ML20154E452

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Forwards NRC Initial FY85 Base Table for Distribution to Respective Appropriation & Authorization Committees
ML20154E452
Person / Time
Issue date: 11/06/1984
From: Triner E
NRC OFFICE OF RESOURCE MANAGEMENT (ORM)
To: Kammerer C
NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
Shared Package
ML20154D958 List:
References
FOIA-88-237 CCS, NUDOCS 8809160334
Download: ML20154E452 (15)
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II MEMORANDUM FOR: Cariten C. Karrrnerer. Dire:ter i l

Office of Congressional Affairs '

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FROM: Ersin G. Triner Dire:ter  !

Divisien of Budget and Analysis l Office of Resource Managemen. ,

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SUBJECT:

FY 1985 EASE TABLE  ;

i i ,Atta:hed are sufficient cepies of NRC's initial FY 1985 Base Table  !

] for you to distribute to the respe:tive ap;eepriation and authorita. j

tien certittees. t i

] If you have any questions cen:erning the infomation contained in  !

j the table, please cail Rich Shumay er Ray Sanetrik at 492-795E.

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gEdi,in G. Triner. ' Aw.w' Dire:ter

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j Division of Bueget and Analysis i Office of Rescurce Manageren I

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QUESTION 26. The NRC and the Department of Justice (000) are developing a l j ,

4 memorandum of understanding to provide for coordination of i

investigations between the two agencies.

I 1 (A) Describe what problems existed between the NRC and 000 i l which led to the need for a memorandum of understanding, ,

ANSWER.

i j The decision to negotiate a Memorandum of Understanding (MOV) arose not so

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] rnuch out of specific problems as it did from the mutual rccognition of the  ;

desirability of femalizing the procedures for the exchange of investigative information between the two agencies. Both agencies felt that an MOV provided  ;

r for a greater degree of consistency and understanding in these areas, j Moreover, the development of an MOV allowed both agencies to arrive at an '

j agreement ragarding such issues as the timing of investigative referrals and l

) the trechanisms and criteria for either agency to defer actions until the other has taken its acticn. l 1

When criminal wrongdoing in the nuclear industry occurs both the NRC and the l 4

00J are interested in prosecutino such action so as to deter possible future l

! criminal wrongdoing. Normally, the DOJ prefers no action by NRC pend ng l j the prosecution of a c"iminal case. However, when the NRC concludes, based on

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i the conduct which may involve criminal wrongdoing, that icr.ediate action is

{i necessary to protect the public health and 56fety, the NRC has a daty 1

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L QUES 1 ION 26. (continued) to take such action. 00J recognizes NRC's over-riding health and safety resperisibilities. A central purpose of the FOU is to clearly define the process for NRC and 000 carrying out their diffeiint re'pensibilities I

harmoniously.

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1/27/EB EREAUX 026 l l

QUESTION 26. (continued) (B) Describe what priorities have been tentatively agreed to l with respect to NRC refe.*rals to 00J.

ANSWER.

J There has been no discussion of priorities, per se, with respect to NRC' referrals to 00J. The Director. 01, refers to 00J those matters for which the O! investigation has preciced sufficient evidence to support a reasorable suspicien that a criminal violation has occurred. Althoug.' this is normally l

done at the completion of the investigation, the Director. 01, may elect to advise DOJ prior to completion of the O! investigatien. Such a decision may be made on a case by case basis to allow DOJ additional tire to evaluate the I

matter. This eay occur in highly visible cases, when prompt NRC action to protect public health and safety is necessary or when 00J intervention may be necessary to prevent additional criminal activity or the destruction of evidence. ,

The NRC does rot have a forral prioritiration system tar its criminal referrals i to 00J.  !

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1/27/ES EREAUX Q:S l 1

OUESTION 27 In testifying before the Subcomittee on October 8,1987, Mr. Hayes said he would favor legislation codifying O!

authorities and responsibilities as long as certain "guarantees" were included. Describe more fully the "guarantees" envisioned.

ANSWER.

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4 Mr. Hayes has provided the following explanation:

My remark about "guarantees" was in response to a question from Senator Sirpson (hearing Transcript, at page 90, line 21) as to whether "providing a i statutory underpinning for O!" weuld be a satisfactory solution.

My response was that it would be satisfactory were the legislation to "incorporate the guarantees of the Inspector Geneal to the extent...that an ,

l IG Bill does...". This would include at least the authorities currently j granted O! in the original 27 Cemistion-approved O! Policy Statements and ,

j other delegations of authority. A most important feature would be the establishment by statute of OI as a Comission-level office. l I

In addition to codification of its existing authorities end responsibilities, I was also referring to at least three important author' ties given to Inspectors General, but currently not given to 01. These are: (1) the authority of the Director. 01, to appoint, direct, and supervise all sub-ordinate O! personnel, (2) statutory authority to conduct criminal investiga-I' tiers, and (3) a separate appe;riations acccunt to assure O! independence.

l 1/27/38 EREA'JX R*7

OVESTION27.(con %inued) My testimony was meant to reflect my belief that a statutory 01, reportable and accountable to the Commission as we were prior to February 1, 1988, that was granted authorities as described above, would be a satisfactory alterna-tive to making OI a part of a statutory NRC Office of Inspector General.

Without those authorities, I am no longer confident of Ol's ability to continue to provide the quality and quantity of investigative support that it has provided this ageney and the American public for the past five years.

1/27/63 EREAUX Q27

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QUESTION 29. Describe the reasons why the Comission issued a policy statement for training nuclear power plant personnel. Also, a

describe the reasons a policy statement was chosen instead of i a rule in this area.

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ANSWER.

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j Public Law 97-4 $, '.ection 306, directed the Comission to promulgate i

regulations or vther regulatory guidance for the training and qualificat!on of nuclear power plant personnel. After considering the various options i available for regulating trcining and re"tewing existing 'ndustry afforts, l,

the Comission decided that a Policy Stuement endorsing an ongoing INPO program which seeks to establish standards of excellence rather than reeting 4

1 minimum NRC *equireN nts would be the most efficient and effective eachanism 1

l for meeting the intent of the Public Law. The INPO program contained the '

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, eierents of a systems approach tt training which the NRC considered to be  ;

i i i state-of-the-art and later erbraced in rule changes to Part 50 and 55

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published in the Federal Register (52 FR 9453). The INPO progran is l

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enforceable throtgh regulations in Parts 50 and 55 for those utilities which

adopt it. The use of the Policy Statement is conditional on the NRC's continued endorsement of INP0's program. The NRC will censider rulemaking in this area should a change in position occur with lNPO.

