ML20154H864
| ML20154H864 | |
| Person / Time | |
|---|---|
| Issue date: | 02/26/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8603100389 | |
| Download: ML20154H864 (83) | |
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Date: Wednesday, J,.-
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B6031003G9 060226 1~
PDR 10CFR PT-9.7 PDR ANN RILEY & AS5OCIATES
.courg pso c te;;,
.1o45 I a,t.,
...a.
Suite 921
. Washington, D.C.
20006 (202) 293-395C
e 1
O I SCLA I M ER O
3 4
5 C
This is an unofficial transcript of a meeting of the
?
United Stat,es Nuclear Regulatory Commission held on a
2/26/36 in the Commission's office at 1717 H Street.
9 N. iJ., t >a s h i ri 3 t c h,
O.C.
The meeting was open to public 10 4?t46-336:a sat 0:2arvation.
This transcript has not been 11
- reviewed, ce** Set 71, or edited, and it may contain 10 insecuracies 13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 net part of the formal or informal record of decision of the 16 matters ciscu;3ed Exoressions of cosnien in this transcript 17 co net necessartly
-93 '30t final datarminatten or be!lefs.
No 19 pleading or other paper may be filed with the Commission in i
19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Cemmission may 21 authorire.
23 24 25
3 1
1 UNITED STATES CF AMERICA 2
NUCLEAR REGUIATORY CC:C!ISSION 4
3 4
BRIEFING ON NL%\\RC INITIATIVES 5
l 6
[PUBLIC MEETING) 7 8
Nuclear Regulatory Commission 9
20cn 1120 10 1717 H Strast, N0rthvast 11
- J:3hing On,
- 2. 0.
s 12
+
i 13 Wadnesday, Fabruary 26, 1986 14 l
15 The Commission met in open session, pursuant 16 to notice, at 3:34 p.m., the Hencrablo liUNZIO J.
PALLADINO, l'7 Chairman of the Cc= mission, prasiding.
18 COMMISSIO!!ERS PRESENT:
i 19
!TUNZIO J.
PALLACINO, Chairman of tha Connission 20 JAMES K. ASSELSTINE, Member of the Commission 21 FREDERICK M. BERNTHAL, Member of the Commission 22 LANDO W. ZECH, JR., Member of the Commission 23 24 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
25 J. HOYLE
2 1
- 11. IGLSCH 2
J. FERGUSON 3
J. IIILLE2 4
J. OPEKA 5
W. OWEN 6
C. WOODY 7
B. WITHERS 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
~'
25
J 3
1 PROCEEDINGS 2
CHAIRMAN PALLADINO:
Good afternoon, ladies and 3
gentleren.
I should begin by apcicgizing for the delay.
It 4
was unavoidable except for the possibility that we do a better job of scheduling when we have potentially long hearings in
.5 6
the morning.
7 I should point out that Commissioner Roberts won't 8
be able to participate this afternoon.
His mother took 9
seriously ill and he was called to M2 phis.
Cctaissioner 10 3arn:hal will be hora shcr:ly, by his effica advised we should 11 start without hin.
12 We ara pleased to hava with us this aftarncen 13 representativas frcs the Nuclear Utilities Management and 14 Human Resources Cc=mittee known as NUMARC t'o brief the 15 Commission on NUMARC's recent initiatives.
The Commission 16 last met with NUMARC on November 6th, 1935.
17 Since its inception about two years ago, NUMARC has 18 been dev31cping impcrtant non-hardwara prcgrams relating to 19
=anagement and human resources.
The NRC has been very 20 interested in these programs.
And the NRC Staff has had many 21 discussions with NUMARC to determine the extent to which 22 NUMARC and NRC non-hardware problems could be dovetailed.
23 More recently, NUMARC has become involved in 24 technical hardware issues as well.- More specifically, NUMARC 25 will discuss among other topics today, two significant issues
~
I
,z 4
1 which have been outstanding for an extending period of-time, 2
USIA 44, station blackout, and USIA 45, shutdown decay heat 3
. removal..
4 The NUMARC proposed agenda for today's meeting is 5
available in the back of the room.
6 I should point out that Region IV personnel will be 7
listening by phone to today's proceeding.
I shoul'd also point 8
out that I have an appointment I just can't break, so I'll 9
leave at 4:30, but I'll turn the gaval cvar to Mr. A:0312 ina 10 so we can continue.
11 Sefora I turn tha meeting over Oc the NUMANC 12 representatives, do any of my fallcu cc missi:nars h:te 13 cpening ramarks?
14 COMMISSIONER ZECH:
No.
15 COKKISSIONER ASSELSTINE:
No.
16 CHAIRMAN PALLADINO:
All right, I'll turn the 17 meeting to Mr. Miller, chairnan of the NUMARC steering j
18 cc=mittee.
.i 19 MR. MILLER:
Thank you very much.
We appreciato the 1
20 cpportunity.
Especially appreciate it this afternoon.
We i.
21 know you've had a full and trying day, and we'll move as 22 quickly as we can.
I 23 Of course, I'm Jim Millar.
I'm president for i
34 Georgia Power and chairman of the NUMARC steering committee.
i 25 And with me today are Warren Owen, executive vice president of s
1
5 1
Duke Power and vice chairman of the NUMARC s cering 2
committee.
Jack Ferguson, president of Virginia Power and 3
chairman of the NUMARC technical subccasittaa.
4 C.O. Woody,_ group vice president of nuclear energy 5
at Florida Power & Light, and chairman of the NUMARC working 6
group on maintenance.
And Bart Withers, vice presidant Of 7
nuclear at Portland General Electric.
And in the audience, 8
who will appear up here and take my place to oake a 9
presentation later, is John Cpeka, senior vice president cf 10 Northeast Utilities, and chairman of the tr'. ARC werking gr:up 11 cn station blackout.
12 There are other NUMARC members hara, and I'll ask 13 them to stand.
Gentlemen, vculd tha NUMARC-people please 14 stand.
15 (Audience complied.)
16 MR. MILLER:
Thank you very much.
I regret to 17 inform you that we have had a few people leave, and we will 18 continue to have ccme leave because of early flight 19 arrangements.
20 CHAIRMAN PALLADINO:
We'll understand.
21 MR. MILLER:
In today's presentation I'm going to 22 give a very brief update on NUMARC.
Then Warren is going to 23 discuss current NUMARC activities in the areas of operator 24 requal, access authorization, and fitness for duty.
85 Jack's going to provida you with the status of the
9 8
6 1
technical subec==ittoo activities,'and assisted by John Opeka l
2 on station blackout.
3 C.O. Woody will ad'dr2:0 =aintenance, and Sar 4
Withers will discuss a new subject that we haven't talked too 5
much about before, and that's the overall industry afforts in 6
the area to improve cha=iatry.
7 Now we are approaching our second year -- our second 8
year anniversary, and we'll begin our third year in about two 9
weeks.
And that's an important milastone, I kncu to me 10 personally and to a let of these ochar fcihs.
s 11 As you are awar2, throughcut 1934 we cada a numbar 12 of commitments to ycu that reprcsantad many of tha industry's 13 collective efforta towards self-improve =ent and l
14 self-management.
I want to assure you, we've been serious 15 about meeting those commitments.
16 And as we discussed in our Ncvember =coting, vs have 17 made great pregress in ec=pleting these that have bocn j
18 scheduled te be cc=plotad at this time.
We're not 100 19 percent.
We realize that there's a very important dato coming 20 up at the end of the this year and we intend to do our 21 absolute best to see that we all do what we said we wculd do.
22 We'll be back with you later on this year at our next meeting i
23 to report progress in some detail on all of the items that we l
24 made commitments on.
25 The fact that we have made progress and completed a 4
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lot of these thin'gs doesn't mean that we've stopped.
We 2
recognize that through meeting these commitments we've only 3
put in place the foundation and the building blocks necessary 4
to achieve high standards of performance.
And we all desire 5
it, and we expect to continue improvements in these areas.
6 It's our belief that overall nuclear commercial 7
pcWer plants are now being operated, maintained and managad 3
batter than~at any other time in our history.
We cannot stop 3
cr raduce Our offerts for continuing improvement.
10 Recent ovants appear to demonstrata that inproved f.,
11
- srf
- rmancs and greving professionalism of plant personnel in 12
' handling events.
Raports on thosa hava ganerally praised the 12 high lavol of teamwork and effectiveness of the plant 14 eparating personnel.
15 We see that in spite of indications to the contrary, 16 as a pcsitive indicator, especially since this is an area 17 where we have exponded, and our expending, and will continue le to c:: pend ancrmcusa rescurces.
19 We believe that today our people are better trained 20 and qualified and ars =anagers are more involved than ever 21 before.
We believe we have a ways to go, but we think we're 22
-- we know we're making progress.
23 NUMARC has focused the efforts of the nuclear 24 utility industry on selected issues, and has provided the 25 means for us to speak to you and to your staff with one
8 1
. voice.
It has also provided you and your staff the means of 2
interacting with the entire utility industry on selected 3
subjects, rather than having to conmunicate with the many 4
various and separate factions of the industry.
5 We think it's been beneficial to the industry, and 6
we think'it's been beneficial to you.
7 When we first proposed this initiative and discussed 8
new approaches toward regulation and self-management, we were 9
optimistic that we could work with you and the Staff tcward 10 the common purpose.
We think that's happened.
He think we've 11 had some rough sledding in some areas.
We think we're I
12 overcoming in, and have overcome some.
And wo think we'ro 13 making progress.
14 We believe that our inproved dialogue with the Staff 15 is allowing us to discuss and solve some of the tougher issues 16 that you possibly mentioned last time, Cc==issioner 17 Asselstine.
Vic Stello in his assignmont as acting executivo 18 director for Operations is taking an active intarase in 19 strengthening co==unications between the NRC Staff and the 20 industry.
21 We assume that you intend for Vic Stallo now to be 22 the point of contact for NUMARC interactions with the NRC 23 Staff since Bill Dircks has left.
We've assumed that.
We'll 24 continue it unless you tell us otherwise.
25 It is important that as we move forward to address
9 new issues, we have in place a process to bring the collectiva 1
2 expertise and experience of both the industry and the Staff 3
together to achieve the best solution to a problan in a full, 4
cooperative and ccmplementary manner, so that we can get the 5
best solution in a timely manner.
6 We believe that this process will, from time to 7
time, continue to need, and possibly -- at the same level, and 8
possibly increased involvement in' direction from the 9
Commissioners in the early stages of development of an issue, 10 to sort of help ensure that the industry and the Staff direction -- that those directions are consi'stant with ycur 11 12 overall intent.
13 We're optimistic that with the interaction and 14 feedback from you, NUMARC and the Staff will be able to 15 develop optimum achievable solutions to some of the issues 16 facing our industry.
17 Warren is going to go ahead and talk abcut sena 18 other activities, operator raqual, access authorization and 19 fitness for duty.
Warren?
20.
MR. OWEN:
Jim. thank you.
Good afternoon.
21 As you recall, at that last meeting on March the 22 20th, you asked us to discuss the check operator program as a 23 possible solution to problems with operator requalification.
24 In response to that request, we formed a working group on 25 cperator requalification.
It's chaired by John Griffin,
10 1
senicr vice president at Arkansas Powe & Light.
And they were 2
asked'to review problems with operator requalification.
And 3
if problems were identifisd, to review the proposed check 4
operator program as a possible solution to those problems.
5 This working group has interacted with your staff 6
and with :TU:112C utilitics to identify problems in operator 7
requalifica icn and to explore some workable solutions to 8
thesa problems..While thay have not yet completed their work 9
cr formulatad their conclusions, there are several points that 10 need to ha discussed here ceday, 11 First, va think ve all want the requalification 12 process to be one that results in highly qualified, well 13 trained and professional cparators.
In our view, to be 14 effective requalification examinations and requalification 15 training need to cover the practical skills and knowledge 16 requisd to operate the plants under normal conditions, as well 17 as the rarely used knowledge, skills and abilitics that la operators must have to deal with plant emergencies.
