they've got the list and it is complete, that they shouldn't 15 care how long it takes? ,
16 MR. STELLO: That is my view. As long as the 17 maintenance is done properly.
18 COMMISSIONER CARR: I doa't think that's right.
19 COMMISSIONER BERNTRAL: Don't you think it is an 20 appropriate discipline to ens"re that shortcuts aren't taken to 21 do what they do?
22 MR. STELLO:
Well, I am more interested in getting 23 the job done right. If that takes a week--
24 COMMISSIONER BERNTHAL: We all are'.
(_) 25 MR. STELLO: --fine. If it takes a month, fine. But D
4
' I i I
. 35
{
1 -
to get the right maintenance'done, however long it takes, it p '
i 2 takes; and what the Japanese are looking at is whether or not 4 l
3 they can still do all of what needs to be done in a-shorter
{
4 period of time, and they think they ,an .
5 Now whether or not it will turn out that they can't 6 shorten it, that is their judgment. But I d9n't think that one 7 can sit here and decide, well, let's just shut the unit dOwn 8 for a month a year. If you look at reality, our units on the l
9 average are shut down more days by close to a factor of 2 than 10 'che Japanese are now. l 11 Our average plant availability capacity factors run, i
12 as I recall, roughly 20 to 25 percentage points lo9er than the 13 Japanese. Or another way to say that--
14 COMMISSIONER BERNTHAL: 'Yes, but that's got all'the 15 unplanned shutdowns in it. That is,not planned.
16 MR. STELLO: l But the total amount of time the plant !
17 i is shut down per year is longer in the United States than it is 18 in Japan. !
19 COMMISSIONER BERNTRAL: But those are unplanned 20 shutdowns, in many cases. They are not--
21 MR. STELLO: During those unplanned shutdowns, they 22 are fixing things.
23 .
COMMISSIONER BERNTRAL: Indeed.
24 MR. STELLO: That is what they do. And the total
(,) 25 \
amount of. time that the plants are' shut down in Japan to fix I b
9 *
, 36 1 things is shorter than it is in th'a United States, on average.
('. '
2 COMMISSIONER BERNTHAL: Let me try it this way. For 3 all the list of things that you think need to be done, would' 4 any reasonable person expect it to'take at least a week?
5 MR. STELLO: I think it would take considerably more 6 than a week.
7 COMMISSIONER BERNTRAL: Okay. Would any reasonable 8 person expect it would take a month?
9 MR. STELLO: I think it would take more than a month. I 10 I think the typical average is on the order of six weeks.
11 COMMISSIONER BERNTHAL: I would think so, too. So 12 why, for example, t, hen would one not mandate--I'm just asking 13 whether you've looked at this carefully--why would one not 14 mandate, as a minimum, six weeks, as the minimum amount of. time 15 that could reasonably be expected to be required for l 16 maintenance' That is really what we are talking about.
17 MR. ROE: I think our approach really accomplishes 18 that.
19 l COMMISSIONER CARR: But Fred, do you think that ought 20 to be six weeks in a stretch? Or six one-week periods? You 21 don't care, do you? I l
22 l COMMISSIONER BERNTHAL: That is a separate question.
23 I am not sure that matters.
24 COMMISSIONER CARR: Well, it is not separate because
( ) 25 I think what Vic said is they are shut down doing the same' 4
9
37 1 amount of maintenance,'whatever the' reason they shut down.
! b.
2 MR. STELLO: I think what I said--
3 COMMISSIONER BERNTHAL: I don't care whether it is 4 cumulative or whether it is broken out. -
5 COMMISSIONER CARR: And they are getting the same 6 amount of time.
7 MR. ROE: Let me see if I can clarify--
8 MR. STELLO: Let me answer the question directly. I ;
1 9 don't think we ought to specify time. I don't think that's 10 what we're trying to do is specify time, but rather a 11 maintenance activity that is proper. If they can do it in six 12 weeks, fine. If they can do it in four weeks, fine. If it 13 takes them twelve weeks, so be it.
14 I think the issue is: What is a good maintenance 15 1
program for the facility? A,nd that is what we ought to be 16 3
striving for, and however long it takes, in my view, it takes. 1 17 And if they cars be innovative, if they can find ways to do 18 things efficiently, or plan things very well-- !
19 COMMISSIONER BERNTRAL: The question is not however ,
20 long it takes; the question is however short it takes, and 21 whether that should be considered adequate, it seems to me, and 22 you're basically saying it works both ways?
23 j
i MR. STELLO: I don't mean to pursue the point, but I l 24
- am more interected in the quality of the maintenance activity,
! ( ). 25 and that that be done correctly. l O
t #
38 1 COMMIS'SIONER'BERNTHAL: That is'what we are all ,-
O.
t 2 interested in.
3 MR. STELLO: And I,think that focusing on time 4 detracts from that. So I would prefer not to, but you have 5 raised the point. I think we ought to think more about it--
6 COMMISSIONER BERNTHAL: You have not considered this 7 possibility.
8 MR. STELLO: --we have not thought very carefully 9
about it, and I think the total discussion on the issue has 10 been here at this Commission meeting. But my instincts tela ee 11 that what we really want to focus on is a good, solid 12 maintenance program that is implemented, and implemented well, 13 rather than being concerned with trying to decide.
14 COMMISSIONER BERNTHAL: Well, I don't disagree with 15 that.
The point I was trying to make is that this system, 16 whether it is too long or not, there is a minimum reasonable 17 time I think under any circumstance. It seems to be one that 18 has worked extraordinarily well for Japan, and if we are going 19 to get serious about this, it seems to me it behooves us at -
20 least to look at what they have done and consider whether 21 something like that should not be a part of this policy.
22 Enough said.
23 CHAIRMAN ZECH: Commissioner Carr.
24 COMMISSIONER CARR: The briefing is all right, but
( ) 25 can we get into the policy statement itse'lf?
39 1 .
, ' CHAIRMAN ZE.CH: Go right ahead.
O' t
2 COMMISSIONER CARR On the front page, why do we call 3 it an "interim policy statement," if it is going to be a policy 4 statement?
5 MR. ROE Simply because it would allow public 6 comment and then it is written in final stage aft.or the public 1
7 has had an opportunity to give their comments, and we want to !
8 assure that we start using it right away. That is why we havn 9 used the term "interim," sir.
10 MR. STELLO: What we are asking the Commission to do-11 -
12 COMMISSIONER CARR: Is that the way we have to do it?
13 MR. STELLO: No. You could issue it for comment, and 14 then issue it-- '
i 15 COMMISSIONER CARR:
Why can't we just issue it as a '
16 policy statement?
17 MR. STELLO: Right now? Today?
18 COMMISSIONER CARR: Yes.
19 MR. STELLO: And rake it enforced? Yo,u could.
20 COMMISSIONER CARR: Well, there is nothing to
- 21 enforce.
l 22 MR. STELLO: Well, it is telling the--
23 MR. SZNIEZEK: It will be in force the day it is 24 issued , but it is interim because we are going to be
(_) 25 implementing it while we are going to the public' comment stage.
e 8
- 40 1 COMMISSIONER BERNTMAL: There is nothing to enforce.