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OVESTION 31. Has the Commission deforred rulemaking beyond the original two years? If so, for how long? What are the reasons for extending the deferral period?

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ANSWER.

1 The Commission has approved deferring rulemaking on training and quali'ication of nuclear power plant personnel for an additional 2-year period by issuing a revised Policy Statement. The revised Policy Statement

would continue to erphasize the elements of effective performance-based i

training and would provide for continued eenitoring and evaluation of the INPO

) progran. The respense to Questien 30 discusses the reason for this revision.

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1/07/53 BREA'JX Q31 l l

OUESTION 32. Do either of NRC's investigative organizations (0! and O!A) have any role in auditing or reviewing the INP0-managed training program? Has this option ev9r been formally

, considered by the Comission?

l ANSWER. i The basic functions of 0! and O!A would not routinely involve then in (

auditing or reviewing the INPO training accreditation pr: gram, As a result. {

neither O! nor O!A have had a role in auditing or reviewing the INP0-nanaged training program. To the best of our knewledge, the Comission has never i formally considered such an option. O! might be involved in a review of a j utility's progran if there was a reason to believe that sore wrorgdoing by a l licensee or its employees had occurred in the program, ,

3 1/27/S3 SREAUX 032

1 QUESTION 35. The Comission has testified that the NRC monitors operator license exans and reviews those exams. What is the pass rate for utility-given requalification examinations for operator licensing?

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In the past, the NRC administered and monitored operator requalification examinations enly on a saeple basis. For this reascn. the NRC dees not have l <

, comprehensive records of the pass rate of requalification examinations given "

I j by utilities. Since nor al utility practice is to remediate examination  ;

l li deficiencies and then reexamine the affected operator, we anticipate that the '

pass rate on utility-given recualificatien exaninations wculd be high. I 1

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OUEST!ON 41. During his testimony before the Subcomittee, Mr. Stello said he favored a policy statement on maintenance rather than a j rule, in part, because he did not want to "lese the momentum" by the industry in the maintenance area. Please describe the  ;

soecific examples of industry initiatives contributing to this I l

momentum. ..

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MSWER.

i The industry has taken a number of steps in this area since 1985. Some of i

the most significar,t of these are: .

1. Development of the document "Guidelines for the Conduct of Maintenance at Nuclear Power Stations" (!NPO 05-033). This report pec,vides a ccmprehensive overview for the development, ,

implerentation, and periodic reassessment of a facility's l maintenance program. [

2. Industry Maintenance Selt Assessment. In 1987, all licensees f

conducted a self assessment of their maintenance programs using the l

!  !NPO guidelines. The goal of the self assessment process was to  !

l identify preblem areas in clear and sufficient detail se root causes '

I could be detemined and corrective actions taken. l l  !

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1/27/EE EREA'JX Cal !

OVESTION41.(con %inued) i

3. Formation of the INPO Maintenance Assistance and Review Teams. :NPO formed two teams of naintenance experts to visit nuclear plants upon the request of the utility. Working closely with the plant and corporate personnel, the team focuses on deter-mining the root causes of the more significant traintenance problems. l Recoreendations for improvement are provided to the utility in j writing.  !

l The industry has informed the Comission of its activities through periodic 1

briefings (November 6, 198A; November 20, 1986; May 13, 1987). INPO provided l

l a list of specific activities in a letter from W. F. Conway to J. W. Roe, NRC, 1

1 dated September 10, 1957. A copy of the letter is attached. '

A rajority of the Comission recently voted to direct the staff to go forward with rulemakirg activities in this area. (See answer to question 34).

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Attachment:

INFO Letter i

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yumuN 41 Attaencent l Institute cf

!) Nucle:r Power 1 W Operations suae1500 11oo Cee 7s Penan NOTE: INPO has aoproved releasing N;N[Ed'ssNgoo '

this letter to the public.

September 10. 1987 i

Mr. J. W. Roe. Direc tor Division of License Performance and Quality [velvation .

Office of HRR V. 5. Nuclear Regulatory Comission Washington, CC 20555

Dear Mr. Rot:

This is in response to your letter dated August 17, 1957, concerning development of an NRC maintenance policy statement. The lett<,r requested current, descriptive information atout INPO maintenance activities and .

initiatives. It also sought access to the data collected during iep1ementation of INP0 maintenance initiatives in order to factittate NRC ,

monitoring of industry progress in improving nuclear plant maintenance. l Enclosed is a copy of our current Suesary of Maintenance Activities and a i copy of a March 13,1987 letter to our members announcing the !NP0 raintenance initiatives. Together these documents provide a detailed descriptien of our raintenance activities. We are providing these docueents for your internal use only.

  • Access to the data collected as a result of our raintenance initiative would be accer.modated under our remorandum of agreement for NRC nonitoring of '

plant evaluation results. Specifically, desig.:ated NRC individuals could visit INPQ and review plant specific maintenance self assessment results for  ;

sort plants as selected by INP0. They could also review maintenance assistance and review team (KtJtT) reports ih the sane manner. Cognizant thPO 1 personnel wuld te available to answer questions resulting from the reviews.

In addition, we would brief the NRC personnel'9n generic results and, as we had previously discussed, plant specific data on maintenance indicators g uld l be shared. NRC regional personnel, if involved with these reviews, should not ,

be asked to review plant specific information for plants in their region. l l

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Mr. J. W. Roe. Director 5epte:ber 9. 1987 i 9ett 2 i .  :

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l 1 trust that the above information is responsive to your request. Please cor. tact me if you desire Nrther information.

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, $lecerely.

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William . nway l 2 Group Vice President t

Industry and GovernmentRelations 1 Group .

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I Inclcsures: 1. Sumary of Maintenance 4tivities

2. March 13.1987 letter to our members on maintenance r activities
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, J. Taylor '

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ee viste 4/30/97 5U W RY OF MAINTENANC( ACTIVITI(5 This sumary is intended to identify some of the more significant efforts i

currently being undertaken by the industry to improve the maintenance of nuclear power plants. The tsprovements are the result of a coordinated effort between wtilities. Owner's growCs, the Nuclear Menegament and Resourcel l Counct) (NWAC), the Electric Pe=tr Research Institute (EPR!). !NPO. and otheri. were aseiteenie trendi in perfor.4nce .re ,reiented. .