19 As you knew, sinca 1982 the !TRC has annually been 20 writing, conducting and grading examinations for about 20 21 percent of the operators at half of the nuclear power plants, 22 or about 10 percent of the operators overall.
We believe tha 23 the current system of NRC-administered examinations may be 24 detrimental to both the motivation of our operators, and to 25 the retraining and requalification process'itself.
11 1
We recognize the NRC mandate to protect the public 2
health and safety, and recognize the need for the NRC Staff to 3.
review training at licensee's plants.
We do believe, however, 4
that the NRC Staff should be-involved in the requalification 5
process through the audit of utility requalification rather 6
than as an administrator of requalification examinations.
We 7
believe that the responsibility for administering the requal 8
examinations should rest solely with the utility.
9 While we have not yet formulated definitive 10 conclusions on the subject of a check operator program, we 11 would like to make a few comments relating to that subject.
12 First, we recognize that the involvement of senior 13 experienced and licensed utility personnel in their utility's 14 requal program is an important element towards achieving well 15 trained and well qualified operators.
16 We also believe that the requal program can benefit
[
17 by using these personnel to provide feedback to management on 1
18 the effectiveness of the training program through observations i
19 and evaluations of operator perfor=anco, both individual and 20 team performance.
i 21 Some of these concepts are being used by utilities i
22 in their requal pregrams today.
In particular Virginia Pow'er 23 is setting up a pilot check operator program at their two i
24 plant sites..This program basically will establish a highly 25 qualified, professional senior reactor operator at each site i
12 1
reporting to the station manager, who will be involved in the 2
operational. evaluations and qualification for all Ros and SRos 3
at'their sites.
4 Virginia Power has scheduled this program to 5
be in place about the middle of this year.
This is one 6
example of how a utility has taken the initiative to upgrade 7
its requalification program.
8 Progress on the resolution of this issue has been slower than we expected, partly because of the change in 9
10 personnel assigned to work on the issue.
As you recall, the 11 working group's initial NRC interface, Don Beckham is no 12 longer with the Commission.
The new primary interfaca, Bill 13 Russell and John Griffin are working together towards 14 identifying and defining tdue problems and possible solutions.
15 At our next meeting with you we plan to provide a more 16 in-depth briefing on this subject.
17 While we agree with the principles that I've discussed briefly, we strongly believe that each utility 18 19 should determine how best to implement those at their 20 utility.
As the NUMARC v.': king group proceeds to develop 21 conclusions on thit
.au..
we look forward to some additional 22 discussions with you and with the Staff.
23 CHAIRMAN PALLADINO:
This is still on requalification.
24 25 MR. MILLER:
Yes, sir.
13 1
MR. QUIN:
Still on requalification.
2' Now on access authori:stion --
3 CHAIRMAN PALLADINO:
Would you entertain a brief 4
. question?
5 MR. OWIN:
Certainly.
-6 CHAIRMAN PALI.ACINO:
I don't want to intarrupt you
-7 ctoo much.
But since I' feel quite differently about this 8
requalification, operator raqualification, feel that it should 9
be increased on the part of NEC ncr. decreased, I wca 10 interested in the specifics you had that wculd bring about
'll detrimental effects by pr:coading tith N2C r2cualifica:ica 12 exams.or even increasing them?
13 MR. CWIN:
Well, there are a number of areas.
I 14 think at time the exams have been somewhat unrelated to the 15 things that our folks feel are really the key things that the 16 operators need to know and understand.
And that has led to 17 some demotivation on the pecple who are standing for these 18 exams.
19 I think that follows that that can be corrected, and 20 in many places that has been corrected to some degree.
21 CHAIRMAN PALLADINO:
Isn't that a reason why we 22 should have more requalification, because these are the areas 23 that people tend to don't want to think about until they have 24 emergencies on which they could draw on this.
25' MR..OWEN:
No, we're not talking about those things
- r. -
14 1
hat the operator needs to know in order to deal not only with 2
normal operation but with emergencies, but things that are 3
just unrelated to --
4 CHAIRMAN PALLADINO:
Like what?
5 MR. OWEN:
Well, I can't think of something to quote 6
to you at this particular time.
We'll be happy to bring 1
7 forward some of those.
8 There was a survey taken of the kinds of questions 9
that have been on some exams that are really unrelated to --
10 COMMISSICliZR ZECH:
I've talked to a number of 11 operators on this very subject, and perhaps I can give a few 12 thoughts on it.
13 First of all, the criticism I get is that -- and 14 you're right, there is a considerable amount of criticism on 15 the program.
But the criticism I hear mostly is that the exam 16 is not related to what they really do, what they need to 17 know.
Some of them object to the fact that some of the exam i
18 is more theoretical than they think it should be.
Those are 19 the kind of things that I'v3 heard more often.
20-But mainly it's the exam doesn't seem to be oriented 21 towards what, at least some of the operators think they really 22 do in operating the plant.
And I submit that if that's true, 23 why then those are valid criticisms.
24 I think tha program -- there's a need for the 25 program.
I really believe that ~~ I'll be interested in your l
L
16 1
more specifics next time, because I think that's very 2
important.
There's no question but the program is gcod.
3 There is a lot of displeasure with the program 4
amongst some of the operators, I know, because they feel that, 5
first of all, they shouldn't even have to go through this 6
every year.
And that can be debated, of course.
7 But I think, if the program were realistic and aimed 8
towards what they really need to know, I think, frankly, most 9
of the operators would accept it as a valid program.
And I 10 think probably the program does need some kind of hard look to 11 make sure that it is the pregram that we feel is reasonable, l
12 and the operators accept as not only reasonable but something 13 that they should be challenged with and keep them up to date.
14 I don't think they would object to a program that 15 really has merit.
I simply think that perhaps next time when 16 you come back and give us your more specific recommendations 17 that I would feel a little more comfortable about it.
18 j
I don't object at all to having the utility people i
19 do their own checking on this program.
In fact, I think INPO 20 is doing some of that now, as I understand it, getting teams 21 at least from different utilities and going from one to i
22 another, perhaps not in the requalification area, but in other 23 areas of training, which I think is very healthy.
j 24 So those kind of things, I submit, are very good.
25 But I'd need to see some meat and potatoes in what you have in i
16 1
mind and try to. keep an open mind towards it.
2 MR. OWEN:
We will certainly respond to that.
3 I think you've stated very well what we've heard 4
from our folks as to the problem.
And I don't think that any 5
of the operators, and certainly none of the managers, object 6
to doing whatever is constructivo and boing sure that wa hava 7
highly trained, well qualified people who continue to be 8
skilled in the things that they need to do in order to run the 9
plant.
10 CHAIRMAN PALLADINO:
But one of the probla.93 -- !
11 don't want to dwell on it too long, but one of tha pr:bl us is 12 knowing what it is.
They're going to need to knew undar sc:a 13 of these emergency conditions.
Go when you begin to say you 14 want to take out the theoretical work because they don't use 15 -
that every day, that's precisely why I would say I'd like to 16
'see more, on the part of NRC, to keep it up at this high 17 standard because some of the recent events have chown that 18 people didn't really understand all aspects of just subcooling 19 versus the ability of a plant to --
20 MR. MILLER:
One of the things the industry is going 21 through right now is the accreditation process which is 22 supported by a tremendous foundation of work, which was 23 designed to produce the basis for what a guy needs to know how 24.
to do to operate that plant under all conditions, i
25 CHAIRMAN PALLADINO:
It would appear to me that once
17 1
that is done it gives you the foundatien to movo into both a 2
training program and an. examination and requal program based 3
on what he needs to knew.
Until that timo, you really have 4
two people that might meet exactly, but it's probably by 5
accident.
And that's from a guy that's never taken an exam.
6 MR. OWEN:
Mr. Chairman, there was no inference on 7
our part -- I'm sorry that John Griffin was not able to be 8
hora t day, but there is no interest on our part in that 9
Oparator
.0t having all of the technical know-how that he 10 nands.
- ia want to just be sure that it is aimed at the things 11 n't h3 nsads to knew for emergencies as well as normal 12 cperation in that it's demotivating to him to be tested on 13 things that he kncvs he never needs to know, even in emergency 14 conditions.
15 CHAIRMAN PALLADINO:
Well, I think we should be is avara of ways to improve the program and I'm not implying --
17 M2. CWEN:
Absolutely, sir.
18 M2. MILLER:
That is cur intent.
19 CC:IMISSICMER ASSELSTINE:
Let ma add Ona connant on 20 this.
21 First of all, I'm glad you brought this one up.
I 22 think this is an area of substantial concern on both sides and i
23 I think I have the same feeling that Lando does, after talking i
24' with a number of operators.
This is a source of frustration 25 and concern.
18 1
In fact, I just spoke with a group of training folks 2
.last night, over in Baltimore, and I heard this again from 2
ccmo of the people in your training programs.
4 One of the concerns I hears is that with the new 5
systems based training program,~ operators may be trained and 5
then they take an exam, including the requal exams that we 7
give.
And all of a sudden they get asked things that aren't a
covered by the training program.
4 9
If that's the case, then there really is a 10 disconnect and we do need to sort out.
If we're asking things 11 that we think they really nacd to know, then we need to hash 12 that out and then that needs to be put in the training 13 programs.
If we're asking things that they don't need to 14 know, then we shouldn't be doing that and we need to get that 15 part fixed.
16 MR. MILLER:
I think there's somewhat of a 17 disconnect.
I think the basis is there, through the 18 accreditation prcgram, to lay the foundation for correction.
19 COMMISSIONER ASSELSTINE:
But nothing is more 20 frustrating than taking an exam after you've studied and 21 worked for it, only to find out that you're being tested on a 22 lot of things that you weren't trained for.
That's just not 23 right.
34 And we do need to get it sorted out.
35 MR. OWEN:
I think the elements are in place to --
i
o 19 1
I've talked to both John Griffin and Bill Russell in recent 2
weeks and I think we're at the place now where.we've got a 3
good working arrangement and can move ahead with that.
4 COMMISSIONER ASSELSTINE:
I just would agree with 5
Joe, though, that I would like us at least to consider is 6
there a way to solve those problems and work it out in a way 7
that still permits a requal licensing program both by you and 8
-- to a certain extent -- by us, to provide that check, rather 9
than saying the answer is we stop the NRC requal program all 10 together.
11 At least I think it's worth exploring.
12 MR. OWEN:
Okay, we'll certainly do that.
13 COMMISSIONER ZECH:
May I just say one quick thing 14 on this and than we'll move along.
15 To me, the requal program should be an advanced 16 exam.
It should be people who are trained, they have taken 17 the exam, they have been operating the plant.
It should be an 18 advanced exam.
And by that I mean -- and it should have some 19 theory in it.
It should have some theoretical.
80 For example, when one of the bperators throws a
~
21 switch or turns a valve or manipulates something in the 22 control room, he ought to be able to tell you exactly what 23 happens.
What happens when you throw that valve.. What 24 happens down the line, through the electrical circuit, what 25 switches go, why do they go, and does that actuate -- down the
20 1
line -- a pump or something.
And they can tell you about the 2
hydraulic situation and so forth.
3 But he ought to mentally be able to describe se=a of 4
the theory that happens when.he takes this action and he ought i
~
5 to go through the whole thing.
6 Most good operators, they do think along this line 7
and I know they have skull sessions this way.
And they quiz 8
each other.
3
- Icok ac that, and 2 Juhmit, for a recall exam 10 that's kind Of a cenbinati:n of all cf the knowledge of 11 cperati ns 22 9211 as th) thacry, 22 well as the 12 tamperatures.
And ens cpara:cre kn:V the temporsturas and 13 they don't mind being a:::2d tha limits, and so forth because 14 they have those down.
And they appreciate the fact.
15 Some of the things we've been talking about here is recently, as far as prassurizar level and things like that, 17 the cperaters usually think abcut thase things.
But my 18 experience ha: shewn =2 td t th27'r3 goed things to think 4
13 about.