(~% '
- t -
2 I repeat what Commissioner Carr just said.
3 MR. STELLO: I think it is asking the Commission to 4 speak and, until the Commission agrees, this i's what its policy 5 is.
6 COMMISSIONER CARR: Oh, if it is just interim until
)
7 we approve it, I can understand that.
8 MR. STELLO: It is interim because what we are L
9 suggesting to the Commission is we want you to agree to tell l 10 the industry: This is the Commission's policy. We would like 11 your comments on it. When we get your comments from the i 1
12 public, we may wish to change this--it may be a substantial 13 changer it may not. And than when we make a change, we will l
14 issue it and say: Thia is now the Final Commission Policy j 15 Statement on this matter. This is what we always do. It is l
16 not unusual. l 17 The reason for saying "interim" is because we are 18 r.uggesting to the Commission to tell the industry this is our !
l 19 policy.
J j
l 20 CHAIRMAN ZECH: You want to make it effective, and 21 you also want to have comments on it.
22 MR. SZNIEZEK: Yes, sir. 1 That is exactly right, i 23 MR. STELLO: And that is the reason for the 24 "interim."
I j () 25 COMMISSIONER CARR:
But all we are telling them is e
. 41 1 'that they ought to have a maintenance program. .
2 MR. STELLO: That is right.
3 COMMISSIONER CARR: And that is a good policy. I 4 don't see why it has to be "interim."
5 MR. STELLO: W6 . it has a few more things in it.
6 There are a lot of utilitie. that are not now doing those 7 things.
8 COMMISSIONER CARR: Well, look at page 2. I would 9 like- "appropriate to its prescribed function" bothers me. I 10 would like to just put a period after "level" and say "maintain 11 at a proper level." Everybody is going to look at "appropriate i
12 to'its prescribed function" and read that in a different sense, i
13 .if you are on the same policy page as I am.
14 MR. SZNIEZEK: Yes, sir. '
15 COMMISSIONER CARR: That same thing in the last 15 paragraph there.
l 17 MR. STELLO: Yes. 1 18 COMMISSIONER CARR: Some guys may not think they need i
19 that "off-site boiler" there t,o keep their--they may think the 20 heating is going to come some other way, by sunshine or 21 something. It wasn't put in there to keep the place warm, l 22 probably.
i 23 On the next page on definitions, I think you need to 24 include "post-repair testing and post-repair records." The
(_)25 whole thing of whether this thing is going to work or not is i l
, e *
]
, 42' 1 whether you are going to have a good machinery history so you l
((~. 2 can get reliability in the maintenance. We don't want them to j
,3 be doing maintenance for maintenance sake. We want them to be 4 doing maintenance on the things that require repair, or require 1
5 being looked at before they break.
6 So that is equally important to have the records and 7 the post-repair testing in the definition.
8 MR. ROE: That particular definition in the "for 9 example" section of "repair surveillance" was not meant to be 10 all-inclusivo. It was just a list, but we will put those in.
11 COMMISSIONER CARR: And I was just giving you another t 12 idea'.
13 The same on the next page.
I think "reliability 14 centered maintenance" belongs in that program for the 15 development and implementation.
16 On Commissioner Bernthal's point there, the Japanese 17 when I visited them are doing an extensive review now because 18 they keep opening up things in this mandatory period looking at 19 them, that don't requ' ire any repair, and putting them back 20 together again, and they've done that time and time again. Now l 21 they're thinking, why do we do this?
22 COMMISSIONER BERNTHAL: That's right.
l l
23 COMMISSIONER CARR: So I think we need to make sure l 24 that doesn't occur.
,,) 25 -
I am uneasy- when you get to 'the "component, systems,
, 43 1 and structures" list. I was going along great with this policy
~s'
( statement when we were talking about "all systems," and then 2
3 you say: Well, but we're going to prioritize and make sure 4 that we give more emphasis to those "safety systems."
5 I, as you know, don't believe you can have two 6 maintenance philosophies. You've either got a good maintenance 7 program and it extends throughout the plant, or you don't have. ,
8 I would like to delete the list of what they need to maintain 9 and make sure they maintain it all. You've said "all systems."
10 MR. STELLO: We mean that, too. But I think in 11 fairness--
12 COMMISSIONER CARR: Well, having said that, why do 13 you say, but "these" are really important?
14 MR. STELLO: Because we want to tell them we have to 15 be careful of how we're going to allocate resources, and we're !
16 going to be emphasizing those things that have the most \
1 17 important safety impact. That's all.
18 COMMISSIOllER CARR: We can emphasize that if we want 19 to. We can tell them to emphasize everything.
20 NR. ROE: I think that's what it says, sir.
21 MR. STELLO: We have.
22 COMMISSIONFj CARR: It didn't say that to me. ,
23 MR. STELLO: Oh, okay. That's the intent.
24 MR. SZNIEZEK We have not relayed the right signal,
( ,) 2 5 then.
- 4
- e
)
e 44 1 MR. STELLO: Our intent is to do what you said.
{
("\ '
l 6 2 They've got to do everything, but we're going to be i 3 prioritizing where we've spent a lot of resources, depending on 4 the safety' significance. '
5 COMMISSIONER CARR:' Yes, but if we find out something 6 in the secondary plant is shutting them down all the time, 7 we'll emphasize that.
l 8 MR. STELLO: You bet.
9 MR. ROE: You bet.
I 10 COMMISSIONER CARR: Okay. But they won't get that 11 message from this, because it's not one of the things you 12 listed.
- 13 MR. STELLO: Okay.
We will fix it.
14 COMMISSIONER CARR: Now when you say you are going to 15 inspect licensee maintenance programs at "selected sites," what 6 is the criteria for selection?
17 MR. SZNIEZEK: Let me address that. We didn't want 18 to say "all," because there might be a couple where we've done a
19 a s'afety system functional inspection that looked at 20 maintenance, so we're not going to go back maybe in that two-21 year period. Like Jack said, it will probably be 75 or 80 1
22 percent or so. We just didn't want to commit to all of them, 23 to say that in this document, t
24 COMMISSIONER CARRi So what is the criteria for
.\ ) 25 selection of the 75 'ercent, p then?
. 45 1 MR ROE: It is more of'a'deselection. For example, p
i 2 we are going to do a maintenance inspection this coming month 3 at the Perry Nuclear Power' Plant, and we will probably not put 4 them in there because-we will have already looked at them. We -
5 have done some detailed looks at Rancho'Seco before restart.
f 6 We probably will not go back and put them in the particular 7 pool. It is more the ones that--
8 COMMISSIONER CARR: I am not sure we can afford to do 9 that from a resource standpoint. You realize that they top 10 each other. If you go and look at one plant, pretty soon 11 everybody will call them up and say, what did they look at? It 12 isn't as if they're going to--the word is going to get around l
13 on what you're going to go look at when you go look at these 14 maintenance programs.