TABLE OF CONTENTS Section Pit,t A. J0!NT INCUSTAY/INP0 ACTIVIT!!5

1. New initittive to IFprove Industry M4intenance .

PerforW4mCo................................................. 1

4. 5 elf assdssments....................................,,,, 1
b. INPO 5pecial Maintenance Assistance and Reviw Teens.... 2
2. Predicttre M4tatenance...................................... 3
3. Nyman P e r fo rsance i s sue s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
4. Ma inten4nce Peer tv a lwa t9r Pt str4m.. . . . . . . . . . . . . . . . . . . . . . 4. . .

, 5. Long. rang e Pe r f orse nc e Ge a 1 s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

4. Training....................................................

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7. Learet and Industry Part icipation Program. . . . ..... .. . ....... 7
8. iderkshops................................................... 4
9. Performance leprovement initiative for New Plants........... 10
8. OTHER IMP 0 (FFORT5
1. leproving the Quality of the Evoluetten Process............. 11
a. Nuclear Plant Re1146111ty Data Systee {4PR05) and Coopenent f at twre Analys t s Sys',ee (CP.'5)............ 11
b. Focused Plant tv41wattens................................ 11
c. Etw t poent P erf o rwarw e !grevement . . . . . . . . . . . . . . . . . . . . . . . 12
2. A l l i s t a nc e Pr o g r am s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3. Plant Patatenance Indicators................................ 14 .

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$130/81 l TAllt CF CONTENT 5 (continued) i jection

  • P.111 i
4. Maintenance Long term P14n.................................. 15 ,

j 5. Etwipment Reliability An41yses.............................. 15  :

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C. OTHER !%0U$ FAY EFFORT 5

1. Electric Pcaer Research Institute........................... 16
2. Nwele tr M41 ntenance As silt 4mco Cent er. . . . . . . . . . . . . . . . . . . . . . .> 10 l

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A. J0!NT IN USTRY/!!Jo ACT!v!T!!$ . <

l. New Imit18tive to !=:reve ledust*y Mainteesect Performaece l

In March 1987, 4 new initiettve was annewnced 41 sed at accelerating l

ingrovttents in inJWstry reintenancs performance. AlthcWgh individwal utt11ty and colltetive industry efforts have retulted in irgrevsd maintenance over the past several years, irgrove.*ent has been insufficient 4t some plants, and additional teprowe*ent is needed at M st plants. High quality paintenance is essential in i schieving excellence in overall plant performanca, as well as in schieving the 1990 industry.estadttshed perforstace goals.

The see t. se is cc=;rtsed of two parts. First, the conduct of a self .w '

1 a of its maintenance program by each nuclear statten using 4 etintenance guidelines as t basis, 464 second, the fcreat'.en wy !NM cf special maintinence 4:ststance end reytew 1t4"l$ '

j to assist utilities in reviewing their raintenance progr4Ms and j

identifying roCt C4Wsts of significant EstatenenCs prettems. 1 J

4.  ; elf.4ssestrents i

l In 1956, four meter utt11ttes participated in a pilot )

j F4tattnince self. assessment pregram. The Self.astelssent, l 1

s;casered by the NWRC MaintamaXe Workthg GrcVP, was COndWcted using the Guide 11ees for the Condvet of Maintecance at Nucles, i i

powersJt tems (!MP0 85 038) as a basts. The results of the plict effort citarly dtN nstrated the value of the self.

Assessunt apprcach in identifying etoded lage&vesents and conf trred the validity of tr.4 IMP 0 setnten4nce guidelines as 4

) stund battline dccumnt for the self.assessMnt.

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lach utility has been requested to perfors a self. assessment of the atintenance progr#m at each of its nuclose stations.

Co8Pencing this ef f ort el soon 4s practic4ble and Co#pleting it by Cecester 31. 1987. Almost all utilitf es have submitted tneir plans for conducting the self-assessment, inctwding which guideline chapters will be covered. time fraae for concletion, and team ccmposition. Several utt11ttes have self essesstents (

already in progress. The gos) of the self. assessment process is i to identify probles freas in clear end sufficient detatt se root l Causes can be deters'ned and corrective actions taken.

Ultimately, the effectiveness of this industry' aide effort will  ;

be seen during subsetwent plant evaluations and, in the 1erger j ters, perforsahce indicaters.

b. IMP 0 5pecial Maintenance Assistance and Review Teams
  • i T o spec 141 saintenance review and assistance te us were formed in M4rch 1987 to assist utt11ttes in introvteg 241ntenance l performance. Each te u consists of an INPQ te m men 49er with a l esintenance backgrowr.d, INPQ P4tntenance evaluators, an [lectric Power Research Institute (EPRI) rt;resentative. en apprcpriate l nuclear sten supply systes (M351) representative for the plant  ;

,- type, peer utt11ty reuert. ar4 members from the utt11ty/ plant beleg visited. It is desired that one of the memoers from the l utility teing visited be 4 Itne corporate nuclear sanager. I

, Wcrking closely with the plant and corporats uttitty personnel during a two. week period, the tem util focus its attention om deterstateg the root e.auses of the more significant saintenance prchleet. Reccmendettons for toprovement will be provided in writing to the uttitty being visited.

Fo11cwing the te u visit, the plent fornaltres action plans to adsress the identified problems. Subsetvently, the team is available to return to the site to assist in reviewing the actten plans for mainten4nce terrevement. Using the varied k expertise av4114ble on the te m.

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$1mce the team's formuletlon in March, sia plants have been visited, with six more visitt p14mr.Jd by December 1987.,

2. P*edictive MaiPtenamce Tme t t of predictive maintenance techniawel 46 4 form of preventive reinten.nce het received increated attention by utilit,iel ever the past lever 41 years. Mary utilitial are seking lignificant changel to their preventive maintenance progreet beled en the relwlti of their predictive sainten4%e efforts. The primary ge418 of ,

pregictive notatenance are to detect incipient ogwipment failure and to provide teput to pertedic or plammed maintenance.