And they're things that, if they don't think about c
20 them -- if they prepare themselves for a requalification exam 21 properly, hey, that's the greatest value of the exam itself 22 perhaps, just going through the mental gymnastics of all these J
23 quizzes they give each other.
l 24 And they think about their own plant and they think i
25 about what can happen and they think about the weaknesses, i
i
21 1
- srha7;, in their plant and they think about the strengths and 2
they prepara chansalves for emergencies and for what really 3
- +
- c.
- .n ta2: plant.
4 And I submit that a requal exam ought to be aimed 5
towards that laval of kn:Vladge and understanding.
And if it 5
is then I think ycur p3rators really respect an exam like 7
that and they learn from it and it means something to them.
3 So I would submit that -- I hope that the requal G
exam will have at least scme of that kind of thrust to it.
10 MR. ONEN:
I think certainly it will.
I guecs the 11 Ona point I'd lika to leava is that it needs to be a 12 motivational developmental kind of process to improvo our 13 operators as opposed to something that's demotivating.
14 And I think, in many respects, what has been 15 happening has been demotivating for all of the reasons that 16 we've talked abcut.
And I think we all want to achieve the 17 some result.
We've just got to be innovative enough to como 13 up with comathing that accenplishes that.
19 COMMISSIONER ASSELSTINE:
Let me throw two quick 20 points, as well.
21 You might want to throw into the hopper use of 22 simulators as requal exam tools.
I gather that's a fairly 23 sensitive topic right new, too, and without a lot of ground 24 rules and understanding of at least what the rules are going 25 to be.
22 1
One other point, I am very pleased to hear about the 2
check operator approach and that you're pursuing it.
Jack, I think it's commendable that you're going to put it into place 3
4 on a pilot program.
And I think that holds real promise and 5
it may be a way to help solve the problem as well.
6 CHAIRMAN PALLADINO:
Okay, let's try your second 7
_ topic and we'll try not to interrupt.
8 MR. OWEN:
Fine, that's what we came for.
9 NUMARC became involved in the access authorization issue in December of '84 when we requested a delay in the 10 11 close of the comment period on a proposed insider safeguards 12 rule package.
And you agraed to extent the comment period and 13 ve formed a working group on insider safeguards.
This working 14 group reviewed the proposed rulemaking and developed an industry document which we entitled Guidelines for Industry 15 16 Nuclear Power Plant Access Authorization Program because it 17 believed that the rules package was overly prescriptive and 19 would not sorva tho best needs of the industry or the NRC.
We 10 did develop that guideline.
20 In our briefing, in March of 1985, we requested that 21 you withdraw the proposed rule on insider safeguards and 1
22 re-evaluate the need for existing regulations in this area.
23 As a result, you assigned the NRC Staff to work with NUMARC to 24 define the problems in this area and to determine an 25 appropriate course of. action.
23 1
NUMARC formed another working group at that time, 2
chaired by Bruce Kenyon, Senior Vice President of Pennsylvania 3
Power and Light to address the broad area of security and to 4
work with the NRC Staff.
5 Since that time, NUMARC and the NRC Staff have met 6
on a number of occasions and have developed a solution that is 7
agreeable to both NUMARC and the Staff.
The NUMARC guidelines 8
document formed the basis for this agreement and it underwent 3
marv changas in the precasa and in tha int 2racti:ns th::
- h
.10 plac2.
j 11 The Tuifalina dccuman; in::rycrata: :n s 2: 113c ti m 12 c:gertiss and 2::perienc2 ef b0th tha industry and tha U20 13 S aff.
Cen;3quantly, wo balleve tnat th4 guidalines ara a far 14 superier approach to the issue of accass authorizatien than 15 the proposed rules package.
The guidelines address the 16' nacassary requiranents for access authorization and provida 17 for n =cre roas nable inplementatica of tha regairenanta ind la are censids:;d an accaptabla alternativo to rulama%1ng by tha 13 URC Staff.
20 The guidelines were overwhelmingly endorsed by the 21 NUMARC executive group at its meeting in August, 1985.
And we 22 sent a letter to that effect, forwarding the guidelines to the 23 oxecutivo director for operations on September 5th, 1905.
24 We understand that the NRC Staff has ncW recommended 25 that you proceed with rulemaking in this area, even though 4
24 I
1 they consider the guidaline: 20:ap:2bla.
Th a U20 Staff had 2
two concerns related := the guidalinea, ena ralating to 3
monitoring and enforceabili:-f nd -h2 ::h2r :
an appeala 4
provision.
i 5
The first is the cencern regarding ths monitoring 1
6 and anforcaability of ths guidelinas.
To addrass that t
7 concern, the UUMA2C executive group, in January of this year, 1
l j
8 ovoruhalmingly agraad to modify the security plans at their 3
plants as necessary to = sat or excced the elomonts of th3 i
13 NUMARC guidelines if the guidelinos wore accepted in lieu of l
{
11 tha rulenahing, i
12 Thus the elonents of tha guidelines would be 13 incorporated into cach utilitias security plan and would then i
14 be enforceable by the NRC Staff, as part of the operating 15 license.
7' 16' The URC Staff has agreed that this approach is i
i 17 acceptable and ansvers the quastions concerning =enitoring la and enforcaability.
19 As I nald earliar, tha Staff has also expressed a 20 concern that the right to appeal by individuals denied access
{
21 to nuclear power plants is not addressed in the guidelines.
22 Utilities must maintain the right for ourselves and our I
{.
23 contractors to set high standards regarding who works in a 24 nuclear facility.
This, in our view, is essential to our s
I j
25 responsibilities' for the safety, quality, and cost of our
{
d l
)
i
25 1
nuOlGar CpGrationS.
2 We acknowledge our obligation to comply with all 3
todaral and stata laws concerning discrimination.
And we 4
strongly believe that they are sufficient existing means to 5
address perceived wrongs, including EEOC, state Human 1
6 Relatiens Commissions, and finally the courts.
7 We believe the onerous and highly prescriptive a
process in the current rule package is both unnecessary and 3
cnarcus and duplicative of many things that we are already t
10 d 1ng.
4 11 A: tha A07.3 full consittee meeting on February the 12 14th, just a de't 99eko ago, the ACRS reviewed the proposed 13 accons authori:stion rulemaking and the NUMARC guidelines 14 and -- as we understand it -- agreed that the NUMARC 1
15 guidelines ara the preferred approach to resolve this issue.
16 They also agr2od that the need for an appeals process in the 17 quidelinen er the rule was not well supported.
j 18 In cummary, 99 be11ovs that the industry developed i
13 NUMARC guidelines for industry nuclear power plant access 20 authorization program are a superior alternativo to the 21 proposed rulomaking in the access authorization area.
They i
I 22 were developed through an interactive process between NUMARC 23 and the Staff.
They incorporate our collective expertise.
24 They are agreeable to both the NRC and the industry and they 25 are fully supported by the industry.
i
e I
3 26 1
So we strongly enc =urage ycu to adopt the guidelines 2
as the best solution to this longstanding issue.
And we are 3
ready to move ahead with that, if we could.
4 CI!AIPJIAN PALLADINO:
The guidelines, though, don't 5
cover the appeal process or any appeal process?
6 MR. OWEN:
They themsalves dcn't cover the appeal 1
7 process, but our view is that there are already adequate F
8 appeal procasses in place in all of our companies and always 9
the ultinata raccurso to th3 cour53, if that is necessary.
Na 10 have appeal procesita for cur empicyaac tha: 23rva all the 11 other purpocca and vs.27a't :22 th: -.2:1 for a du711:stive 12 process hers.
i 13 Ua hava ashsd two 12 gal firma to give us their vious I
14 on the need for that and va havo hoon assured that we ara a
j 15 adequately covered from an appeal process standpoint and thero 9
l 16 is nothing abcut this that mahos it nococcary to have a 1
17 separata and diffarant Xind of sppsal capability.
19 S
wo uculd str:ngly ancouraga you to adopt thcao 19 quidelinos as the boot solution to the longstanding issue and 20 we can move on with getting that put to bed.
i i
21 How the other area that Jim asked me to discuss, 22 fitness for duty, the industry is continuing its progress l
23 toward meeting its commit = ants that we made to you in 1984.
l 1
j 24 We have received and are in the process of reviewing your most l
25 recent draft version of a policy statement on fitness for
-A
i
{
I 27 1
duty.
(
2 We understand that INFO will moot with the NRC Stati i
i 3
to discuss specific details regarding implanantTrica :f tha 1
i i
j 4
policy statement in early March, that that was the earlicct
[
i i
i 5
that they.could get together.
6 And as ycu requestad, vo'11 he w::::ing with them to i
7 formalize our comments on the policy stacament so that they r
1 8
can meet the March 17th data that you set for us.
We think 9
we'll be abla to dc that.
I f
]
10 Cvarall, va don'u aava major prob 11ma with the I
i
{
11 current draft Of tha pelicy statamont.
Un bollava that wo'll i
i 12 be able to work out una tv1 small remaining details en the 13 policy statomont with ths NRC Staff.
1 i
j 14 Since this issue was discussed at some length in our I
4 I
15 last meeting, unless you have questions on this issue, we i
i 16 don't have any additional comments to offer at this time.
i i
1 17 CHAIR:!A:t PALLADINO:
Just eno question.
In giving l
4 j
la your comments to the Staff, havs you censidsend er censultsd 6
j other groups, such as plant operator empicyos uniens or do 19 f
20 they reflect primarily your comments?
I 21
- 13. CW N:
Well, we are all moving ahead with the l
i j
22 implementation of our drug and alcohol abuse programs in 83 accordance with our commitments to you.
While we have been i
84 somewhat disturbed by not having this policy statement, we i
I i
25 have not buen reluctant at all to move ahead and are doing I
t I
l
28 1
so.
And each of the ccmpanios are carrying those discussions, i
2 as appropriata.
If they have uniens, with the unions.
.-3 We, for instanc1, ars right in the middle of our 4
training with our employees.
We're having individual sessions 5
with all of them.
Other ce=panies are doing similar kinds of e
1 i
5 things.
So vo'ra making excallant progress, in my view, from 7
that standpoinc.
3 What we would like to have is that policy statement 4
3 finally confirnad.
10 CZAIR:IAN MLLTDI:TCt C%27 11 "R.
MILL 22:
!cw lot =a incr:duca Jack Ferguson.
l l
12 As you know, and as ycu notad in 7:ur :p2ni..; remarks, j,
j 13
- !r. Chairman, liU:IARC has octablished a achnical subcommittee 14 and has moved into dealing with a selected number of issues in 15 that area.
And Jack will bring you up to date on what we've
/
r 16 dono in those area.
17
!!R. 722GUSCT:
Thank you, Warron.
t j
19 I uculd lika to provida a bria! cvarview of the i
j 13 technical subccmmittne, including its origin, its objectives i
s 20 and procedures, how the subccrmittoo fits into NUMARC, and a 4
i 21 brief status report.
i 22 The original fccus of NUMARC was on management and l
23 human resource issues.
But there's always been a discussion i
24 within NUMARC of the technical issues facing the utilities and 25 the difficulty experienced in posing these issues.
A
29 1
Recognizing this, the Utility Nuclear Power Oversight 2
Committee, or UNPOC, recommended that NUMARC establish on an 3
interim basis, a method to address selected technical issues.
4 The NUMARC steering committee took this 5
recommendation, and in August 1985, posed to the NUMARC 6
executive group the formation of the technical subccumittee.
7 The executive group voted unanimously to support this 8
proposal.
9 Before I diccuss the sub :=mittao, I'd 11%a ::
10 address cencerns c::pracced by sens of ycu at a pravicus 11 MUMARC-NRC Commissicn meeting concarning C 3 V7:07ri2:an3 u 12 of UUMARC's involvement in technical issuss.
13 I believe it's generally agreed tha spacific 14 management issues fall within the expertise and the 15 responsibility of utility management.
However, concern was 16 expressed about any attempt by the industry to prae..pt the 17 responsibility of tha NRC for technical issue 2.
19 I want to assure you that it is not tha intant of 19 NUMARC to preempt or usurp the responsibility dua to the 20 Commission or the Staff.
Technical expertise in the Staff is 21 recognized.
However, the industry has considorable technical 22 expertise and resources.