15 MR. SZNIEZEK: There is no way, Commissioner, they 16 can prepare for one of our inspections. There is no way that 17 they can prepare. When we go in and look, that we look at from i 18 the sampling basis changes. l We select different components. ;
19 At one plant we may look at auxiliary feedwater pumps. In 4
20 another-- -
21 COMMISSIONER CARR: Well, then, you won't get a 22 comprehensive look at any plant.
23 MR. SZNIEZEK: Oh, yes, we will. You can't look at 24 every component, but you look at their program; you select
, (,) 25 components, and those component listings can change from plant 9
' 4 9
- v-- ,
. l
, 46 1 . to plant. I bs '
2 COMMISSIONER CARR: All the more reason I don't see i
l 3 why you should go to every plant, but that's--if we can afford 4 it, fine; but I am worried about the resources. It is going to '
~
5 l take a lot of people. !
l 6 COMMISSIONER ROGERS: You said 75 to 80 percent, did 7 you not? l l
8 MR. STELLO: Yes, in two years.
9 MR. ROE: In two years.
10 COMMISSIONER ROGERS: That is a lot of resources. . 1 11 COMMISSIONER CARR Well, if I might make a 12 suggestion, I would say we ought to hit these plants that are 13 three in maintenance, first.
1 14 MR. ROE: There's no doubt about that. l l
15 COMMISSIONER CARR: And then we ought to hit a couple lj i
16 that are willing to see what we can learn. But, you know, the 17 idea that you've got to hit 75 percent of the plants to get a 18 feel for what is going on out thera seems to be overkill. But 19 having said that, I will move on.
20 MR. STELLO: Maybe there is a point that I would like 21 to make, that I think as part of what we do in inspection is 22 not just getting information, but the fact that we go in there- l 23
-we find out what the weakness and the problems are, and we get 24 the utilit'y to fix them..
Our whole idea of going through this
(_)25 I
cycle is to get the maintenance programs to'ba improved. And t
l . .
, 47
^
l , as part of the inspection, we will find out where the,
[ 2 weaknesses are and get them fixed. '
3 COMMISSIONER CARR: Well, that is separate from >
4 tryir y to write a rule, which I thought-- -
5 MR. STELLO: Oh, yes.
6 COMMISSIONER'CARR --I thought the explanation you 7 gave me was we're going out to look at all these plants so we ,
8 will know what to put in the rule.
9 MR. ROE No, that is just a secondary effect.
10 COMMISSIONER CARR: Maybe I didn't understand what 11 you told me.
12 MR. STELLO: We want to go out there and do these 13 inspections to make sure that the plants get their uaintenance 14 programs fixed. -
15 COMMISSIONER CARR: What maintenance programs? t 16 MR. STELLO: The maintenance that they do at the 17 facilities.
18 COMMISSIONER CARR We don't require them to have 19 one.
20 MR. STELLO: They all are required to perform
)
21 maintenance.
22 COMMISSIONER CARR:
t You're right.
l 23 MR. STELLO: This policy is. going to tell them that 24 they'd better have a good mainter.ance' program for everything,
( ' 25 and we are going'to go out and'insp6ct and find out if they've 9
4 e
48 Iftheydon't,we'regoingtopointoutwhehethey 1 got that.
("N 2 don't and they'll have to fix it.
3 COMMISSIONER CARR Well, then we ought to just put 4
out a rule saying you'll have a maintenance program, and then 5 we can go in and enforce it. If that is the plan for the 6 inspection, we ought to just do it.
7 MR. STELLO: Well, if we knew how to write that rule, 8
that is what we would be proposing today.
9 COMMISSIONER BERNTHAL: Well, it isn't hard to write lo a rule saying: You shall do a maintenance program.
11- COMMISSIONER CARR: And then if there is something 12 breaks, we can enforce it. Obviously you didn't maintain it if 13 it broke due to lack of maintenance.
14 MR. SZNIEZEK: Yes, but look. We can write a rule 15 that says you've got a' maintenance program, and they can write 16 garbage out there.
We envision a rule that says: Run a 17 maintenance program that encompasses elements. We want to 18 review it and approve it.
19 Now we can spend two or three years reviewing paper 20 and not get out in the plants and see what they're really 21 doing, to see if there are safety problems. That is why we are 22 sending out teams. Are there safety problems? If there are, 23 how severe?
We can take corrective actions when we find 24 problems out there that are impacting safety.
(_) 25 COMMISSIONER CARR:. Okay. I don't have any problem e
6 3 _ --
. +
l
. 49 1 with that. In fact, you led righ't in'to'my next question on
(~;
2 page 7. "It is envisioned that the regulatory approach !
3 embodied in the rule will be to review each licensee 4 maintenance program plan for adequacy." If we don't want to 5 look at paper, why don't we change "program plan" to "results"?
6 So it will read: "To review each licensee's maintenance 7 results for adequacy."
8 MR. STELLO: I would prefer to put "plan" and 9 "results" both.
10 COMMISSIONER CARR: Well, all right, but you said you 11 didn't want to go out and just look at a bunch of paper. They 12 could have the plan there.
13 MR. SZNIEZEK: Right now we want to find out if there 14 are any safety problems in the plants being caused by 15 maintenance. We are going to go out and look at the plants.
16 COMMISSIONER CARR: I thought we were doing that 17 already.
18 MR. SZNI'EZEK Well, we haven't done a good job of 19 that.
20 COMMISSIONER CARR: Well, let's go do that.
21 MR. SZNIEZEK That's what we intend to do.
22 COMMISSIONER CARR: But you don't need this policy 23 statement to do that.
24 MR. SZNIEZEK: I agree. It is part of the overall
(_) 25 push we're taking to beef up maintenance. ' '
I g i
e 4
. 50 1 CO'MMISSIONER BERNTMAL: Then why are we sitting'here l
(I 2 today if we agree on that? -
1 3 COMMISSIONER CARR: Well, as you can tell, I am .,
4 interested in maintenance. J
~ :
5 (Laughter.)
6 COMMISSIONER CARR: And I think we do a lousy job of 7 giving those people the impression that we are going to be
- 8 there looking at what they're doing and how their maintenance 9 program is working. I quit.
10 CHAIRMAN ZECH: Commissioner Rogers.
! 11 COMMISSIONER ROGERS: Well, I was curious as to how l
\ '
12 many people you expect to have on this interdisciplinary team, -
13 and just what this whole thing is going to cost. What are your 14 estimates of the number of people on each team, and roughly * '
15 what you think on an annual basis this program is going to cost !
16 you?
17 MR. SZNIEZEK: i We envision about six to eight people ,
18 on the team, and on en annual basis it should be about 25 to 30 .
i 19 ;
FTE, which we would take from areas that we don't feel are 1 20 quite as important as the maintenance area. We're not asking 21 for additional resources. We are reorienting our programs to l 22 l focus on maintenance over the next two years.
23 COMMISSIONER ROGERS: Well, what doe' that translate
. 24 into in dollars? Do you know? I
(,) 25 MR. SZNIEZEX:. We're going to do it with our own '
\
i
. J rg --+--- --. , - - . . - .- - -r.~ , ., ,,.,-.,,.,--..,,,.,-_,,.r--.p7.,n,, ,..,,,,-wv"*d- v -w on \~~-v'v'-~M+
. 51 staff, primaril',.,with^very'little contractors, so we're not 1 y 3
2 talking--
3 MR. ROE: If we're talking salary and benefits, on 4 the order of $2.5 million.
5 COMMISSIONER CARR: A six-man team on how many days 6 at a site?
7 MR. ROE: Seven inspection days.
8 MR. SZNIEZEK: Seven to eight days, on average.
9 MR. ROE: On-site, sir.
10 COMMISSIONER CARR: You won't get done in two years, 11 then.
12 MR. ROE: We will get it done in two years.
13 MR. SZNIEZEK:
We did a health physics' appraisal 14 program a few years ago in one year with a five- to six-man 15 team. We did every site in the country in one year.