A MtWRC survey condwCted in 1944 vevealed that the most widely used ,

form cf predictive enintentece il vibration acnttering. Soled on infctsatis % 'm 11 planti, 99 percent yled vibration monitoring and entlysis of y t rotating equipment. Minetydia pt cent of the plants ocnitored lubricating 011 for quality and weer particlel to detersine the origins and severity of machinery wear. leertr$

temperatures were acnitored by 88 percent of the plantl. Meter.

cstrated valve dyntiic testing wel condwcted by $9 percent of the

  • l respondents. Infrared detection wel used by $4 percent of the

, l plants to detect hot spett en electric 41 eevipeent. Forty.five r

,e,ceet e,ie,w an u stic . nit.,in, pre,r. se deien internai  !

valve lettale. Other preetctive saintenance techntques beirt used l include condenter air in. leakage monitoring, electrical inewletion l checkt, heat enchanger and etwipMnt perfors4Ne monitoring, and l ruie.fre,wency =nitorin, .f sne . tin genertier.

I Cyring the 1987 Maintenance Superintendents tierkshop, two speachel I were delivered that directly lddrelled predictive maintenance techniawel ' Meter.cperated Valve Testing Program' and 'Secefits of Predictive Maintenance.'

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3. Human Performance issues ,

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Reducing human performance errors continues to be an area that requires increased industry effort. Issues such as wrong "lit /=rong train, labeling deficiencies, procedure problems, and comunication errors are just some examples of improvement needed by the industry. INPO initiated the Human Performance Evaluation System (HPES) to focus upon and help resolve human performance issues, i Currently there are 29 U.S. and two international utilities participating in the program. The participating U.S. utilities represent more than 50 units. Over 150 people have beer. trained as l HPES evaluators and coordinators. In September 1986, 170 people  !

from 17 countries met in Lyon, France, to discuss lessons learned in the area of human performance at a workshop cosponsored by INPO and l

Electricita de France. Recently, a new topic on human performance

  • l was &c.itd to Nuclear Network. Additionally, a "Report of the Month"  :

is being disseminated to the industry using Nuclear Network to '

discuss issues that are parr.icular'<y troublesome to the industry.

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Tcpics presented to date have included transposition errors leading to actions on the wrong unit or wrong train; near miss situations brought about by inappropriate valve alignments, design problems, and infrequent operational testing; improper or incomplete equipmen't '

labeling) error detection; and using written instructions.

4 Mainte, nance Peer tvaluator Precram Industry participation in this program has been strong. Since June 1986. 50 maintenance managers or supervisory.leYel personnel have acceepanied IMPO teams on plant evaluations or maintenance assis-tance and review visits. The benefits being derived from this program include the following:

o improved evaluation team capability by the addition of l

experienced people from similar plants i

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enhanced professionalism and comunication within the nuclear industry maintenance comunity o

a learning opportunity for peers by observing maintenance activities at another utility o

additional skills that the peer evaluator can use to improve maintenance at his own plant o familiarization of the peer evaluator with INPO and its programs Feedback received from the participants in the Maintenance Peer Evaluator program has been, in general, very positive. Many coments have been received that reinforce the benefits listed.

  • Improved training and an additional preparation day were recently added to the peer schedule based on program feedbeck. '

S. l.enq-rance Plant Perfomance Goals In January 1985, the INP0 Board of Directors tasked INPO to develop an action plan to assist the industry in the establishment of long *

~ term goals. A plan was developed and three separate review groups representing utilities, suppliers, ano an outside group (to provide an independent perspective) began work to develop a uniforte set of overall performance indicators and establish a baseline for use by utilities in setting long-term goals. These indicators and goals serve as mechanisms to support achievement of industry benchmarks of excellence and are impacted by overall maintenance performance.

Also, this effort resulted in the establishment of 1990 goals by each utility with an operating nuclear unit.

INP0 is monitoring progress toward achieving these challenging 1990 goals and has reported progress to the industry in the "Industrywide Nuclear Power Plant Performance Indicators - 1986 Year-end Report' i

and the INPO ' Annual Report." With the exception of equivalent

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Revised 6/30/87 l availability factor and forced outage rate, which were significantly affected by the long-term shutdown of seven units, industry progress

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in the remaining overall indicators for 1986 was consistent with  !

that needed to achieve the industrywide 1990 goals. Collective 1

radiation exposure, low-level solid radioactive waste, and l industrial safety lost-tin accidents were areas in which noteworthy improvements occurred.

6. Traininc INPO cenducts a comprehensive training incereditation program for member utilities based on a systems approach to training and job and task analysis. Plant maintenance positions in the mechanical, electrical, and instrument and control areas are included in the progra n.

The current status of accreditation of the maintenance .

training programs is as follows:

o Ninety programs at 30 plants fu'eled before 1985 have been accredited in the instrumentation and control, mechanical, and electrical areas.

o To date, all plants that had fuel leaded at the end of 1984

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have submitted acceptable self-evaluation reports for all three

, maintenance programs.

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Self-evaluation reports for 15 progrars at five plants not fueled before 1985 have been accepted.

Additionally, a revised training and qualification document, QuidelinesforTrainingandQualificationofMaintenancePersonnel, lHP0 86 018, has been published. These comprehensive guidelines j

incorporate results frein the industry feb and task analysis.

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In conjunction with plant evaluation visits, training and qualift-cation evaluators conduct r.ssessments of implemntation of

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maintenance training and evaluate training related to personnel 4 :

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7 Revised 6/30/87 performance problems. These evaluations are conducted using the training and qualification objectives and criteria of Performance Obiectives and Criteria for Operatino and Near-term Operatina License Plants (!NPO 85-001) as a basis.

7. Leanee and Industry Participation Program
a. INP0's Maintenance Department staff currently includes seven industry-leaned employees (,33 percent of the staff). This program strengthens the INPO maintenance effort in the following ways:

o provides a direct utility input and improves evaluation credibility with me.nber utilities o provides a conduit for the transmission of good ideas, good practices, and established progra.ms to the loanee's

  • parent utility o improves contact and ccmunication af ter the loanee returns to the parent company

~ .

o provides opportunities to see other ways to approach main-tenance firsthand o provides experience in observation and evaluation techniques Currently, the following utili+'as or supplier participants have maintenance evaluators on-lean to INP0:

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o Carolina Power and Light Company o Consolidated Edison Company E

o Philadelphia Electric Company .;

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I Revised  !

6/30/87 o Southern California Edison Company o Tennessee Valley Authority I

o United Engineers and Constructors l l

o Vermont Yankee Nuclear Power Company

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b. Selected alumni maintenance evaluators are returning to INPO on a three week temporary assignment to participate in a plant 1 evaluation. This program strengthens the evaluation team and benefits the parent utility. Since the start of this program,  !

three alumni maintenance evaluators have participated in a plant evaluation. In addition, three other aluant evaluators .

have participated in special assistance visits.

c. Industry observers and advisors accompany evaluation teams upon ,

request or invitation. This program has some of the same

{

benefits as the loanee program while providing the observers l with a better understanding of the INPO mission and evaluation process as well as exposure to maintenance practices at another utility. Since January 1987, seventeen corporate advisors and '

e 42 industry observers have acceepanied evaluation teams.