We believe that together we can 23 develop a better technical solution than either of us working 34 separately.
25 Furthermore, a mutually developed approach to a
30 1
technical issue will almost certainly ha implemenced more 2
quickly and more completely than ono that is proscribed by tha
.3 NRC, or-proposed unilaterally by tha industry.
4 While we fully expect technical disagreements and 5
some.hard-fought discussions, we believe that an open 6
technical exchange betwaan the two parties is tha seat 7
effective way to resolve technical issues.
And we urgo ycur 8
support of this approach to technical issues, just as you've 9
supported NUMARC on tho =anagement related 132033.
10 It is our intent to address, at 12as: at tha cutsot, 11 only a few carefully salactad tachnical issues.
2300 all these 12 issues are amenable to the NUMARC precass, nor is it desirabla 13 to preempt other groups and activities if succesaful closure 14 of technical issues can be reached by other means.
15 The technical subcommittee is to function in a 16 manner similar to other NUMARC activities.
And the first stop 17 is to identify and prioriti:e issues for pc331ble NUMARC 18 attentien.
19 If an issue meets our celection criteria, which I'll 20 list in a moment, a working group composed of senior utility 21 executives and technical experts is established to develop a 22 proposed position for the industry on that particular subject, 23 together with a plan,for closure.
24 This position is to be based upon input from the 25 responsible members of the NRC Staff, as well as from the
31 1
industry.
Upon the majority approval by the working group, 2
the proposal is procented to the technical subcommittee for 3
revieV.
If approved by ths technical subecm=itusa, it is then 4'
proposed to the NUMARc steering committee for approval, rework 5
or rejection.
6 Upon approval by the steering committee, the 7
proposal is voted upon by the entire executive group, which as 8
you know is composed of a senior executive from every nuclear i
1 9
utility.
If approvod by tha e:mcutive group, the propocal 10 then becomes the pcsition of the antira nuciaar utility 1
11 industry.
12 The and r33 ult 13 What Ve b0liava to be a fully 13 competent and rasponsibia cc=mitson by the entire nuclear 14 utility group.
15 The technical subcommittee reports to the NRC 16 steering committaa.
But unlike the remaindor of UCMARC, which 17 is supported by IM?o, the technical subcommittse and its t
18 working groups are supportad by CPRI.
This supports takaa tha 19 form of administrative support for the subcommittee and all 20 its working groups.
And in many cases, the principal 21 technical support is also provided by EPRI.
t 22 Each working group has a primary technical support
)
l 23 organization, which may be EPRI, AIF, or ownor's groups, or i.
l 24 some combination of the several organi:ations.
The technical 25 subcommittee is composed of five senior utility executives.
i
32 1.
They're regularly attended by.the working group chairmen, 2
representatives of EPRI, AIF, EEI, INPO,-APPI, and NRECA to 3
ensure the coordination of all active issues.
Representativos S
4 of owner's group and architect engineers are included where 5
appropriate.
6 The progress of the technical subcommittee since i
7 being authorized by the executive group in August of 1905 a
includes the following.
The charter of the technical 9
subcommittee has boon approved by the executive grcup and 13 incorporated inco the overall NU?tARC guidolin23.
11 Fcur meetings have bean hald, and four working 12 groups have been established.
These working groups addrass, 13 first, issue prioritization; second, station blackouci third, 14 safety goals, cost benefits; fourth, shutdown decay heat i
15 removal.
16 And I'll discuss briefly the status of each working 17 group, except for that dealing with statio1 blackout, which la vill be covered by John Cpoka.
19 The first working group, issue prioritization was t
20 established in conjunction with the technical subcommittee in i
21 August of 1985.
The mission of the working group is to i
22 develop and maintain a list of prioritized technical issues l
23 for the subcommittee.
The' initial list of issues was 24 generated from input from EPRI, AIF and EEI.
And our next i
85 step will be to review the listing of the NRC Staff and ensure
o -
6 a
33 l
l 1
that all high priority issues are included.
I 2
In order to prioritize the issues, five critoria 3
were established.
The criteria are, ripensas, im;crtanca, 4
amenability to the NUMARC process, breadth, and technical l
5 natures.
l 15 The ripeness criterion reflects the readiness of an l
7 issue for closure.
Since the purpose of the subcommittee is i
l 8
to close issues in a timely manner, generally only those 9
issues that are ripe will be addrescod by lTUMARC.
l 10 The issue should be important.
That is, significan-l h
l 11 to safety and/or of large potential financial impact to the 12 nuclear utilities.
13 The amenability to the ITUMARC process criterion 14 reflects whether it takes the backing of all the utility 15 executive to close an issue expeditiously, c
16 The breadth criterion considers the types of plants
[
i 17 involved.
For example, all LWRs, all PURs and so forth.
It I
i 18 is not the intent of the technical subcommittoo to adlraaa i
19 issues affecting only a handful of plants.
20 The last criterion, technical nature is included to i
al avoid this issues better addressed by the renainder of NUMARC 22 as a management and human resource oriented issue, or by some 23 other group.
24 Thirty-five issues are prioritized relative to the i
1 25 five criteria.
The issues were divided into three categories, l
i
34 1
active, monitored, or inactive.
Activa issues are thosa heing 2
addressed by NUMARC.
!!cnitored issues are those being 3
followed by NUMARC, however no near tarm a tien is 4
contemplated.
Inactive issues are those issues considered by 5
the prioritization working group, but which voro not judgod to 6
be of sufficient urgency for either action or formal 7
monitoring.
8 The prioritization working group was aakad to 9
prepara an abbreviated issue summary for each active and 10 monitored issue.
The issue summary addrazaas tha natura and 11 principal features of the 1:sua, including salaty 12 significance, potential cest, tlRC and indu:try involvimant, 13 areas of disagreement, outstanding tachnical quantiona, clecur 4
14 philosophy, and potential future concerns.
15 These summaries were developed for the working group 16 by EPRI with input from AIF.
Tha working group has 17 established a technical issue document for the subccmmittaa.
18 That document has also been distributed tc all ;tt:mac 19 executives to provide a concise, prioriti:ad listing of 20 technical issues, along with a short summary of the most 21 important ones.
22 And we'll leave copies of this document for you 23 following this meeting.
The document though, is intondad for 24 information only at this point.
25 The safety goals, cost benefit group was establishod
35 1
in November cf 1935 and is chaired by Wally Willis, vice 2
president, Florida Power Corporation.
There are three working 3
group objectivos.
To generato a position paper on avoided and 4
averted costs, recommend a procedure for safety goal 5
implementation, and suggest guidelines for utility cost 6
bcnqfit nalysis.
7 Wo believe that this working group is central to the 8
subcca:ittoo's activities, because cost benefit analysis and 3
- aft:7 7cals affac: alaca: all the technical issues facing the 10 au;1:ar utilittaa.
Th r,'
are also required for preper 11
- t. placentation cd th) backfit rulo.
12 The technical 200istance to this group is being 13 providad by 2?RI, A 7 and utility representatives.
At the 14 prosent timo, the working group staffing is nearly complete, 15 and work is beginning on all tasks, with the position paper on 16 costs being the most advancod.
17 The schedula f the working grcup is very la ambiticus.
No aro endssvering to suppert tha Gtaff's 19 objectivo to cl0so this iscuo by June 30, 1936.
20 CHAIP14AN PALLADINO:
That's a good objectivo.
21 MR. FERGU50N The shutdown docay heat removal 22 working group was autablishod in November of
'85, and Jerry 23 Niles of Northern Statos Power is tho chairman.
The working 04 group will coordinate the utility position on shutdown decay 25 heat removal.
36 1
The central issue is whether expensive modificatiens 2
are either desirable or effective in improving decay heat 3
removal system reliability, or whether procedural and 4
administrative changes with some selected hardware fixos are 5
mor appropriate.
6 The sources of technical support on this issue, 7
include the owner's group and EPRI.
It is necessary to 8
coordinate the ongoing owner's groups activities, becauso 9
apprcpriate actions are not common to all reactor designs.
10 Thorafore, there will probably be no generic tix.
11 The status of the working group, staffing is nearly 12 complete, the cooperation of the owner's groups has boon 13 secured, and initial contact has boon made with the NRC 14 Staff.
It's essential that the NRC Staff work very closely 15 and openly with the ITUMARC working group to achieve successful 16 resolution of this particular issue in a timely manner.
17 There has been this typo of closo cooperation 10 betwoon NUMARC and tho Staff in dealing with station blackcut
- 3 issue.
20 The NUMARC station blackout working group was also 21 initiated along with the technical subcommittee.
In part, the 22 station blackout issuo Was a strong stimulus for the formation 23 of the NUMARC technical subcommittoo.
24 As you know, the Nuclear Utility Group on Station 25 Blackout, or ! TUG 3BO, reprenanting a largo portion, but not all
37 1
of the nuclear utilities had previously tried to resolve the 2
station blackout issue with the NRC Staff.
However, the 3
effort at that time was unsuccessful, due primarily to the 4
lack of utility-wide support, or even utility-wide knowledge 5
of the proposed NUGSBO position.
6 NUMARC being the only organization with the ability 7
to develop a utility consensus would have been the logical 8
mechanism.
However, at that time, NUMARC was involved only 9
with management and human resourcos, not with technical 10 issues.
11 We'd like to give you a bit = ora detail on the l
12 status and the proposed plan of action for resolving tho 13 station blackout issue, and for that I'll turn this over to 14 John Opeka.
15 MR. OPEKA Thank you, Jack, and good afternoon.
16 Thank you for allowing me to brief you today on the 17 activities and progress that we have made with respect to tho 18 station blackout issue.
At our last briefing to you in 19 November we reported to you on the information and composition 20 of the NUMARC working group on station blackout, and our 21 intent to coordinate industry efforts to address this issue.
22 Since the November commission presentation, NUMARC 23 and the Nuclear Utility Group on Station Blackout, which is j
24 NUCSBO, which is the technical support group for NUMARC on
~
25 this issue, have met with the NRC Staff on five separate L
4 m
l 38 occasions to discuss resolution of the specific station 1
2 blackout issues.
I have attended most of these mootings and 3
have found the discussions pr ductivo towards rosciving the 4
station blackout issue.
5 We have reviewed the pr:pe:ad rule that we 6
undarstand Will seen bo iscual 20r cc ment.
Ua ara 7
particularly interested in receiving the backfit analysis that 8
is to be includod with the proposed rule.
Recent information J
is availablo that ccull affa:: :.10 validity en 2:: ptab12 10 backfit analysis aupportin7 thi naad for a ruli, 11 CIARC is cc it:2d :: ::cparating d r
- n
- tRC art!
12 to advancing managonant initiativas.
Tharafora, avon though 13 the Staff's backfit analyais haa not yet baan transmitted for 14 review, ITUMARC and ITUCS30 have been working with the NRC Staff 15 to develop a mutually agreeable resolution to the station 16 blackout issuo.
17 trU:tARC is considering tuo optiens to resolvo this 18 iccuo.
30th Optiens onecurago inproved r311 ability of tha 19 on-site and off-site AC pcVer sourcos.
20 The first is a modified rule option, which 21 potentially involves hardware and nonhardware changos.
The 22 second is a nonrule option, which contains nonhardware changes 23 similar to those proposed by !TUGSDO in May 1985.
24 The modified rule that we are currently discussing i
4
~
25 with the NRC Staff would involve eliminating the ruquired
39 1
study to determina the maximum duration of coping time for 2
each plant, which would result in unnecessary costly 3
analysis.
Instead, a simplified ccping study would be 4
required for a specific duration to be determined by 5
considering current on-site and off-site AC power source 6
reliability for each plant, and/or by the availability of a 7
diverse AC power source.
8 concerning a nonrule option, NUMARC is considering 9
an initiative consisting of an AC power reliability program 10 and other nenhardware programs which should ensure that the 11 existing level of safety associated with a station blackout 12 event will be enhanced.
This aspect of the station blackout 13 effort will likaly be pursued, whether or not any derivation 14 of the NRC Staff's proposed rule passes the threshold 15 established by a backfit rule.