16 COMMISSIONER BERNTRAL: How many plants did we have, 17 and what was the agency's budget at,that time?
18 MR.SZhiIEZEK: A rough answer is about half what we 19 have now.
20 COMMISSIONER BERNTHAL: Half the plants, and what was 21 the budget?
22 MR. ROE: The budget at that time, in equivalent 23 dollars is really hard to address beca.use there was such a 24 large research compor.ent and such a small research component
(, ) 25
_ now to make the correlation. ' .
4 e
._ -^ "
, 52 ;
i
'l MR. SZNIEZEK: We had maybe ,hilf the plants, but we
(*>'
\ 2 had more than half the units. We wrote, as I recall, about 60 3 inspection reports.
4 COMMISSIONER CARR: Seven days at a site for those?
5 MR. SZhIEZEK: It was two weeks. We put together a 6 lot of teams and we went out and.did it. But that is where we 7 started to turn around the health physics program at these l 8 plants, not through additional--
9 COMMISSIONER CARa Ch, I am a firm believer in 10 inspection. Don't get me wrong. I think inspection will do 99 11 percent of the work.
12 MR. ROEt I agree.
13 MR. SZNIEZEX: l And that is why it is in here, to let <
14 . people know we are coming out and looking.' !
15 COMMISSIONER CARR: Well, I had better rewrite the j i
t 16 policy statement to tell them that. Instea'd of being an l 17 assessment team, it is an inspecticn., ,
18 MR. ROE: I agree. l t
19 COMMISSIONER BERNTHAL: Mow many people are going to i
20 be on each team, if I may ask?
21 MR. SZNIEZEK Six to eight.
22 MR. ROE Six to eight.
) 23 COMMISSIONER BERNTMAL: So you've got 80 plants 24 you're going to do.
You take a week per plant, and you've got
- (;) 25 6 to 8 people in the space of 2 years?
4
-)
WI i
. 53 l
1 , .MR. ROE: We do it by sites. We don't do it by .
f3 . -
' l 2 plants, like Oconee 1, 2, 3.
1 e
3 COMMISSIONER BERNTHAL: A week per site?
.i 4 MR. SZNIEZEK: Approximately.
5 COMMISSIONER BERNTHAL: I'm sorry. Go ahead.
4 6 COMMISSIONER ROGERS: Well, it will be interesting to 7 see how you've got it worked out to do it in that period of 8 time. I feel a little uncomfortable about that, i 9 But my concern is a little bit along the same lines lo
, as Commissioner Carr, that the emphasis seems to be on programs 11 rather than results. I hope that this doesn't look as if 12 somehow or other we are taking the responsibility when it is 13 the licensee that is to take the responsibility.
i 14 -
MR. ROE,: Sir, if I could address those two points, ,
15 the first thing is that specifically the staff's intention is 16 to get away from paper reviews and to look at the performance 17 of these programs in the field.
18 I If we were to use the standard approach, they would !
19 i
submit us a paper plan, we would' review a paper plan, we would 20 i
write them back a request for additional information, they 21 'would send us additional,information; we would never know 22 whether it was performing at the plant.
1 23 We want a balanced view. Obviously there will be a
- 24 i
look at the paper when we are out there at the site, but there
(_) 25 will also bd a~1ook at the performance. .There will be a look i .
l l
. .i
1
. l e 54 j 1 at how they conduct ,ma'intenance. Actually, maybe even to. -
{
( 2 follow one job. We found some very interesting things when we )
3 have gone out there and just said, you are going to do this 4
particular pump seal. The last one that was addressed in the - '
5 staff meeting in this particular plant was the pump seal. We ;
6 got ready, set.up all the procedures, and unfortunately they I 7 hadn't drawn the proper seal from stock. So they had 8
'everything ready to go except for they cocidn't do the job.
9 Those are important things to know about the l
10 performance of maintenance. That shows a problem with spare l 11 parts' management--something that would not be seen in just a 12 paper review. So we expect to have a focus on a broad spectrum !
1 13 of activity so we can get an integrated look.
14 I do not believ'e the staff has any intention of 15 \
releasing the burden of proper maintenance programs from the !
16 utilities. As a matter of fact, I hope these maintenance 17 inspections enhance that particular responsibility.
18 COMMISSIONER ROGERS: It is just that all the time I . I 19 \
am concerned that we don't start taking the initiative that 20 really should be the licensee's; that we should be evaluating 21 them and holding them accountable, but I am just concerned 22 about that always, and maintenance is something that they have 23 to do and we will never do. You can look at it, but you won't 24 do it, and they are the ones that have to actually do it.
j ,) 25 MR. SZNIEZEK Our philosophy in maintenance le -
e S e
- 55 another area that has to be, directed.
1 The lihensee is '
- !p 2 responsible for the safety of that plant, but we are here to-i i
j 3 .make sure they carry out their responsibilities. '
l 4
4 MR. PARLER: Mr. Chairman?
- 5 CHAIRMAN Z,ECH
- Yes.
i 6 MR. PARLER: That is not only a question of ,
7 philosophy, but it is a matter, at least in my interpretation, 8 of a statutory requirement. That is really fundamental. It is i
9 their responsibility and it always will be their 1 ,
10 responsibility. This is a regulatory really overview or 4
11 oversight agency.
.i 12 CHAIRMAN ZECH: I certainly agree with that. ;
. i 13 COMMISSIONER ROGERS: 'Well, but you can enhance or '
l 14 , diminish that sense of responsibility by your posture.
What I 15 am saying is I want to make sure our posture is something that i
i '
- 16 reminds the licensee all the time that they have to take the i ;
17 1
initiative; it isn't because we are coming for an inspection 4
- 18 that it is necessary to do something. 'It is necessary to do it 19 to maintain a safe system. .
20 Therefore, I think that that message should raally,be 21 in her,e to a greater degree than I see it in this policy 22 statement. It doesn't really say that, and I think it is 23 something that should be said, and said, and said until it is
{
24 just automatic.
1 x_] 25 The other point is that i,n the feedback' area it is a ,
i t
e 4
. . - - - - - , - - - - . , - - . . ~ _ , _ _ . - _ , _ _ _ _ _ _ _ , ..m. , .,,.m. , , _ ,,-m,._, ,._.__-,,.r-_ . . . .._,_.,_,-m . _ , , _ , , _ .
' 56 1 little detailed, but I don't think there 1s any~ sense in here .
( 2 that I picked up that'the use will be made of information with 3 respect to maintenance from other sites, and from other plants' 4 experience. .
5 Now I know that that is expected, but somehow the 6
lessons learned seem to be related to the lessons learned at 7 that particular site. It seems to somewhat imply that.
i It is 8 not necessarily so, but it should be an obligation of course to 9 the licensee to make sure that they are totally informed about 10 any kind of maintenance procedures that evolve from experience 11 elsewhere in the world, and that ought to be part of it.