Approximately half of these observers devoted some time looking at saintenance-specitic areas.

8. Workshoes Curing the past year various workshop activities have related directly to improving maintenance throughout the industry. A sumary of these recent activities are as follows: '

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o In September 1986, the Operttions Superintandents Workshop with the theme, ' Improving the Operations / Maintenance Interface.'

was held. In suoport of this theme, 22 maintenance superinten-

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Revised 6/30/87 dents participated in the workshop. In addition to the speeches that addressed the operations /malatenance relation.

ship, a panel with both operations and maintenance managers led a discussion entitled, "Techniques We Use to improve Operations / Maintenance Coordination."

o Also in September. the Outage Management Workshop was held.

Principle topics discussed were long and short range cutage planning, managing cutage performance, and outage mar)agement in France, o In October 1986, the Check Valve Workshop was held. Topics discussed industry efforts to address check valve problems, including selection, maintenance, testing, and troubleshooting check valves.

o In November 1986, the CEO conference was' held. Mr. Warren H. -

' Owen, Executive Vice President, Engineering, Construction, and Productien. Duke Power Company, delivered a speech entitled.

'Haintenance Improvement: A Xey in the Quest for Excellence".

This speech addressed industry efforts to improve the use of

~ predictive maintenance techniques, the expanding role of main- .

tenance as our industry evolves from the construction phase to the operations phase, the identification and relationships of all people involved directly or indirectly with maintaining nuclear power plants, managing cutages, and improving mainten-ance in order to achieve industry performance goals by 1990, o The Maintenance Superintendents Workshop was held in March 1987 The theme established for this workshop was ' Working Together To leprove The Plant". In keeping with this theme, approximately 30 operations superintendents and 15 radiation protection superintendents participated along with the main.

l tenance superintendents. Topics discussed included work i

ccordination, post-maintenance testing, performance indicators.

predictive maintenance, motor-operated valves, and self. Q~

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Revised 6/30/87 assessments. This was one of the largest workshops attended at INPO with a total of 201 participants. 1 I

l o In April 1987, a Plant Managers Workshop was held. Topics included the role of root cause analysis in achieving enhanced performance, improving plant performance by improving human performance, outage scope management, and managing operations and maintenance changes.

o In May 1987, the Technical Support / Design Engineering ilorkshop was held. Topics included controlling the modification backlog; root cause determination; optimizing constructability, operability, and maintainability of plant design changes; and post-modification testing.

9. Performance Imoreve?ent initiative for New Plants The IDCOR study, ' Nuclear Power Plant Response to Severe Accidents,"

and the NRC AE00 study, "Trends and Patterns Analysis of the Opera-tional Experience of Newly Licensed U.S. Nuclear Power Reactors,'

indicated a need to improve the performance of newly licensed plants

~

to reduce the occurrence of significant events. Plant-specific - -

action plans have been prepared for each new plant. The plans list actions with firm INP0/ utility cemitments and dates as well as actions for which additional utility interactions are needed to i finalize comitments. The scope of the new initiative involves the evaluation program, training (e.g., accreditation, senior nuclear managers course), and the analysis program (e.g., increased emphasis on uting industry operating experience). Action plans are tailored I to fit the circumstances at each utility. Maintenance performance is a key element of this initiative. INP0 maintenance evaluators will participate on pre-fuel load assistance visits, as appropriate, and participate on plant evaluations three to six months after reaching full power.

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Reviseo I 6/30/87 i B. OTHER INPO EFTORTS l

1. Improving the Quality of the Evaluation Precess
a. Nuclear Plant Reliability Data System (NPROS) and Component Failure Analysis System (CFAS)

During the past year, approximately 50 maintenance peer evaluators have been introduced to the various ways NPROS can be used to support plant maintenance activities. Examples of typical uses of NPRDS include location of critical spara parts,  !

finding other plants that have experienced similar equipment problems, and providing a sumary of maintenance history data.

Emphasis has also been placed on analyzing equipment problems in preparation for a plant evaluation or maintenance and assistance ,

review team visit. I Equipment failure analysis reports using NPROS a.e now being generated using the Component Failure Analy'is System (CFAS). CFAS is a ccmputer-based analysis methodology for identifying significant ccmponent failure trends frcm NPROS.

, CFAS is a two-step process that does a systematic statistical .

computer screening of NPROS data and the subsequent engineering e

analysis of the results. The CFAS computer program applies several mathematical screening tests and significance erfteria to NPROS ccmponent failure data. The first reports usef, for evaluation trips began in March 1987. CFAS is now being used to provide information for all evaluation rad maintenance review and assistance team visits,

b. Focused Plant Evaluations l

In October 1986, a program was begun with the purpose of achieving a more focus 6d maintenance evaluation effort. One of l

the key elements to this program was the development of an ,

1 evaluation plan prior to arriving at the plant. This plan .s \l

. u. s x!  !

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Revised 6/30/87 discusses evaluation areas that will need more concentraticn based on information gathered while preparing for the trip and discussions with plant counterparts. Th; plan also takqs into account what evaluation areas will receive only minimal review. The results of this approach have been generally j favorable, allowing more time to be spent on the most important issues. This method is now standard for all evaluation trips.

In conjunction with this focused approach, the Maintenance' l Department manager has specified that review of the following ]

areas should be emphasized on evaluations: work control process .

I and interdepartmental coordination; post-maintenance test!ng; ,

material condition and preventive maintenance; motor cperated  !

valves; and the use and content of procedures.

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c. Equipment Perfomance Improvement l

In March 1987, IMPO developed the ' Top Equipment Problems List" to identify the key equipment problems industrywide. The development of this list has been a combined effort by the (&A and A&E technical staff. The intent of developing this list is to use INP0's key pecgrams (e.g., evaluation teams, SEE-!N) to -

improve the performance of this equipment. This list will not remain fixed but will be updated based on equipment perfor-mance. Maintenance evaluators review this list while preparing for plant evaluations. The list, when combined with CFAS, NPRDS, 50ERs, etc., will enable the maintenance evaluators to focus their efforts toward reviewing and making possible recceendations to improve equipment performance. The "Top Equipment Problems List" is an initiative that is still in a i

pilot stage of development with several additional enhancements l

being considered.