16 In summary, we intend to continue working with the 17 NRC Staff towards reaching a prcept and rossonable resolution i
19 of the station blackout issue.
Based on recent experience, 19 UUMARC b u '. i rt. 3 in : agr33nent on the station blackout issue, 20 with a modified rule, could be achieved in approximately four 21 or more months once the backfit analysis is reviewed and i
22 accepted.
23 If a rule cannot be justified on the basis of a j
24 backfit analyais, we still intend to pursue establishing a 25 nonrule option that should reduce the overall probability and
40 1
consequences of a station blackout event.
2 CHAIRMAN PALLADINO:
I wonder if I could ask just 3
one question.
On a number of these hardware l'ssues the 4
Commission has been working on for a long period of time.
As 5
a matter of fact, I think, on the station blackout issue, 6
we've been working on the order of five years or so.
And 7
you're just coming into this.
8 And I don't mean you shouldn't get into it.
As a 9
matter of fact, we welcome your com= ants.
However, there does 10 come a point at which we lose great momentum if we just stop 11 and wait.
And an idea that croses my mind from time to time 12 is, well, can't we go out with this proposed rule and got your 13 comments at the same time?
14 Could you comment briefly on what you see as a 15 difficulty if we go that way?
16 MR. OPEKA:
Well, that's where -- at the last 17 meeting or after the last meeting it was indicated that therc 18 was intent to pass -- to. issue the proposed rule.
And based 19 on that, then our direction at that time was then to work with 20 the NRC Staff on the rule and see if we can modify it to be 21 something better than what would already exist.
22 We're very interested, however, because we do have 23 some disagreements on whether there is a need for a rule at 24 this time.
And what we want to particularly make sure is that
~
25 the-rule at least meets the-backfit analysis.
Once that's
41 1
achieved, then I see no reason why !TUMARC, as a coordinator 2
for all the other industry groups, can't work with the NRC and 3
resolve this issue within, I said, four or more months.
!Te're 4
well on our way right now.
5 And one of the biggest problem with the pracont rula 6
that we see now, which we've discussed with the Staff, is that 7
there'is a need.to determine a maximum duration coping 8
capability, which can be very costly.
And what we're saying 9
is that, there's no need to do that.
What v3 should ba doing 10 is determining what the reliability of the on-sica and 11 off-site AC power sources arc.
And once you de 2rmin2 that, 12 then determine what kind of coping capability you no d in I
13 order to meet the requirements of the rule.
14 I think that the Staff has somewhat receptive to 15 what we're suggesting.
But before we spent a lot in going 16 further any kind of modified rule, we'd like to make sure that 17 at least the rule, whatever it is, meets the backfit analysic.
18 CHAIRMAN PALLADINC:
Well, I think we've bought that 19 as a given, getting the backfit analysis.
But there sometimes i
20 is good desire, or well-founded desire to go out with a 21 proposal and get comments from industry and.others at the same 22 time.
But we'll have to take that up as it comes.
23 MR. OPEKA:
One of the advantages, I think you have 24 now with NUMARC is that we polled our meetings with various
~
25 industry groups that are addressing this issue.
And as a
42 1
. result, we feel that we can resolve this issue in a much more 2
timely fashion, because we'll coordinate industry comments, 3
instead of having the NRC hava to do that.
4 MR. OWEN:
Anything else, Jack?
5 MR. FERGUSON:
No, that's it.
Thank you, Warren.
6 MR. OWEN:
Okay, we had another subject that we 7
wanted to talk to you about.
C.O. Woody, as Jim indicated, is 3
a group vice president with Florida Power & Light, and has 9
bean chairman of our working group on maintenance for sc=e 10 t in a.
I'll turn it over to C.O.
11 CHAIRMN PALI.ADINO:
I am really going to have to 12 1e 2 72, and I apolegize'very sincerely.
I de have two
)
12
- ants, ena on =aintenance.
And I don't mean to steal your 14 thundar.
15 But we have seen recent occasions where, I think 15 thara were seven check valves inoperate, in part from 17 22 int 2 nance.
We had 12 valves in other area that hadn't 19 received any maintenanca since the plant began.
13 And we would appreciate anytning that NU:! ARC can do 20 to accelerate attention to maintenance, especially on those 21 components.
Sometimes people feel we're picking on a 22 particular. utility when it's a generic problem.
It truly is a 23 generic problem in =any cases.
But it's generically 24 applicable to a lot of utilities.
25 The other point I wanted to make was, I'd like to
43 1
- = mand NUMARC for the outstanding results'that you obtained 2
in your chemistry improvement program.
And the only comment I 3
had was, we can use all the help you can give us to ensure 4
that all licensees either meet the Staff's standard review 5
plan on this matter or the EPRI steam generator chemistry G
criteria.
I think that's something that you've made real 7
contributions on.
8 MR. OWEN:
We thank you for those comments.
'And we 9
.are sorry you're leaving, particularly because we're going to 10 nake a little presentation lator on what the industry has dene-l' in the way of water chamistry.
And we'll make sure that you 12 have the full benefit of that.
13 CEAIRMAN PALLADINO:
All right, I'll read the rest 14 of the transcript.
At least, I get the benefit'of that.
And 15
.my colleagues can give me any insight that I might not get 16 from reading the transcript.
17 Jim, I'll turn the gavel over to you.
18 Thank you very much though for joining us this i
19 afterncon and for being se patient.
i l
20 MR. MILLER:
We appreciate you all finding some 21 time.
We know it's been a long day.
22 CHAIRMAN PALLADINO:
Okay, thank you.
23 (Chairman Palladino left the room.)
24 MR. WOOD'i:
Good afternoon, gentlemen.
Thank you 25 for allowing me-to update you today on the activities of our
44 1
NUMARC maintenance working group and the. industry's effort to 2
improve performance of maintenance.
And I hope before I'm 3
through I will cover some of the things that the chairman 4
expressed concern about.
i 5
Since June 1984 the NUMARC maintenance working group 6
has brought together a large amount of nuclear industry 7
expertise to look into the maintenance issues.
In past briefing, I have described the systematic approach the working 8
9 group has used to review maintenance in the industry, and Oc 10 help identify areas in which to focus attention to improve 11 pcwer plant maintenance.
12 These efforts by the NUMARC maintenance working 1
13 group have given us a better insight into maintenance and have 14 resulted in various activities that I will discuss today..
15 As I reported to you previously, our review and 16 analysis determined that there are valid working programs in 17 the industry to support maintenance activities.
However, we 18 do recognize that there are various levels of performance 19 problems and implementation problems at some individual 20 utilities.
21 I believe as part of the industry overall effort.in l
22 striving for excellence, utilities are evaluating their own i
23 situations and taking appropriate corrective action to cause 24 improvement.
In fact, there's strong recognition in the 1
25 industry that good maintenance is a key to a well-run nuclear
45 1
power plant, and provides economic benefit to the customers.
2 From these and other equally important reasons, utilities are working to i= prove maintenance in their plants.
3 4
Let me illustrate some of the nuclear plant industry's more 5
-significant efforts directed toward improving the broad area 6
of maintenance over the past several new or strengthened 7
initiatives.
8 These efforts have involved the individual 9
utilitiac, supplisr3 2nd centractors, NUMARC, INFO, EPRI, and 13 other industry cr72nica:icns.
11 As ra;c :sf :: 7:u in our November '85 briefing, 12 NUMARC spent :ter 2 7 22 2naly:ing and assessing the state of 13 maintananca in tha industry.
This included a one-time, 14 multi-year rcot cause analysis of 653 significant events.
I 15 touched briefly before on the breakdown of the causes.
16 And just to stata a couple of those, 51 percent of 17 the rcct causas wara human performance; 37 percent were design 13 related.
Thirty-eight par: ant of tha human performance 19 problems were vastad in the maintenance area.
And of that, 20 the majority of the root causes were centered in the adequacy 21 and documentation of procedures.
22 Further, planning and scheduling was about 17 23 percent of the root causes; 16 percent, the failure to follow 24 procedures, and training about 12 percent.
We recognize that some subjective assessment was placed, but this was validated 25'
46 1
by mor2 than en 2 analys: a: the root cause analysis was done.
2
- chink this effort has been a cornerstone for our 3
being abla c direct cur activities in the right place.
4 We hava accistad INFO in upgrading in the 5
maintenance area cf thair INPO performance objectives and 5
crit:ria for c;2 ration and near-term operating license 7
plants.
8
[ Commissioner Bernthal entered the room.]
9 MR. WOODY:
We've assisted in the davolopment of 10 INFO's writing guidelines for maintenance test and calibration 11 procedures.
And again, that's because a significant number of 12 the rect causes were in the adequacy of proceduros.
13 We've assisted in development of a one-time 14 maintenance matrix analysis, which was prepared to serve as a 15 summary of the industry maintenance programs to improve power 16 plant maintenance performance and safety.
We've served as an 17 interface with varicus standards groups in the maintenance.
le We're centinuing cur intarfaca and mutual sharing of 19 infermation with the NRC Staff.
20 Significant assistance in the development of INPO's 21 guidelines for the conduct of maintenance at nuclear power 22 stations have been given.
This guideline is now being used by 23 cur utilities, and I will mention more about this later.
24 Further, development and acceptance of maintenance 25 performance indicators to monitor industry performance trends
47 1
and to assist utilities in identifying performance problems 2
has been another one of our key efforts.
INPO and the NRC 3
Staff, including Mr. Stallo, had a very productive performance 4
indicator meeting in December down at INPO headquarters.
In 5
my opinion, there was an excellent exchange of information.
I hope you've received some positive feedback from that meeting.
6 7
The industry is just now completing submission of 8
the 1985 performance indicator to INPO.
In the near term, 9
INPO will provide an industry performance indicator report for 10 the year 1985 for use by all utilities.
11 Lastly, but most importantly, focusing top nuclear 12 utility executive attention toward improving maintenance.
13 The NUMARC maintenance working group review indicates that 14 while some plants have excellent maintenance programs, 15 opportunity for improvement in maintenanbe exists in all 16 plants, some more than others.
17 NUMARC review did indicate that improved guidance on 18 post-maintenanca testing and plant aging analysis methodology 19 is needed.
These two areas are being addressed by INPO and 20 EPRI respectively.
21 Let me now briefly cover the principal activities 22 undertaken through INPO in the area of maintenance.
The 23 cornerstone of their work is the evaluation process.
They 24 have now completed over 300 plant NTOL and corporate 25 evaluations'and assistance visits.
Each focusing a-
48 1
significant amount of resources in the area of maintenance.
2 A second significant program is the screening, 3
analysis and dissemination of reports resulting from review of 4
nearly 10,000 reports per year.under the significant event and 5
evaluation and information network.
6 Management of the Nuclear Plant Reliability Data 7
System, containing over 400,000 engineering reports, and G
34,000 failures reports that is being used by utilities, INPO, 3
252I, N2C and cther: to i=prova n2 raliability of nu 132r la plant sysi an-3 and con;cnents.
11 T:r 2::: p12, cna cf Our utiliti::
.a : 2 tha 372 S 12 databacq to nelp an217:2 racurring failur:2 :f its 7 Il 12 ble %ing valves.
Oscarmining that it had a uniqua block valve 14 design and other plants were not experiencing this sane type 15 failure, the utility modified its blocking valves and improved 15 the maintanance precadures and training en chase valves.
This.
17 reduced its blocking valva failura r2 tic by a f acter of f:ur, 19 with en'2stimatad annual benefit to tha custe ars of $300,000 19 and.a throc-tanths of 1 percent increase in plant 20 availability.
21 There are some other examples of practical use of 22 NPRDS that will be given to you in a packet as we complete the 23 briefing today.
24 The development of the INPO guidelines for the 25 conduct of maintenance at nuclear power stations provides the
49 1
fundamental principlas :.' aff 2ctivs maint2nanca prcgrams for 2
all utilities :: use has ncy b:in cc plated and disseminated 3
to the utilities.
.inf I ' ll I n:l
- steu that in a fcu 4-moments.