12 MR. STELLot I think that this is an area'Where we 13 and INPO need to focus on that very hard.
14 -
COMMISSIONER ROGERS: Yes.
- 15 MR. ROE
- We have seen some positive steps taken by 16 INPO in this area. The peer evaluator program, obviously in 17 going to another plant when it is your responsibility back at 10 your particular plant to see how others do it, and the 19 exparience is very positive also; there are initiatives in the 20 area of maintenance managers workshops. It is good to pusvide 21 this type of lessons learned back and forth, and we hava seen-22 that it has been fairly effective.
23 COMMISSIONER ROGERS: And just a comment, that the 24 covering memorandum from Mr. Stello on this policy issue seems
( j 25 to indicate a much greater degree of uncertainty as to whether 0
9
d
, 57 1 a rule wil,1 actually be issued or not than the policy statement ;
( ~^ l t 2 seems to indicate itself. The thrust of the covering j 3 memorandum says that there will be a two-year period to 1
j 4 evaluate the effectiveness, and to decide whether a maintenance i
! 5 rule is required, and if so what form the rule should take; 6 whereas this policy statement simply says, as I read it, that 4
7 we are going to get started on writing that rule, period. It l 8 really doesn't say that there is an uncertainty as to whether I i i 9 that rule will ultimately be put into effect.
.I 10 So I would read the covering memorandum frem Mr.
l 11 Stello as a much weaker commitment to put in place a rule than l i
12 the interim policy statement would indicate.
And of course it l 13 is the interim policy statement which will become the public 14 document. So that I think we should be clear on where we stand 1
15 on that, because I would read your covering memorandum to i 16 indicate that, well, we're going to test this idea of a rule by l 17 putting this policy statement out and consider it, and at the
, 18 end of the evaluation' period the NRC will decide whether a 19 maintenance rule is required and, if so, what form the rule.
20 should take. .
21 Whereas, I would say in reading the interim policy j 22 statement it seems much more of a firm commitment to put the
{
23 rule into place; it's just that we don't kno'w how to. write it 24 now. So there is a difference in emphasis there, and I think i ( ) 25 we should be, clear on how we are proceeding.
4
, i
. 58 !
1 I wculd say th,at there may be a little uncertainty p' *
\ -
2 here as to just where we do stand on this. Are we ready to go 3 for a rule, and we need two' years to on how to write it? Or' l
- l. 4 are we really genuinely uncertain as to whether a rule is.the 5 best way to go or not? I 6 MR. STELLO: We intend to provide to the-Commission l
l
. 7 the first step in that process, which is an advance notice, in l l 8 March and that will make it clear to everyone that it is the 9 Commission's intent to go forward on rulemaking in this area. l 10 Now whether at the end of that process the Commission 11 decides to issue a rule or not, it is the Commission's i 12 decision. We are going to initiate a process that will lead us 13 down the rulemaking path. i 14 COMMISSIONER CARRt I have a little problem with the ;
15 criteria for evaluation, that you're going to decide whether it 16 is good or not, you know, because they don't know what the l 17 !
critaria is and neither do I on how you are going to say 18 whether they've got a good gaintenance program or not. You 19 have got some criteria in mind?
20 MR. STELLO: I think at the end of a week, with seven 21 or eight people, I would expect that you ought to be able to 22 get from them a fairly good judgment of, is the maintenance at .
23 that facility good, bad, or indifferent, and if it has 24 weaknesses, what are those weaknesses, and what needs to be
(,) 25 fixed to make it okay. ,
l l
l l
i
. . 1
o .
O 9
59 1 ' COMMISSIONER 2CARR Is that. going to' help me make the' b 2 rule, then?
3 MR. STELLO: Well, I think it tells you all of the l 4 things that you might want to consider if you try to write a 5 proscriptive rule for developing a plan. I am not sure that 6 that is the way to go, but I think it would, yes, give you the 7 kinds of things that would be very detailed and prescriptive 8 that need to be in the plan.
l.
It could get as prescriptive as 9
to say you shall do testing, tear down, overhaul every X.
10 There are maintenance rules that are that specific.
11 COMMISSIONER CARR: Right, and as broad as "you shall 12 keep it running."
13 MR. STELLO: Right, which maybe it ought to be. I 14 don't know.
15 COMMISSIONER ROGERS: Well, this comes back to 16 another question I had, which is where do you stand on the l
17 concept of performance indicators for maintenance. Is that 18 part of your thinking here on program evaluation, to try to i
19 develop performance indicators?
20 MR. STELLO: The Commission has directed that the 21 staff look at developing a suitable performance indicator. I 22 just asked Mr. Jordan. Our schedule for that is to try to have 23 something proposed by February. ,
24 COMMISSIONER ROGERS: On maintenance?
(_) 25 MR. STELLO: The Commission has already directed us.
1 .
o 60 i 1 , COMMISS'IONER BERNTHALt Yes. If I may interject on
(%
- 2 that point, one of the comments which I don't guess the ,
3 majority supported, but one of the things which I had wondered 4 prior to the staff "developing suitable performance .
5 indicators," one of the things I had hoped they would do is [
v 6 feed back to the Commission at some interim point what in your 7 judgment could be considered suitable performance indicators.
8 That is not proceeding on the presumption that there are +
9 suitable performance indicators, because I have no doubt-that i 10 if the commission tells you to find some, you will come back 11 with some; but rather to indicate to us what you might think ;
l 12 would be such indicators.
13 I don't want to interrupt Commissioner Rogers'here, .
14 but perhaps before the end of this meeting we copld get an [
i 15 interim report, if Mr. Jordan or someone has a few words on i
16 that subject. !
+
17 MR. STELLO: If the Commission desires, Mr. Jordan is 18 here and c,an ad lib'the status of that. '
19 COMMISSIONER ROGERS: I would be interested in 20 hearing that.
21 COMMISSIONER BERNTRAL: Yes.- I think it relates very :
t 82- much to this question of program evaluation and how you are ;
33 going to be looking at evaluating programs, and on what kind of i 34 a basis. Performance indicators is coming to grips with that t i
(_) 25 question. Trying to develop performance indicators is l
s e a
61
,1 certainly the,first. step towards being able t6 evaluate a b 2 program, in my opinion.
~
3 CHAIRMAN ZECH: Let's ask Mr. Jordan to step up to 4 the microphone and give'us a very brief status report. Would 5 you, p.1. ease.
6 MR. JORDAN: Yes, sir. Ed Jordan at EOD.
l 7 The performance indicator that we have found to be 8 most practical at this time for maintenance is a cause Code 9 across the existing performance indicators that would include 10 maintenance as one of the causes. Jack Roe alluded to that by P
11 sc.ying that in identifying some of the plants with poor l 1
12 maintenance, the cause of significant events for instance was i 13 maintenance in many cases. So when we look at scrams, 14 significant events, safety system failures, those kinds of 15 existing performance indicators with a cause code and we find a 16 particular plant that has maintenance as a cause predominant 17 c'rer the other causes, then we have a case to say that there is 18 perhaps a problem with maintenance at that plant.