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Revised

. 6/30/87 The following is the current "Top Equipment Problems list":

Station batteries Motor-operated valves .

Diesel generators Standby turbine driven pumps Main feedwater flow control Heat exchanger tubes Relief valves .

-- Piping Main steam turbines Check valves Reactor coolant pumps A. C. inverters

2. Assistance Procrams i
4. Special assistance visits are conducted in response to specific requests by member utilities or international participants.

Since January 1987, five assistance visits were conducted addressing the following areas:

b .

o field performance of maintenance activities

,. o review of maintenance programs o planning and scheduling / work control o

instrument and control surveillances o corrective maintenance backleg Maintenance Department perser.nel also assisted the Events 1

Analysis Ocpartment with an industry event follow-up of a feed.

ster discharge check valve failure.

b. In addition to assistance visits, 96 specific requests for assistance have been answered by the Maintenance Department since January 1987. Also, nine requests for maintenance procedure 4 be "

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'Rev hed 6/30/87 reviews or procedure writer's guide reviews have been answered by either the Maintenance or Human Performance Departments since January. ,

3. Plant Maintenance Indicators In the maintenance area. INPO continues to collect and process data for ten maintenance indicators. In March, the "!ndustrywide Nuclear Power Plant Performance Indicators - 1986 Year-end Report" was*

f provided to the industry. Trend graphs covering at least three years of data were provided for the maintenance indicators.

Improved industry trends existed in the ratio of highest priority maintenance work requests (MWRs) to total MWRs completed, ratio of preventive to total maintenance, maintenance ovtrtime worked, and  !

maintenance radiation exposure (BWR and PWR). A slight decline in ,

performance was noted in preventive maintenance items overdue and '

lost-time accident rate for personnel involved in maintenance.

Unplanned autcmatic scram'. while critical associated with maintenaMe activities showed steady performance. Included in the 1986 year-end report were clarified definitions for the maintenance indicators. .

  • Currently, a rework indicator is being considered in response to a request free MUHARC. A preliminary definition and reporting requirements have been draf ted. This information, along with a

. questionnaire, will be sent to a cross section of utility represen-tatives for coment. Based on this industry input, a final decision will be made en implementing a rework indicator.

I 1 Additional steps have been taken to clarify the definition of preventive maintenance. This is also in response to a NUMARC request. Changes to the data collection forms and the definitions section of the semiannual report have bien made for inclusion in the I next revision and issue respectively. ,

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i R9 vised 6/30/87 4 Maintenance Long-term Plan I

i A Maintenance Long-term Plan has been developed to serye h a guide '

for the Maintenance Department activit' n The department Long-term Plan '.cmplements the overall INFO Long-term Plan and the INPO responses to the "Sillin" Report. Also, this plari addresses the identified issues of the NRC's Maintenance and Surveillance Program Plan.

The Maintenance Long-term Plan specifies goal: and objectives that support the plan. An underlying assumption is that INP0's basic mission, and therefore its basic goals, will not change over the next five years. The long term objectives are aimed at the next two to five years. An action plan to address each of the objectives will be developed on an annual basis. -

5. Equip ent Reliability analyses
  • INFO selects certain important plant systems for in-depth study of equipment reliability and proviries the results,of these studies to its me cers and participants. The first syttes selected was the auxiliary feedwater system in pressurized water reactors. A report
  • ofthisstudywaspublishedinSeptecer1985(!NPO85-036),and this was followed by an 50ER on the sar4 subject in January 1986 (50ER86-1). Many of the issues identified in the study and the rec:Tenda' ions made in the SOER relate to maintenance activities.

On several occasions, during regular plant evaluations, IMPO has performed an Operational Readiness Evaluation of the auxiliary feetwater, high pressure coolant in.4ection, reactor core isolation cooling, and other important systems.

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Revised

, 6/30/8P I C. OTHER INDUSTRY FFFORTS

1. Electric Power Research Institute .

The Electric Power Research Institute (EPRI) supports member utility investment in nuclear power plants and predominately emphasizes the economic improvement of the present operating units. Researen is performed in many areas including operation and maintenance.

Investigations have been performed on comen industrywice maintenance problems including valve and pump packing leakage, gasket leakage, bolting failures, and various safeguard equipment failure. Program enhancements in preventive maintenance, vibration monitoring, equipment procurement, and equipment qualification hav3 also been recomended by EPRI. Two recent reports on valve packing i

and bolt torquing are often referred to in discussions with plant -

maintenance personnel. Signif'iant improvements are being made at i several plants where EPRI recomendations have been adopted. The l

INP0 Maintenance Department maintains close contact with EPRI to help comunicate program and equipment improvements to the t industry. EPR! is also providing personnel to serve on the I

msintenance assistance and review teams.

2. Nuclear Maintenance Assistance Center e

L .

The Nuclear Maintenance Assistance Center (NMAC) is a new concept with a single purpose--to assist utilities in improving their e.tintenance efferts. MMAC will provide a vehicle for ccmunicating tried and proven solutions to technical maintenance problems.

Existing lines of comunication are not effective for addressing technical problems as they arise. F.MAC will provide acre than just solutions to technical maintenance problems. It will assist in helping plants to allocate saintenahce resources (e.g., to decide what preventive maintenance (PM) tasks are really necessary and {

desirable, what tasks to autcaste and how, and whether to use - I predictiveorp0riedicmaintenance). MMAC is not intended to i l

ccepete with existing, effective maintenance service organi.

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Revised i

. 6/30/87 i zations. It is not a research organization as is EPRI. NMC startup will be heavily supported by EPRI but, after a short period of time, will be the utilities' maintenance assistance  ;

organization. NMC will draw on the best talent in thd nuclear  ;

industry, both domestic and foreign.

NKAC is envisioned to be a self. sufficient, independent organization l by 1991. Operation of the center is expected in 1987 I

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INCLOSL'RE 2 s institute of

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Nuclear Power Operations tioo Cee 1s Panewey SAMPLE LETTER MAILED TO EPOC's $'[,000 FORWARDING THE NEW MAINTENANCE To M.3o33,953 3400 '

INITIATIVE WITE cc's TO CEO's AND APOC's March 13, 1987 i

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Mr. R. Patrick Mcdonald j 3enior Vice President l Nuclear Generation

600 North 18th Street

! P. O. Box 641 -

] Birmingh <Alabra 35291 0400 1'

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Cear Mr. Mc0cnald: .