5 Improved training prcgrams for machanical, 6
electrical, I;C craftaman, and thair kay managers -- and by 7
the latter, I mean the craft technical =anagers -- this is i
8 being done through the INPO managed accreditation program, and 9
supportad by pm.rfer ance cbjectives and criteria and training 10 guidelines in each area.
11 700 vill r2 call that I said earlier that in our root 12 cause analysis progra=, at 12ast 12 percent of the rect causes 13 ware detar=in2d te be lack of knowledge or vested in the 14 training area.
15 And then finally, assistance programs, including 15 special assist visits and industry participation programs and 17 workshops have been ver;r affective in raising the standard of 19 performanca lav21 in tha maintenance area.
19 A variety of maintanance-related activities have 20 been undertaken through EPRI.
These activities involve 21 industry expenditures of over S20 million in research to 22 improve nuclear plant maintenance since 1977, and scme $4 23 million in the current annual EPRI budget.
24 I'm pleased to report that after talking with John 85 Taylor earlier this week that the EPRI board approved recently
50 1
the request for $16.8 million between now and the year 1990 2
for additional research in the maintenance area.
These 3
projects will principally be vested in advanced robotics, also 4
in the predictive maintenance and on-line diagnostics.
I'll 5
again to speak to.that just a little later.
6 Some key EPRI activities in the area of maintenance 7
that have been recently completed or are currently in process include projects in enhanced predictive maintenance programs, a
8
' including programs such as vibratory analysis, generating 9
la arcing dataccion, valve and diesel generator and vertical 11 shaft pta; diagncstics.
Methods to improve system and 12 equivalent prevenrive maintenance programs, including a recent 13 dav210pmen: in tasting of an airline technique known as 14 reliability centered =aintenance.
15 Human factor programs related to maintenance, 15 including pr:gra=s such as equipment maintainability, job 17 perfornanca aids, and heat stress mitigation.
Programs l
13
- ulting in hardwara improvements, including areas such as i
19 valve =aintanance and testing, bolting practices, high 20 reliability and low maintenance instrumentation modules.
And 21 some of the details of these programs have been presented to 22 your Staff at a joint meeting that we had down in the EPRI 23 Charlotte facility.
24 Robotic applications to nuclear plant maintenance 25 activities is receiving a lot of interest from both the
51 1
utility and frem EPRI.
This is a principal target for the 2
next five years as maintenance and surveillance robotics will 3
be developed and tested in cur plants.
4 The EPRI maintenance equipment and application 5
center in Charlotte, North Carolina, to enhance and augment 6
the technology transfer is being used extensively now.
7 Suppliers and contractors are active in developing a
techniques and programs to improve overall maintenance and to 9
enhanca equipman reliability.
Typical supplior and 10 ccatrac:or activi:123 in tha area of '.aintananc2 include itana 11 such a3 spaci21i: 2t :::inire la :p2:ill maintsnane:
12 techniques.
2ecantly a reae:cr ecolant pump coal verkshcp 'tas 13 cc-hostad by a utility and cna Of the principal N333 venders, 14 attended by ever 100 utility personnel to improve techniques 15 on how to do this work and reduce manrem exposure.
15 2nchanga of information, information to enhance tha 17 perfermance cf main:cnanca, r2:r fit equipment with impreved la reliability 2nd maintainability, cutaga plannings and 19 management systems and support of engineering services, and 20 field support for plant maintenance, and special tool 21 development to improve maintenance performance and reduce 22 radiation exposure.
23 Perhaps the best ena=ple of that would be in the 24 vast steam generator work that's been done, and the tools that 2 5,.
have been developed to support that.
52-1 Tha intaraction of NUMARC indica:2 :c 2; that 2
individual utilities have directed considarabla attantion and 3
effort to upgrade maintananc3, in additien :: 1=;12.ran:in-4 activities appropriate for their plants.
5 Some examples of these efforts includa davalcpment 6
of i= proved corporata and plant gcals and cbjactives in 7
performance monitoring programs; improvements in maintenance 3
infor=atien manage =ent and work control systems; increased 9
maintenanca in th3 nain:snance suppcrt staffa and maintenance 10 facilitias, impl3:3ntation cf enhancad training and training 11 facilitisa fcr maintananca persennel.
Incr2asad maintananca 12 presence in the plants to enhance maint2nanco affectivenssa; 13 incrossad =anagsmant prasonca in tha plants to enhanca
=aintenance effectiveness; increased attention.to the quality 14 15 of balance of plant maintenance.
16 Furthar, increased domestic and international 17 technical axchange vicits are taking placc.
22 cant and widely 19 dictributed reper. cn tha Japanasa trip by tha nuclear i
l 19 industry is receiving wide distributien and being very 1
20 favorably acted upon by utilities.
A number of us, including 21 the utility that I work for, have entered agrcements with e
l 22 Japanese companies to share both management and technical 23 information.
24 And then finally, increased use of predictive i
25 maintenance techniques.
And let me'stop to give you the
i 53 1
benefit of a survey that we just got results back yesterday.
I' 2
We queried the entire industry the week before last 3
to ask what uso cf pr:dictive maintenanca techniques do you 4
now have?
And through a survey that centered around eight 1
5 processes, wa learned that 71 plants responding to us, that 99 4
5 percent of those plants are now using vibratory monitoring and analysis as a predictive =sintenance technique.
Ninety-three 7
1 8
percent of those are trending that information.
]
9 Fifty-four percent of cham, for exa=ple, responded i
10 tha: they do hava in place char cgraphy and infrared thermal 11 monitoring to both predict failur23 and to monitor when l
12 equipment should be maintained.
- tcr Operated valve dynamic I
13 current and vcitaga tasting, 53 parcent of the utilities now l
14 have that process in place.
i i
15 And for all of those, we find a surprising and very 16 favorablo responsa that thasa predictiva techniques are now in 17 place.
And 'Je vill provide this rapert to your Staff that la d3 tails tha 3%tansivanass of pradictive maintenance 19 techniques.
20 NUMARC believes that the programs established by the 21 industry through INPO are the proper vahicle for focusing cur I
4 i
22 industry-wide efforts to cause improvements in the area of i
l 23 maintenance.
Zack Pate has briefed you on INPO programs 24 several times in the past.
And I know that you are aware of I
25 INPO's programs.
However, let me share with you some recent s
_ _ _. _ _ _ _ _. - _, _, _, _ -,. _. ~ _ -..
O O
54 1
initiatives being taken in the area of maintanance that' 2
include the following.
3 Several utilities intend to conduct a 4
self-assessment of their maintenance programs using the 5
recently promulgated INPo maintenance guidelina as a basis 6
document.
I'm aware that about 20 percent of our plants aro 7
now or will be conducting this self-assessnent in devoleping 8
improvement action plans as appropriate.
9 INPO has agreed to ascia in sene of thasa affer s 10 and review the results of salected pile: 2:sasa 2nts te hsip 11 detarmine if e::panding the self-12:asanant aff:rt :: O rc.a 12 utilities is appropriate.
It is th2 Opini:n of Our ::rhing 13 group that this is, parhaps, tha highaat quality overall 14 document we've seen that constitutes a goed balanced 15 maintenance program.
And I have spoken to you previously 16 about the content.
The document has nov been finalised and 17 shared with your Staff.
18 As a result of a suggestien fr:m tha ucr%ing gr:up, 19 IMPO has initiated a =sintenanca peer ovaluator program for 20 selected INPO plant evaluations and assistance visits.
This 21
.is modeled after the very successful SRO peer evaluator 22 program.
This program will assist in strengthening the 23 evaluation prvcess and increasing technology transfer using 24 maintenance managers, supervisors and maintenance engineers.
25 The INPO-managed plant performance indicator program
.o.
95 1
Lis being strengthened as a tool for industry perfor=ance 2
monitoring and trending.
Quarterly reporting of data to INPC 3
by utilities has been established, and INPO will issua 4
periodic reports to the industry.-
5 Greater emphasis will be placed on incrassing the 6
use of the NPRCS data in supp;rt of maintenance and 7
maintenance related activities.
8 Finally, tha results of the recent survey on 9
predictive maintenance will be shared Nich utilitias and 10
.factorad into ongoing efforts.
11 In conclusion, I would 11%3 to say that althcugh 12 many of the efforus discussed with you ars relatively new, maintenance perfernance has alraady i=prov d'in some key 13 14 areas, such as upgraded plant cleanliness and material 15 condition, reduction in overall collective personnel radiation 16 exposure, and a general reduction of significant events and 17 unplanned reactor scrams.
18 We will 12ava with ycu today a pachat that sheva a 19 number of indicators.
And I'll just shcu this, for example, 20 as the very encouraging decline in number of significant 21 events per operating unit since 1981.
It has been cut by a 22 factor of three.
23 We are providing you with a handout to illustrate 24 some of the examples, and provide additional maintenance
~
25 information of all that-has been-done in the' last two years.'
56 1
Many building blocks ar.2 JLn place, and others are being put
~2 into place to improva maintenance industrywida.
Individual 3
utilities and the industry as a whole hava spent considerable 4
effort and resources to improve maintenance performance.
5 We are improving, and intend to continue, this 6
imprcving trend.
The NUMARC =aintenance working group will 7
continue meeting as needed to keep all NUMARC executives 8
' abreast of tha status of maintenance and any issues needing 9
their attantion.
10 NUMA20 will continue tc intaract with th2 H2C and 11 industry cr;2ni:stiens such 1; INro te facilita:2 impr:vnaanc 12 in the arca of maintenance.
Ycu and ycur staffs will c:ntinua 13 to.be updated in tha craa of maintenanca by I370, individual 14 utilities and NUMARC, as the need arises.
15 Thank you.
16 M2. MILLE 2:
I think we will also, of course, taks i
17 to heart what the Chairman said befora he left, and 93 till 18 undertake to do er to hcip gat dcnc what va nacd to de in that 19 regard as well.
20
- Mr. Owen.
Okay.
We have one other subject wo 21 wanted to cover.
At one of our previous meetings we were 22 asked to provide you with some information on what the l
23 industry has been doing in the area of water chemistry, and we 24 have asked Mark Withers from Portland General Electric to come 25 today and fill you in on that.
He-has been active in that for
57 1
a number.
Mark?
2 COMMISSIONER ZECH:
Before he goes'into that, may I 3
just make one quick comment on the maintenance?
4 First of all, I am pleased to see that the industry, 5
the utilities, the NUMARC group with the leadership there is 6
really getting into maintenance, and I am. encouraged by what 7
you are telling us today.
3 You have heard me say before, I think, that it has 3_
been my impression that there plenty of reca for impr r nanc 10 in maintanance, and that it dces lock lika ve are carmainly 11 moving in the right direction.
12 I am particularly pleased to hear ycu talking ab:ut 13 your predictiva techniques and also your emphasis on balanca 14 of plant.
15 I think it is important that maintenance cover a is wide area, and it be looked at and upgraded, if you will, and 17 given the management attention it looks lika it's getting with 19 the NUMARC omphasis, and I really commend you fcr that.
19 I would be particularly interested in any 20 maintenance effort you have underway in valve maintenanco, and 21 especially for check valves, and I hope that you are putting 22 some time in on that.
Limit torque valves, also.
There is 23 such room for improvement in some of those araas and scme of 24 the things that we have heard about recently that have 25 happened in the check valve area.
It would certainly seem to
r 58 1
me that maintenance plays a very large part in that, and 2
whether our regulations require it, or whether the utilities 3
themselves have programs for it, I don't think is the main 4
point.
The main point is that we should be looking at what 5
really needs to be maintained, and perhaps your group is-6 exactly the one to do that.
7 MR. WOODY:
A couple of comments, Ccmmissioner-8 Zach.
The ability to monitor on line the performance of 9
something like a check valve, we do not have that nachnolcgy 10 at this time.
We have talked about it.
I:iPO has alraady 11 gotten their ESA division involved in analy=ing particularly 12 those events that were mentioned by the Chairman carli2r.