19 So the staff has collected a great deal of data. We 20 do expect to come to the Commission in late February or March 21 with a proposal for that kind of an indicator.
22 CHAIRMAN ZECH: All right. Thank you, very much.
23 Anything else, Commissioner Rogers?
24 COMMISSIONER ROGERS: No. That's all.
(_) 25 CHAIRMAN ZECH: Just len me make a couple of 4
6 4
. _- .Qe *"* " ' '
i o 62 1 comments, and maybe a couple of questions, and p'erhaps my
(-,
~
2 fellow Commissioners will have oth'er comhants or question's on 3 this very important issue. -
4 First of all on criteria, it seems to me that 5 although this has been mentioned at the meeting, before yod go '
6 out on your first inspection that you really ought to have a 7 criteria developed so that you will have some kind of a 8 standard to go on. .T am aware of the fact that INPO has been 9 involved in maintenance programs and evaluations and !
10 assessments, and they use what they call "guidelines." It seems 11 to me that we need what I would term "criteria" so that your i
12 people going out really have a good idea what to look for.
13 It also leads me to the conc'ern about qualified 14 inspectors and team members. We are taking on a rather focused 15 area. I would hope that we would have people that have 16 credibility and maintenance background so that we can be i 17 confident that their assessment is a proper one. l 18 !
' Are we going to do any specific training? Could you
\
19 speak for just a few minutes on the type of people we intend to 20 send out, and perhaps their background?
21 MR. ROE: Sir, I can address two of the comments you 22 have made so far. The staff understands the need for a 23 criteria and an assessment or inspection plan. We have one 24 under development now. It is going to take a logical approach.
(_) 25
~
, There will be specific types of worksheets and logic flow'
-v,<.,
w ,
. =
, 63 1, diagrams so that we are abid to cover the areas in the sampling O
s
?
2 basis that we think is important and things that show relevant 3 in one area to be sure that we follow up if there is a 4 relationship to another.
5 With respect to qualified individuals, based on our 6 knowledge of the capabilities of the Headquarters staff and the 7 region-based staff, we believe that we have sufficient numbers 8 of qualified people to carry out the program. We do intend to 9 provide them training on the program on what we expect to be 10 looked at, and how we expect to find these to be sent back in f
11 to us, sir.
12 CHAIRMAN ZECH: I would suggest that you might want 13 to look at the regions, and perhaps the residents. We have a 14 lot of talent out there, too, and I am sure we have some of our 15 people in those areas that could be really helpful, and you ,
16 might want to put them with your teams if they have a certain 17 expertise that you feel is valuable.
18 It also might be worthwhile to use the peer approach.
19 I wouldn't see anything wrong with getting an expert to go with 20 you from parhaps outside our agency that would be able to 21 provide expertise that might be valuable.
22 In other words, my view is that we need the criteria.
23 We need competent, credible inspectors; and it also concerns me 24 that we are only going to make a single visit. I recognize
() 25 there are tremendous resources involved in this really, and I
, e 6
4 64 1 appreciate the fact that you are going to refocus resources, -
( 2 andIdob'tthinkwecandoitanyotherway. But this is a 3 big commitment, and with only making one visit to the site I 4 guess my concern would be that the first few visits I'm sure 5 you're going to learn a lot. But with only one visit to the 6 site, it is going to perhaps be a challenge to make sure that i
7 we can be confident of our own evaluation and our own l 8 !
assessment, especially on those first few visits.
9 So I would ask that you go into perhaps some special 10 planning, or even your own training period, before you launch l
11 off on this very significant effort.
12 MR. ROE: I agree with you. I think that one of the 13 benefits that we hav~e at this time in the maintenance team that 14 is going to carry out this program from the Headquarters is the 15 branch chief that will be in place when we carry out this 16 program has extensive regional experience, including being a 17 member of the Performance Appraisal Team.
18 The two section chiefs that I have involve,d in this 19 particular area, one of them that is principally involved has 20 had experience in a multitude of these particular assessments 21 already. The other one that I have that provides us expertise 22 and assistance was a senior resident inspector and has a streng 23 background not only in operations but in construction, so he 24 understand = a great deal about the codes and requirements .:f T ) 26 maintenance from that aspect.
- 1
. . l 4 65 1 *So we believe that we have strength there. But-
/N .
s 2 certainly we will' heed your words and make sure that we provide j 3 the training that is necessary to do a competent job.
4 CHAIRMAN ZECH: Just a word on maintenance 5 performance indicators. It is my understanding that~we have a 6 program--you can call it a performance indicato program I 7 think--that is going to affect a lot of data, Inyway, that we 8 have beeh collecting for many years. It seems to me that 9 perhaps that is being used in your attempt to come up with a 10 performance indicator for maintenance.
11 i
But isn't it true that we do have a considerable 12 amount of data that we have available to us maybe ov,er a five-13 year period that could give you at least some kind of a 1
14 benchmark for establishing criteria for maintenance?
Is that 15 true? That is my understanding, but I would appreciate your 16 educating me if that's not correct.
l 17 MR. ROE: There is a fairly reasonable basis of 18 information. One of the shortcomings is that a lot of the 19 reporting requirements the Commission has does not take a look j i
20 at the balance of plant and other important systems, and that )
21 is extremely important to the staff now.
22 In the policy statement, in our approach, we have 23 told you that we believe that maintenance has got to be carried 24 out for all the systems.
(,) 25 CHAIRMAN ZECH: Well, but isn't it true that the 9
O o
66 1 NPRDS system-- - -
n
( .. .
f 2 MR. STELLOi Oh, yes. Yes.
3 MR. ROE: Yes.
4 CHAIRMAN ZECH: --that INPO has, we have all that 3
5 information at the Commission available to us?
6 MR. STELLO: Yes.
7 CHAIRMAN ZECH: Do we not?
8 MR. STELLO: Yes. Absolutely.
9 CHAIRMAN ZECH: So that is a tremendous amount of 10 bank, I would believe, of relevant information.
11 MR. STELLO: And I think in addition you have a 12 rather significant summary of overall maintenance in the SALP 13 reports over the years. While they did focus on particular 14 aspects, they nevertheless are also an indicator. But the 15 NPRDS detailed component ~ failure is available.
16 CHAIRMAN ZECH: All I am saying is that when you.are i 17 setting up really a very aggressive and new program like this, 18 we want to get together and use as much available data as we 19 can.
20 MR. STELLO: Yes.
21 CHAIRMAN ZECH: My concern is that you have credible 22 people, that you have criteria, that you really start out on 23 this adventure with a fair amount of confidence and background 24 that you can make a good assessment because an awful lot of
() 25 resources are involved in this,.and we want to make' sure that t
4
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1 we accomplish something. As we discussed earlier,.it is s 2 resul'ts we are looking for, and we are looking for improvement.
3 My view is that there is room for improvement in ,
4 maintenance, and in some plants there is room for a lot of 5 improvement. Generally speaking at least, to some degree there 6 is room for improvement in almost all of them.
7 So I certainly commend the program. I do think that we probably want to move, my view is, eventually toward a rule.
8 9 That is certainly what I have in mind. But I think that we 10 must walk before we can run here because it is the utility 11 responsibility for safety of operation, as well as for l
12 maintenance, and.we are the regu'lator and not the operator. ,
l 13 That has been pointed out earlier, and I think we must continue !