The purpose of this letter is to request your support and participation' 4

in a new initiative to accelerate maintenance perfomance improvement in the 4

nuclear pcwer industry. Althcugh individual utility and collective industry efforts have resulted in improved maintenance over the past several years, improvement has been insufficient at some plants, and additional improvement

!' is needed at mest plants. High quality maintenance is essential in achieving excellence in overall plant perfemance, as well as in achieving the 1990 industry-tstabitshed perfemance goals.

In 1986 four v4mber utilities participated in a pilot maintenance sel'f-assessment pro The self-assessment, sponsored by the NUMARC Maintenance

" Working Group, gram.was ;onducted using the Guidelines for the Conduct of j Maintenance at Nuclear Power Stations (,NPQ 45 038) as a basis. The reJults 1 of the pilot effort clearly demonstrated the value of the self assessment approach in identifying needed improvements and confirmed the validity of the

!NPO maintenance guide'ines as a sound baseline document for the self-assessment.

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The new initiative is coeprised of two carts. First, the conduct of a self assessment of its maintenance program by each nuclear station using the i  !NPO maintenance guidelines as a basis, and seccnd, the famation by INPO of j special maintenance review and assistance teams to ashist utilities in review-

- ing their maintenance programs and identifying root csuses of significant j maintenance prcelems. Attachment A to this letter provides additional detail cn this initiative.

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Page Tco With regard to the first part of the initiative, each utility is requested to perform a self-assessment of the maintenance program at each of its nuclear stations, comencing this effort as soon as practicable and com-pleting it by Decceber 31, 1987. It may not be necessary for each station's self-assessment to cover all of the 16 chapters in the IMP 0 matntenance guidelines; an initial screening s5 N1d be conducted to determine the areas that need an in-depth assessment. 1he areas selected should then be included in the formal self-assessment effort. While it is being left to each indi-vidual utility to choose the chapters of the maintenance guidelines that will be subjected to a femal self-assessment, we urge you to make this decision carefully and only eliminate those chapters in which you are confident your organization is already achieving excellence.

Attachment B is a copy of the INPO maintenance guidelines prov'ided for your use. Attachments C and 0 provide exuples of guides used by two utili-ties in conducting self-assessments during the recent pilots. Attachment E is a suple excerpt from a completed self-assessment report.

We would appreciate receiving your plan for conducting this self-assessment at each nuclear station by May 15, 1987. This plan should include the following:

o areas to be covered in the self-assessment o time free for completion o composition of the self-assessment taas llpen cc: plation of the self-assessment, we request that you furnish us a report of the results for each station.

With regard to INP0's special maintenance review te ms, each tea.m will consist of approximately six to eight people, including paar evaluators from member utilities, a carefully selected representative frers the appropriate

. NS$$ vender, and a tea.1 me=,ber from EPRI (the EPRI team aember will os -

involved in or have ready access to the new EPR! Nuclear Maintenance Assis-

" tanceCenter). We will continue to seek your support in providing selected peer evaluators to serve on the review teams in order to achieve the best possible results for the visited utility / plant. It is also anticipated that each te n will include members free the utility / plant being visited.

We anticipate having two te us available for maintenance rev hw visits by the end of March 1987. These special review visits will be indepr.ndent of

!MP0's regular evaluation program and will be conducted at the request and with the support of the visited utility / plant. We expect to make approxi-mately 16 (eight per teaa) of these review and assistance visits over the next 12 months.

The necessity to assign the appropriate resources to this irportant initiative will result in a reduction in the resources assigned to the

maintenance areas on INP0's regular evaluation teus.

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March 13, 1987 Page Three T5e NUMAC Executive Group was briefed on this initiative at their February 18, 1987 meeting. The NUMRC Maintenance Working Group has supported this kind of initiative for sormt time, and the chairman of NUMRC as well as the chairsan of the Maintenance Working Group assisted in final plans for the initiative. Additionally, EPRI was represented at the final pltnning meeting for the initiative and was fully supportive. NUMRC will be kept informed of the progrets of this initiative so generic progress and results can be comunicated to the NRC.

I If you have any questions on this matter, please contact me or Ed Moore l

at(404)980-3211.

Sincerely, l

g .

P. M. Beard. Jr. i

, Group Vice President Evaluation and Assistance PF8:dp

Attachments (As stated above) cc/wo
Mr. Joseph M. Farley INP0 Board of Otractors Mr. Zack T. Pate t l

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. Attachment A INDUSTRY INITIATIVE TO ENHANCE MAINTENANC[

BACKGROUND The nuclear industry is placing great emphasis en improving the performance in its operating plants snd in establishing a record that demonstrates fine

, performance. '

i I To achieve improved operational performance, maintenance activities su:t be conducted to high standards and with efficiency. Maintenance accounts for approximately 70 percent of all activities performed during plant operation.

In addition, about 70 percent of the non-capital money in the plant budget is spent on plant maintenance. That level of rescurce expenditure adds emphasis .

for the need for efficiency in maintenance.

Maintenance is also receiving increased erphasis from the NRC. Recently the NRC issued a Phase One Report on their Maintenance and Surveillance Progran i

Plan, which concluded that 'while overall industry reliability appears to be improving, maintenance continues to be a significant contributor to industry reliability pecb1tss.* -

i O!5C1)$5!0M Although individual utility efforts and efforts by other industry organiza-

) tions are helping to taprove maintenance, the rate of overall improvement is less than desirable. To increase the rate of improvement, a new initiative is

planned.

The proposed initiative is a two-prenged approach:

1. A utility sanaged self-assessment by all nuclear stations, using INFO j maintenance guidelines.

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2. IMPO special maintenance review and assistance team visits to plants to assist thers in assessing their maintenance program and in identifying root causes of 6taintenance problems. These visits can be originated by  ;

. a utility or by INPO and will include visits to plants with superior l maintenance departments as well as to those that need considerable  ;

improvement. Resources have been allocated for approximately 16 visits  !

cver the next 12 months, i

It is expected that appropriate action plans will be develop?d by escli util-ity, based on the results of the self-assessments and special maintenance team visits.  ;

1  !