13 In terms of motor-operated valvas, for example, one 14 of the EPRI projects has been in place now for about two years 15 and, in~ fact, has a deliverable, a much improved control 16 module that is based on a mini-processor that both controls 17 the valve and provides diagacctic tasting.
18 hotor-cporated valves havo bean a scurca of many of 19 the industry problems.
So there are programs that are baing 20 placed and developed --
21 COMMISSIONER ZECH:
. ell, I don't want to prolong W
22 the discussion, but-I really would appreciate any effort that 23 this group could bring, and any emphasis you could bring to 24 maintenance in these areas and others that perhaps have not 25 been given the attention in the past'for =aybe good reasons,
59 1
but maybe not so good reasons, either.
2 But, in any case, I do think that you are e=barkad 3
on an extremely important endeavor, and I command ycu for ycur 4
efforts and ask you to expand your fiald where you need to and 5
see if you can't bring about some wnat I considor needed 6
improvements in this area industrywido.
7 MR. OWEN:
We will certainly do that.
There has 8
been significant interest and, as you ccrrectly point out, 9
it's got attention by the senior pacpla in cur companias that 10 will result in the changes down cha lina that need to ta%a 11 place.
12 COMMISSIONER ZECH:
Goed.
(,
13 COMMISSIONER BER3 THAL:
Lat so maka On2 comment.
I 14 apologize for having missed a goed deal of your presentation 15 here.
Your comments particularly on diagnostics were of great 16 interest to me.
I don't know whether there are diagnostic 17 techniques available, particularly of tha mera modern 18 tschnology that you described, whether infrared or accustic 19 detection, that might be able to diagnosa on line the 20 operation of check valves, for example.
I suspect there may 21 be some hope with acoustic monitoring there, but I'm not sure.
22 But I would really encourage that sort of thing.
It 23 seems to me that if there's one thread that runs through so
~
24 much of what we hear at this table -- we heard it again 25 yesterday in the Rancho Seco affair -- it is the
60 1
nanavailability of critical diagnostic information.
In this 2
case it didn't require anything very sophisticated.
It would 3
have helped a great deal at Rancho Seco.
A red light might 4
have-done a gcod deal.
But generally maintenance activities 5
are quite a bit more complicated, and we all understand that, 6
buo I think that is an araa that with the technology available 7
now, deserves a very careful look.
3 I think you could probably buy you.r way out of a lot 3
cf trouble with 2:ma fairly inexpensive devices.
10
- Mr. C*ian.
I think ens of the examples that 11
0.0. rafar
d to claarly indicatos the cost-effectivonass of 12 good maintenancs, and've are well aware of that, and I think 13 us are moving -- making good prograsa in this area, and we 14 have get a vays to go, bWe wu intend to gat there.
15 COMMISSIONER ASSELSTINE:
Just before we leave 16 maintencnce, I am glad that commissioner Zoch brought up the 17 balance of plant quastion.
I think one of the sonces that wo 18 have gotten, particularly as ws hava locked at a number of the 19 operating events that occurred last year, is that so many of 20 the problems seem to originate there, and lead to events that 21 are of concern to you-all and to us.
22 I wonder to what extent the analysis that you did of 23 operating events highlightad the question of maintenance on 24 the balance of plant as opposed to the safety-related systems 25 and components.
61 1
MR. WOODY:
We did not segregate the two.
Anything
~
2 that was reported as a significant event was analyzed then for 3
root cause and-put in the same hopper, not segregated out as a 4
primary or balance of plant, safety-related.
5 COMMISSIONER ASSELSTINE:
Okay.
One of the lessons, 6
I guess, that I'm coming to see in these events is that the 7
important thing is to focus on what maintenance the equipment 8
needs and not to draw those artificial distinctions as we have 9
in the past between the safety-related and the 10 non-safety-related.
Let's treat the plant as a whole and 11 decide what really needs to be done.
12 MR. WOODY:
I think the thing that will spin out of 13 our work more than anything else is the INPO maintenanco 14 yuideline document requires that, and as we go through the 15 evaluation process with the utilities continually upgrading 16 their programs, we will all~be better in the long run because 17 of that emphasis on that criteria.
18 COMMISSIONER ASSELSTINE:
I was very pleased to hear 10 about the uses of NPRDS and how there are some tangible 20 examples that make sense both from an economic standpoint and 21 from a reliability standpoint.
It's good to hear that NPRDS 22 is being used and use for beneficial purposes both from a 23 safety and economic standpoint.
24 Also I was pleased to hear your emphasis on focusing
~'
25 top utility executive attention on maintenance.
I would ha
62 1
interested in hearing a little bit more about how you're going 2
about doing that.
3 MR. WOODY:
I think you ars helping us with it 4
somewhat.
5 (Laughter.)
6 Through your vicits and interactions, of course, 7
there's continuing recognition.
At every NUMARC executive 3
committee meeting that we've had in the last two years, I 9
think Jim has had me get up and beat on the tabl3 and talk 10 about the importance of the things that we're doing.
A hard 11 copy of all this material has been sent to them.
In 12 establishing the goals through the INPO process for theco tan i
13 key indicators, they were selected, to a great extent, with 14 this in mind.
So that both the selection of the goals and the 15 reporting thereof becomes a very visible thing to all utility 16 executives as we go down through the year.
The combination of 17 those things are bringing emphasis to this and many others.
18 COMMISSIONER ASSELSTINC:
You mentioned also that 19 there's some variation in performance on maintenance 20 activities, and you also mentioned performance indicators.
81 Which performance indicators do you think really are worth 22 keying in on in terms of identifying or differentiating the 23 success of maintenance programs?
Which ones would you look 24 to?
25 MR. WOODY:
At our meeting in December at Atlanta, I
63 4
t 1
think we had tried to do some validation of the 10 maintenance 2
performance indicators against both your assessment of the 3
plants and INPO's assassment-of the planto, and I think what i
4 we concluded from that is there is no strong correlation i
j 5
between those performance indicators and the overall view of 6
what constitutes a gced, ::all 2aintained plant, when you walk 1
7 in there and know it.
i 3
COMMISSIONER ASSEL3 TINE:
That's interesting.
1 9
MR. WCCDT:
Th :r 2 2:2 scue indic ::rs that have sene 10 correlaticn.
That's vny is faal na: tha us2 cf performanca i
11 indicators -- at thia ::in: in ina vcu hava to be carsful.
L 12 They arc.just indient:rs.
Thsy ar2 not abaciutas.
And to try 13 to usa them as absolutas would focus cur a::ention in the i,
14 wrong direction.
Things like the backlog of work, 15 relationship between corrective and preventive maintenance, i-16 those are good indicators, but you have got.to know what you 17 are looking at.
i 19 COICCSSICN2R AUSZLUTI !::
Okay.
I 19 M2. ONEN:
I guess it's really no different than any 20 other indicators that we have used in managing our business i
21 for years.
They are just indicators.
They are a piece of i
. 22 information that you can use as a manager.
I 23 COMMISSIONER ZECH:
But you are not saying not to t
24 use them?
i
~~'
l 25 MR. OWEN:
No, sir.
Absolutely not.
They are a
64 1
pioca of information that helps a. manager to know where to 2
direct his attention.
3 COMMISSIONER ZECH:
They are tools for analyzing.
4 MR. OWEN:
And we intend to continue to try to o
5-refine them and find better ones, because we did not find a
'6 strong correlation didn't mean that there is not a t
7 correlation, or that there is not --
8 COKKISSIONER ZECH:
Or you might need other 9
indicators, perhaps.
Okay.
10 M2. MILLER:
In part to the-question about top 11 management involvement, I can assure you I am involved.
And I 12 can also assure you I have a good ways to go, but we are on 13 the way and we're going to get there.
And I'm sure that Jack
(
14 is involved, and Warren and Woody and all of us at this 15 table.
And I think all these other. guys here, too.
16 COMMISSIONER ASSELSTINE:
Bart?
17 MR. WITHERS:
Good afternoon.
I appreciate the 18 opportunity to brief you cut the many efforts and improvements 19 being rada by th3 industry in the area of chemistry.
This is 20 in follow-up to some of the questions that were asked at the 21 last meeting on November 6th, 1985.
22 I have been involved in a number of areas related to
/'
2 3 chemistry and worked full time in that area for several 34 years.
Over time I have become more and more involved in 25 operating management, but I have maintained a high level of
65 1.
interest in plant chemistry.
2 I currently serve as Chairman of the Steam Generator 3
Owners Group which represents 35 domestic and foreign 4
organizations operating pressurized water reactors.
5 I might first note that although I am speaking on 6
behalf of NUMARC and the industry on this subject, NUEMC has 7
not formed a working group in the area of chemistry.
NUMARC 8
has formed a working group to address areas that, in the 9
collective opinion of NUMARC executive group, need a 10 coordinated, unified industry effort to improve effectiveness i n those areas.
12 However, in NUMARC's opinion, the.ov'erall industry 13 efforts that have been devoted to achieving improvements in 14 chemistry have been successful and are expected to continua, 15 thus precluding the need for NUMARC to become actively 16 involved in chemistry at this time.
17 This industry self-management has been manifested in 18 the individucl and collective efforts of nuclear plants, their 19 corporate support organizations and industry owner groups, the i
20 Electric Power Research Institute, and INPO and others.
21 The results of these self-management efforts have 22 resulted in substantial program improvements and, more 23 importantly, significant plant chemistry improvements over the 84 past several years.
25 I might note that these industry improvements in
66 1
chemistry have been obtained with little involvement or 2
activity by the NRC.
In effect, the area of chemistry is a 3
noteworthy example of how the industry has been able to manage 4
itself.
5 Efforts of the Steam Generator Owners Group vore 6
instrumental in promoting actions by the varicus utilitics 7
which have assisted the NRC in working to clcso cut unresolved 8
safety issues A-3, A-4 and A-5, related to tuba failuras in 9
the steam generators of the thraa 3WH vand:ra.
10 An important factor that brcugh; abou: many of chas 2 11 improve =ents has been the devalopment of industry guidalinas 12 for chemistry.
The guidelines have been devolepec through tho 13 efforts of the industry evner groups and have focussd on 14 secondary water chemistry guidelines for PWas and on boiling 15 water reactor water chemistry guidelines for the BWas.
16 These guidelines provide much tighter but achievable 1
17 chemistry specifications aimed at minimizing impuritias in 10 plant fluid systems.
19 EPRI is currently dev31oping primary water chomistry 20 guidelines for the PWRs that are being prepared by industry 21 committees consisting of utility consultants and NSS3 vendor 22 representatives.
23 These guidelines are expected to be completed next 24 month.
Because of the high quality of these guidelines and s
25 the improvements being cbserved at operating plants, INPO has
67 1
not had to develop water chemistry guidelines.
INPO, rather, 2
has been actively involved in ensuring that nuclear plants are 3
taking actions to neet and exceed the specifications which 4
have bean provided by these industry guidelines.
5 I believe the changes in the attitude of the 6
utilities tcwards the importance of plant chemistry can be 7
illustrated by our experience with the FWR secondary water 3
chemistry guidelines developed by the Steam Generator Owners 3
Group in 1931.
10 When these guidelines waro initially issued, there i
11 Slas considerable debate about the status of the guidelines.
12 Ine results of that debate were that the guidelines were just 1;
that, guidalines, for each utility to use as they deemed 14 appropriate.
They were not to be given to anyone outside the 15 Gwners Group, although they were later given to the NRC.
15 When Revision 1 of these guidelines was issued in 17 1334, the guidelines were unanimously endorsed by the owners 13 gr0up with a strong racommendation for full implementation by 13 all utilitics.
Copies were pr:v'.Nad :: tha URC and to INFO.
20 Pursuit of these guidelines in conjunction with 21 advancement in sampling and analysis techniques have 32 essentially brought about a new era in water chemistry 23 control.
Several years ago analysis and control of impurities 24 were limited to the parts per million range.
I 25 However,.new techniques now permit routine control
68 1
of selected impurities, such as sulfates and chlorides in the 2
low parts per billion range.
3 This represents an improvement by a factor of 1000 4
in measuring and control capabilities for selected impurities 5
in the water.