14 to be mindful of that.
15 On the other hand, if we are going to regulate safety 1
16 properly, maintenance is an area that I think is important that 17 we get into in a vigorous sort of way.
18 Well, let me just ask--
19 COMMISSIONER ROGERS:
i Excuse me, Mr. Chairman.
20 CHAIRMAN ZECH: Yes. l Go unead. ;
1 21 COMMISSIONER ROGERS: If I could just follow up on a 22 point that I think you opened there, and I think it is a very 23 interesting one that hadn't occurred to me.
24 CHAIRMAN ZECH: Please.
(_) 25 COMMISSIONER ROGERS: That is, that we are committing 9
9
4 l
, 68 i considerable resources to this effort, this in.spection effort.
() 2 It'may very well be that we might decide that this should be a 3 continuing activity of the commission; that it is not just to 4 write the rule, but it is the way things ought to be done in 5 the future. And that might or might not be the case, but I 6 think we should anticipate that as a distinct possibility.
7 It seems to me that we are changing the situation, 8 perhaps in a very signif.icant way in terms of . commitment of 9 resources and our expectations from that commitment, and I 10 think we ought to have something we can measure. I think that 11 some thought should go into--it probably has already--but 12 trying to start off with a base here that we kno'w where we are, 13 and then as a result of this program and whatever resources we 14 are committing to it, some results should be apparent. They 15 won't be apparent immediately. They will be apparent 16 particularly if this performance indicator that Mr. Jordc.n 17 spoke about is the best one, then that is a delayed reaction 18 indicator. You are not going to see a big change in these 19 numbers immediately, even if you have a big change in 20 maintenance, or you might not.
21 So I would say that it will take several years before 22 that indicator is one that is going to really give you 23 definitive numbers that you really feel that this thing really 24 has made a difference. .So I think that it is important to
' ( ,) 25 think of this.'as not only a progr'am to accomplish something,. .
c-4
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- 69 1 but also in a sense an experiment that should yield us some 2 data as to what our investment here produced.
3 So you want to start off with some kind of a common 4 base of data that then you will start to compare to three, 5 four, five years down the road. I think it is very important 6 at the outset to give some thought to designing this program 7 not only in terms of what you hope to accomplish, but how you 8 are going to measure what you think might take place.
9 So from the standpoint of experimental design, I 10 would say I would encourage you to give some thought at the 11 very beginning that when you start this clock going, these 12 inspections an'd results and so on and so forth, that three,
~
13 four, five years later whenever it is appropriate to make a 14 comprehensive measurement, you can go back and look at the 15 situation that you started with, the situation you wound up 16 with, and try to see whether in some sense this program really 17 did accomplish something in a very measurable way.
18 i Now that is always going to be hard because you are l 19 dealing with very complex system, and a lot of other things are 20 changing, kind of isolate the variables and so on and so forth 21 '
to the degree that you would like, but as much as possible I 22 would encourage you to design the measures of performance of 23 this program, this new program, at the very outset.
24 CHAIRMAN ZECH:- And that is exactly what I had in
(_j 25 mind, too, and I thank you, Commissioner Rog'ers, for'those 6
4 o 70 1 comments. Because when I.am thinking of criteria to start '
'(O ,
2 with, and so forth, as Commissioner Roger" pointed out, too, j
?,
another way to say'that might be to start with a benchmark so i 4 we can measure it, so we can measure performance and results.
5 So I think the criteria should be very well thought 6
out and be considered kind of a benchmark to start with so that 7 we can measure progress as we go along. In other words, I l
8 think we should try to make this as professional, thoroughly 9 credible ambitious program that it is, but credible and 10 professicnally recognized as something that really can be 11 measured to the extent that you can measure'these difficult 12 areas.
13 But also I think it has'the opportunity, the 14 possibility, of even going perhaps beyond the maintenance and 15 can allow us to be aware, for example, of the problems we .
16 mentioned earlier of conditions that might cause the plant to 17 shut down, or whatever. -
18 For example, we really should be thinking about is it 19 really right to continue to run surveillance and testing while 20 the plant is operating, to the extent that we do? Are there 21 maintenance that we allow and encourage now when the plant is 22 operating, even at 100 percent power, that we really should
- 23. change that policy?
24 My view is that we do an awful lot of tinkering with
(_) 25 plant, well meaning though it might be, in. testing,.
4 6
e
- 71 i
i surveillance,'and maintenance while the' plant'is operating that .
)
( 2 causes problems, as you've mentioned earlier in the briefing. ,
3 So in other words, it is ndt'just mainten'ance, although we are 4 focusing on that. But I would hope that perhaps we could step 5 back as we look at these programs and measure from the '
6 benchmark up, measure what has happened in results of plant 7 operations, of course always focusing on safety because that is 1
8 our business.
9 But it seems to me that this does have the potential ;
10 for making our regulatory responsibilities--for improving our !
11 regulatory responsibilities, and at the same time contributing 12 ,to safer operations. At the same tim'e, hopefully, making the ;
13 plants operate more reliably and more efficiently.
14 But I do think that this is a very important i 15 endeavor. I recognize that my personal view is we are coming I 16 to this emphasis on maintenance awfully late in the game, but 17 better late than never, and I commend the staff for the efforts 18 you have made so far. )
19 I would ask my fellow Commissioners, too. W'e have )
20 had some specific comments to make on the policy. We have the 21 policy statement. I wou'ld respectfully ask their input as 22 promptly as they can give it to us so we can correlate comments 23 they may have and get back to the staff soon with our own 2'4 decision on the policy statement.
( ) 25 I know my other Commissioners may have other-5
+ 72 1 -
questions. Commissioner Bernthal, you indi'ated c you had.
h) 2 COMMISSIONER BERNTHAL: I bad only the performance 3 indicator one. I think we have beat that cp pretty well now.
4 I would say one thing. I am encouraged by the apparent early-5 on thing that you plan to do--that is, to tag events and label 6 clearly those that are-maintenance-related. In fact, I think 7 all of our performanc.a indicators really are a focus on data we 8 already had and just weren't compiling and tabulating and using 9 them statistically perhaps in the way that we could have been, 10 and I think this is a good start, subject of course to the 11 reservation that Commissioner Rogers mentioned.
12 One quick question. Was the policy statement 13 proposal run by'the ACRS.
Have they looked at it, yet?
14 MR. ROE: It hasn't been proposed to them yet.
15 COMMISSIONER BERNTHAL: When are we going to do that?
16 Shouldn't they look at it?
17 MR. STELLO: The proposal was that they would look at 18 it as part of the comment period.
19 MR. ROE: As part of the comment period, and if my 20 memory serves me it is about the lith or 12th of February where 21 we are going to brief them.
22 COMMISSIONER BERNTHAL: Do we have a comment over 23 here?
24 MR. ZWOLINSKI: Jack is correct.
(_) 25 COM1;ISSIONER BERNTHAL: .All right. Well, a minor e
- 73
- t. 1* point, I guess I am not sure that it has been normal practica 2 that the ACRS is considered as part of the public comment' 3 period.