SELF 455E55 MENT

Since March 1986, four member utilities have been participating in a pilot j maintenance self-assessment program initiated by the NUMAAC Maintenance ,

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Working Grcup. The purpose of this pilot program was to examine the value to an individual plant of performing a self-assessment of its maintenance progra against the Guidelines for the Conduct of Ma'intenance at Nuclear Power Stations (INP065-038). The results of this pilot effort have clearly l desenstrated the value of the self-assessment approach and have confireed the  !

J validity of the !NPO maintenance guidelines as the basis of the review. l

~

Ext ;1:s of two formats used in the conduct of the pilot program are provided

, in Attachments C and O. Although different in structur9, both femats were

, taken directly free the !NPO maintenance guidelines and were four.d to be effective.

The methodology used to perform the pilot self-assessments differed at each utility, but the overall results were found to be cearson as follows
i o When done thorcughly, the self-assess.nent process can more clearly define

)I kncwn problem areas and identify new weaknesses within a maintenance j progran t. hat need improvenent.

J i o once prcblems have been recognized, defined, and evaluated, developing an effective action plan to improve the weak areas can be readily acceeplished. i l -2

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o Many of t$e problems identified in the pilot self-assessments were corrected without significant additional resources.

, o A valid, conscientious, and thorough maintenance self-asses'sment takes thoughtful planning, time, and dedicated resoJrces to perform. The connitment of sufficient time and resources reeds to be made available 4

prior to enarking on any form of self-assessment. i o A complete assessment against all 16 chapters of the maintenanc.e

, guidelines took 150 to 200 man-days of effort to co.nplate.

l o A cceplete maintenance self-assessment using all 16 chapters of the maintenance guidelines should be consideredt however, it may not be

) necessary for some utilities. A careful screbning process to detensine which chapters to include in the self-assessM nt is necessary to ensure. ,

l the best results.

o Self-assessrent tea;n composition should be selected with a balance

between station and non-station personnel. Station personnel provide the j day to-day detailed plant / department interface, while non-station  !

].

personnel provide perspective for a more objective assessment.

o The pilot assessments included personnel frors sister plants, corporatn offices and, in some cases, contracted personnel. Plant personnel on the tes;ss were nest effective if middle-level supervisors or above were used.

The goal of the self-assessment process is to identify problem areas in clear

)

and sufficient detail so root causes can be detamined and corrective actions j taken. ,Ulttartely, the effactiveness of this industrywide effort will be measurtd by trends in perfomance.

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INP0 SPECIAl. MINTENANCE REVIEW AND ASSISTANCE TEaNS Special saintenance review and assistance teams will be formed and available to assist utilities in imcroving mainterance performance.

Each team will consist of an IMPO team manager with a maintenance background, IMPO maintenance evaluators, an Electric Power Research Institute (EPRI) representative, an appropriate nuclear steam supply system (MSSS) represen.

tative for the plant type, peer utility members, and members from the i utility / plant being visited. It is desired that one of the members from the utility being visited be a line corporate nuclear manager. Working closely I l with the plant and corporate utility personnel during a two. week period, the team will focus its attention on determining the root causes of the more significant maintenance problems. Reccenendations for improvement will be provided in writing to the utility being visited.

I Following the team visit, the plant shculd fonr.4112e action plans to address the identified problems. Subsequently, the taas will be available to return  !

to the site to assist in reviewing the action plans for maintenance twrovement, using the varied expertise available on the team.

SumaRY

, The needed improveu nt in maintenance performance will require significant .

utility and IMPO ccenitmnt of time and resourcas. However, it is expected l that a ceabined utility, IMP 0, and EPA! effort, capitalizing on expertise j available throughout the industry, can achieve the desired improvement.

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l QUESTION 42. If the nuclear utility industry has,. in NRC's view, made good (

i faith efforts in properly maintaining its plants, is it the j i NRC's responsibility, as the regulator, to have fully enforceable regulations pertaining to all maintenance areas of l l  ;

nuclear power plants? l l

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ANSWER.

l l

It is the responsibility of the NRC to ensure that all nuclear power plants f aremaintainedandoperatedinamannerthatensuresthihealthandsafetyof l the public. The method for that assurance, be it regulation or some other treans,is decided on a case-by-case basis. The NRC does not believe that regulations are necessary in all cases. Often, as exemplified in the training I areas, a Policy Statement or some other alternative is preferable. As noted in the ,inswers to items 41 and 44, the EDO has been directed to develop a proposed rule in this area, l

1/27/88 EREAUX Q40 I

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quE,ST10N,43.

Describe the industry role and participation in drafting the proposed policy statement on maintenance, In your discussion, include a list of all meetings between NRC staff and NUMARC/INPO members and the topic of discussion for each e?eting.

ANSWER.

The proposed policy statement on maintenance was developed solely by the NRC staff.

However, the decision to develcp a policy statement and the general content of the statement were discussed at a meeting with INPO on July 8,1987. A NUMARC representative also attended the meeting. At the meeting, the staff d Tribed t

the approach being used in the development of the policy statement, but -icifics of the policy statement were not discussed. The staff did solicit information regarding what, if any, industry initiatives could be endorsed in the policy statement.

The staff has also met with NUMARC and INPO representatives to discuss technical areas of mutual interest in the area of maintenance. One such meeting was held July 16, 1985 at the EPRI Non-Destructive Test Center and another was held October 16, 1985 at the Crystal River nuclear plant. The first meeting involved an overview of EPR! research projects and a utility presentation on the application of those programs. The second meeting involved a presentation i

en the application of preventive and predictive vaintenance programs. Additienally, the staff met with representatives of INPO and NUMARC on August 15, 1986 to present the findings of Phase I of the Maintenance and Surveillance Program Plan. The policy statement on maintenance was not discussed at any of these meetings.

1/27/68 !REAUX 042  !

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QUESTION 44 Sumarize the status of NRC's maintenance policy statement.  !

l Also, give your best estimate of when the policy statement will l l come before the Comission for a vote. i 1 ,

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  • ANSWER.

l The NRC proposed Policy Statement on Maintenance was forwarded to the l Comission by mercrandum dated December 30,1987(SECY87-314). The Staff briefed the Comission regarding the content of the Policy Statveent on  !

l j January 7, 1987. The Comission has subsequently approved a modified final l

j policy statement and directed the staff to develop a notice of proposed j rulemaking for Comission review by August 1,198,8. A copy of the Staff l

Requirements Memorandum with its attachmetits is provided with this answer.  !

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Attachment:

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l Memo to Victor Stello and Raymond Fraley I

l from Samuel Chilk dated 2/25/88 l

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j 1/27/88 BR DUX 044 1

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