I would think 'that they would normally look at these 4 things perhaps in tandem with the Commission looking at them, 5 if not before the Commission looks at them.
6 In any case, I would like to have the ACRS comments 7 on the policy statement proposal at it stands right now and any 8 subsequent policy statement draft. I think that is important.
9 MR. STELLO: Well, you understand that it will 10 probably be several months before we will be able to issue 11 anything, even a policy statement.
12 CdAIRMAN 2ECH: The point is, if we do that, and I s
13 think it is appropriate that we do that, should we wait for 14 those comments before.we execute the interim policy statement.
15 Maybe that is a decision the Commission should consider while 16 the we're looking over the statement itself.
17 I think definitely we want the ACRS' comments. I 18 guess the point is, is it better to get them before we issue 19 the initi-1 etatement, or get them during the comment period as 20 we go along. So why don't my fellow Commissioners consider 21 that k'ind of a decision bere in the next few days as we are 22 looking over the comments, at the same time we look at the 23 statement itself.
24 Are there any other comments from anybody?
(_) 25 COMMISSIONER C'ARR Well, I would like to say one a
l e - 74 l l
1 thing about that. There are some uti'lities out there,who are
(~ ~' '
\ 2 doing an excellent job o'f maintenance and it is not all bad, \
i I
i 3 They have all got a program of some sort. I think they are all 4 beginning to realize it is important to do it, and what we are :
5 trying to do is encourage them. But I think it'is important 6 that we be on record As I say, what it is going to do is cost 7 them money, but in the long run they're going to get it back. !
i 8 CHAIRMAN ZECH: Any other comments? j 1
9 COMMISSIONER BERNTHAL: Well, again I want to stress 10 that I would hope and expect to see a serious look at the i
11 Japanese system, being as it is probably the most successful i 12 maintenance system in the world for a program of its size.
13 -
CHAIRMAN ZECH: All right.
14 Let me just conclude, then, by thanking the staff for 15 a very excellent presentation, and also to just emphasize that 16 there is, at least in my view and I think my fellow 17 Commissioners wopld agree with me fully, that there is a clear 18 and direct relationship between maintenance and plant safety, 19 and we should look at our regulatory framework to see whether 20 and where we can improve this.
21 Certainly we recognize that maintenance 10 a utility 22 responsibility, but safety is our business. And if it does '
23 have a direct application to safety, that is why we are 24 concerned.
(_) 25 Let me just say again, I would ask my fellow
. _ . ,
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'75 l l
1 Commissioners to take whatever, actions they can on the policy P' I s 2 statement so that we can come back to the staff promptly. I 1
think'this is a very important program that we should move on 3
4 as quickly as we feel confident that we can.
5 If there are no other comments, we stand adjourned.
6 (Whereupon, at 3:35 p.m., the Commissioners meeting 7 was adjourned.]
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} 2 REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5
meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7
TITI2 OF MEETING: Briefing on Status of Maintenance Program and B PLACE OF MEETING: go:icgb).nhton,D.C.
"'has Statement / Advanced Notice 9 DATE OF MEETING: Thursday, January 7,1988 10 ,
11 were held as herein appears, and thi.t this is the original 12 transcript thereof for the file of the Commission taken 13
{~. stenographically,by me, thereafter reduced to typewriting by !
14 me or under the direction of the court reporting company, and 15 that the transe,ript is a true and accurate record of the 16 foregoing events.
~s /' l i
17 \
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18 .. ...! Ob.... ' .' s
....k.... <
/ Jane W. Beach '
19 20 21 '
22 Ann Riley & Associates, Ltd.
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4
t MAINTENANCE POLICY STATEMENT -
COMMISSION MEETING JANUARY 7, 1987
.r h -- _______-_____--______----w.-_m--. -
. --__ m. - - _ _ - __m _____________.____.m-
1 BACKGROUND
, o INDUSTRY INITIATIVES ARE BEING IMPLEMENTED o WIDE VARIATION IN EFFECTIVENESS o NEEDED MAINTENANCE NOT BEING ACCOMPLISHED OR NOT PERFORMED EFFECTIVELY AT SOME PLANTS o HIGH PERCENTAGE OF FAILURES FROM IMPROPER PE'RFORMANCE OF
, MAINTENANCE
', o MAINTENANCE / OPERATIONS INTERFACE INADEQUATE o MAINTENANCE ,RELATED CHALLENGES TO SAFETY SYSTEMS IS EXCESSIVE e
9 0
4
CONTENT OF TH E POLICY STATEMEN F -
~
SUMMARY
PO LICY o BACKGROUND o POLICY STATEMENT .
ADDITIONAL INFORMATION o DEFINITION OF MAINTENANCE o FRAM EWOR K FOR MAINTENANCE PROGRAMS o COMPONENTS, SYSTEMS AND STRUCTURES -
o NRC ASSESSMENT ACTIVITIES -
i ENFORCEMENT 4
)
i
_ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . . . . .___________-_____m _________.___.______.________v _ _ _ _- _ _ , - , - ,-
1 i
POLICY I POLICY STATEMENT r
~
ALL C0FPONENTS, SYSTEMS, i . STRUCTURES l -
AVAILABLE TO PERFORM~
j-
~
INTENDED FUNCTION j ..
PROMPTLY REPAIRED .
~
- PRESCRIBED MAINIt. NANCE PROGRAM 4
(
O ADDITIONAL INFORMATION DEFINITION OF MAINTENANCE o AGGREGATE OF FUNCTIONS TO ASSURE SAFETY AND RELIABILITf INCLUDES SUPPORTING FUNCTIONS o
FRAMEWORK o ESTABLISH PROGRAM OBJECTIVES o DEVELOP AND IMPLEMENT PROGRAM o PROGRAM EVALUATION
~
o FEEDBACK
, COMPONENTS. SYSTEMS AND STRUCTURES o MAINTENANCE PROGRAM FOR ALL COMPONENTS, SYSTEMS AND STRUCTURES o COMMENSURATE WITH ITS FUNCTION o NRC FOCUS PRIMARY ATTENTION ON LISTED ITEMS
,e O
L.___ . _ _ _ _ ________-__ _ _ _ _ __-___-_ _ _ _ - - - -
o
'6 NRC PLANT ASSESSMENT o EXISTENCE / DEVELOPMENT OF MAINTENANCE PROGRAM PLANT FOUR ELEMENTS -
o SPECIFIC AREAS OF REVIEW MANAGEMENT COMMITMENT WORK CONTROL, (E.G., PLANNING AND SCHEDULING, BACKLOC, -
WORK CLOSE-OUT) ,
FACILITIES AND EQUIPMENT (E.G., SPARE PARTS, TOOLS, PLANT MATERIAL CONDITION)
PERSONNEL (E.G., TRAINING. STAFFI NG, PERSONNEL PERFORMANCE) -
TECHNICAL SUPPORT / INTERFACES e
G S
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p j ADVANCED COPY T0: The Public Document Rocm
,! OATE: /////f<I
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FROM:
SECY Correspondence & Records Branch
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Attached are copies of a Commission meeting transcript and related meeting A 2
document (s). They are being forwarded for entry on the Daily Accession List and &
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