6 A number of plants have now adopted programs similar 7
to the ALARA policy, as low as reasonably achievable, which is 8
used in radiation protection, and they use this policy to 9
centrol chemical impurities.
Success in achieving the 10 reduction needad to meet the guidelines has spurred the plants 11 to strive beyond guidelines towards excellence.
12 Routine i= purity concentrations are well below even 13 guideline values at many plants.
14 In addition, a number of significant improvements 15 have been achieved in the reduction of chemical impurities in 16 plant water systems.
17 For example, anionic impurities, such as sulfate and 18 chloride,,in steam generators contribute to denting, pitting 19.
and wastage of steam generator tubes, and have caused several 20 utilities to replace steam generators.
21 3etween 1982 and 1985, the typical cation 22 conductivity, which is a measure of anionic impurities, in 23 steam generator water has been reduced by more than a factor 24 of five, from generally graater than 1.5 micromoles per a
t 25 centimeter to less than 0.3 micromoles per centimeter.
o 69 1
Since 1982, makeup water quality has been improving 2
throughout the industry, so that it is now approaching the 3
quality of pure water.
4 control of these chemical impurities has been 5
enhanced by improvements in system monitoring and analysis 6
capabilities.
On-line monitors, for exampla, are now 7
significantly aiding plants in rapidly detecting and 8
correcting abnormal chemistry conditions in condensate 9
feedwater and makeup water systems.
10 Analytical and monitoring capabilities of the 11 utilities have been significantly improved.
Fan 12 chromatography and atomic absorption spectrophotometry with
,I 13 graphite furnished capability are now standard features of 14 most nuclear plant chemical laboratories, and the current 15 trend is towards on-line ion chromatography.
16 Many plants have improved their programs for 17 handling and using chemicals within the plants, and have 18 improved sampling programs to prevant intrusien Of undacirad 19 chemicals.
i 20 INPO reports that chemistry quality control programs 21 and measures have improved substantially in the last two to 22 three years, and are now much better able to ensure that 23 sampling and analysis results are accurate.
~
24 Many p'lants have also made a number of substantial 25 physical improvements and implemented design changes or b
70 1
improved equip =ent maintenance to correct conditions that have 2
been adverse to good chemistry control.
3 As an e:: ample, removal of copper alloy materials 4
from condensate and feed systems and improved chemistry 5
controls have substantially reduced copper levels in steam 6
generators.
7 Copper intrusion in steam generators has resulted in 8
tube bending and pitting.
9 Another 2::ampl 2 Of improved performance is a 10 reduccicn in c:nlenaar air in-leakage, which in turn has 11 raductd th 1_.:Z_h:02 :f general corrosion of plant systems.
12 Five years age 1: n: ty;1:al for the best plants to run with 13 cir in-la: Mag: Of 20 :::ndard cubic feet per minute.
- However, 14 the best plants neu oparate in the range of zero to 5 standard 15 cubic feet per minuta, and approximately half are routinely 15 cperating balev 10.
17 C:ndan32:2 d2nineralizers have been installed or 18 upgraded in m:ny plant to r3 duce the quantity of the 19 impuritias added to staa= generators or the reactor.
Sena 20 plants have installed deaerators to remove oxygen from 21 condensate and feed systems and reduce general corrosion.
22 A' number of plants have significantly upgraded the 23 operation of makeup water systems or installed new, improved 24 systems, to improve their makeup water quality.
25 In the area-of chemistry research, EPRI has-
71 1
cendu:23d numerous technical research projects to develop 2
ransdi2s for known or suspected chemistry problems.
These tcaarca activities have been aimed at identifying impurity 4
scurces, quantifying the effects of impurities, developing 5
improved monitoring techniques, reducing the intrusion of 6
impuritias, improving impurity removal, and reducing the 7
impact of such impurities.
8 As I mentioned earlier, EPRI was involved in 9
developing guidelines for watar chemistry, as well as the 10 development of complementary guidelines to assist utilities in 11 achieving the target water chemistry spacifications.
12 EPRI is also currently ccnducting a number of 13 projects aimed at improving chemistry performance in the 14 plants.
15 One example is a project to reduce corrosion and 16 corrosion product activation, which will in turn reduce 17 radiation levels during maintenance and operation.
19 EPRI is finding hors'that the addition of zinc to 19 BWR coolant, for example, shows promise of significantly 20 reducing radiation from corrosion product activation.
21 Similarly, pH control in PWR primary systems can 22 minimize radiation fields in steam generator channel heads 23 through reduction in corrosion product transport.
24 In BWR reactor water, hydrogen additions are also 25 being used to reduce-oxygen concentrations and thus retard
72 1
2 EPRI is also involved in developing improved 3
guidelines with the design, operation and maintenance of 4
secondary and makeup systems and monitoring equipment in order 5
to help optimize secondary water chemistry.
6 EPRI has sponsored a major effort to develop and 7
improve nondestructive examination techniques.
These 8
examination methods are widely used by the utilities to 9
monitor the material condition of systems and ccmponents.
10 Verification of material conditions is a vital part of any 11 improved chemistry program.
12 INPO has been actively involved in bringing about 13 industry improvements in chemistry also.
Since 1981, INPO has 14 evaluated chemistry as one of the major performance areas 15 during plant evaluation.
16 In 1984 and '85, 89 evaluations and assistance 17 visits were performed, resulting in formal findings and i
18 recommendations addressing areas for improvement in chemistry.
19 INPO also follows up to ensure that responsive 20 actions are effective.
21 INPO provides special assistance to utilities upon l
l 22 request.
This assistance often consists of one or more 23 experienced professionals who can provide specific help to 24 utilities, often in areas related to recommendations made
~
25 during INPO evaluations.
73 1
~In 1984 and '85, 25 such special assistance visits 2
were conducted, representing a total of 248 man-days of 3
assistance to the requesting utilities.
4 INPO collects written information about particularly 5
effective chemistry programs during evaluations, and makes 6
these available to the utilitios upon request.
7 In 1984 and
'85, INPO responded.to 125 requests for 8
assistanca information.
Two INPO chemistry workshops have 9
bren held to proacto e:: hanga of inferraticn areng utility 10 chasiatry ::nagers and 10 anceur2ge
..p'.t:2nta:icn of needed 11 ir7::"22:nts.
12 In 1933, 143 people 1:02nd2d, r2 prs:2nting all but 13
- 30 nucl3ar utilitiO3.
In 1304, 171 pacpla at:andad, 14 representing all but one nuclear utility.
15 Plant chemistry workshops have been hold annually by 15 the Staam Ganarst0r Cwners Group for plant managers to focus 17 their attention on ch3=i3 ry.
A Cari33 cf enemistry working 13 meetings are scheduled through ut 193G.
19 Chemistry training procra=3 ar2 also improving.
20 Chemistry technician training programs are being accredited by 21 the National Nuclear Accrediting Board.
Six programs have 22 been accredited to date, and self-evaluation reports completed 23 for 21 additional programs.
24 This represents approximately one half of the 25 accrediting effort.
74 1
In a.ddici n, cha.:iatry : 1chnician qualification guidelines and job cas% an21 saa have been daveloped to aid in 2
7 3
tha accr2 dita:icn ;!
- a ning aff:r:3.
4 Many utilities currently use chemistry parameters as 5
one of the performance indicaters for follcuing their plant 6
cperations.
7 In summary, the industry has achieved substantial 3
improve =snts on its own in the area of chemistry.
The 3
e::iztanca of an improving trend, however, does not mean that 10 va believe ch2mistry performance has been optimum.
We 11 racegni:o that improvements ar2 still noodod, and we will 12 continun to work to bring about improvements in this area.
13 Thank ycu.
14 MR. MILLER:
Thank you very much, Brad, and thank 15 you, gentlemen, for letting us be with you today.
15 COMMISSIONZR AS3ELSTINE:
I have just comment on the 17 chemistry.
I apprecista that presentation.
It's interesting 18 and gecd to he:r about tha many improvomants that have been 19 achieved thars.
Lando, I know that's an arca that you have 20 emphasized as well.
21 It strikes me that this is another one of those 22 happy marriages of benefits in reducing occupational 23 exposures, benefits in improving safety, and also benefits in 24 economics to the utilities, and I commend you for those 25 efforts.
It's good to hear'of those.
75 1
MR. WITHERS:
Thank you.
I believe there is a real 2
pay-off in these programs.
3 COMMISSIONER ZECH:
I'd like to make a comment, if I 4
may.
5 First of all, I am pleased to see that there are 6
improvements being made in the area of chemistry in our 7
plants.
My feeling is that there is, as you indicated, I 8
believe, more improvements needed, and certainly I believe 0
cc.
I always felt that chemistry is kind of the lifeblood of 10 tha ;1 ant, and the only way you really knew a lot of things 11
~cin~ :n inside the system, what really goes on, is through 12 enew.istry, both the primary system and the secondary side, 13
- 20.
And that gives you a real good indication.
14 And also my impression has been, in my earlier 15 visits to the plants, since becoming Commissioner, was that*
16 chsmi2try was not an area that was getting the attention that 17 it cheuld have been getting.
I felt about chemistry like I 13 did about esintenance.
13
- must say I have been encouraged by more recent 20 visits, and by your presentation today, for example, that the 21 aanior management group, NUMARC in particular, is emphasizing 22 chemistry.
23 I think you are absolutely correct in saying that 24 some utilities in particular have done a good job in 25 chemistry.
Others have not, in my judgment, given it the
t O
76 1
attention it should have.
2 For example, I was surprised to learn that all 3
utilities, for example -- at least this is what I have -- I 4
think this is correct -- all utilities don't even have 5
procedures for power reductions or other corrective actions if 6
they have chemistry that's cut of specs.
7 New I don't suppose we require that in NRC, but 8
maybe we shculd.
Iut I was kind of interested to find out 9
tha: if you'ra :u: cf : pacs in chanistry, you dcn't hav2 ::
1::
reduca ;c-; 2 r. c yen don' ht"2 :: do :thar :hings.
11
- .hirl part:;; 2: a u :Lir:ics.de ha"a cuch 12 requirementa, :u at 17: 7: :
uld datormino, all de not.
13 That did curpri:2 me.
14 Chamistry 10 very important.
I had the opportunity 15 not 1cng ago to look at the steam generator out at that 16 rasaarch lab in Idaho.
I was nec impressed.
It was supposad 17 00 last der 0 y20r3 cr 7.cra, and it lasted -for aix.
It 19 leched prn 07 rn cut t: ma, and cartainly not a gccd exampla 19 cf chemistry, ycu knew, and I think that chemistry has to play 20 a big part in the deterioration of that relatively new steam 21 generator.
22 So all I'm saying is that -- and I agree with you 23 that INPO has helped and made a significant centribution to 24 increase emphasis in chemistry, and I am pleased to see that 25 NUMARC is taking an active interest in chemistry by our
77 1
presentation here today, but I da cuanti: tha 21:hcugh 2
improvements have been mado, thera ic plenty of reem 'er 3
improvement.
It dccc need rather acres -tha-3 ri an;hacia by l
4 all utilitics, not just some, and I think thara.is~a Ways to 5
go, and I think it is certainly in ycur best intarast -- when 6
we're talking 220:ndary chemiatry, of course, wa'ra. talking 7
the balance of plant side, and again it's the balanca of plant 8
side that I think perhaps should be getting more emphasic than i
9 it's getting, aa C missiencr A33alstina pointad cut earliar, 10 too.
11 30 I just athmit that -- and I cartainly 12 respectfully request that veu continua your emphasis in this
,t 13' regard.
I think it's a Wall chcaan Way to spond some i
14 executivo time, and I do think it is in your best interest as 15 well as more reliable and. safer operations.
i 15 M2. MILL 22:
Thank you, Commissioner.
We certainly 17 vill take into ac00unt what you have caid.
13 Mc have nothing furthar.
19 CCMMISSICNER ASSELSTIU2:
Ckay.
Thank you very l
20 much, Jim, Warren and the others, for your precentations.
21 They were very useful and very informative, as always.
22 Again, let me extend our apologios for delaying 23 you-all in the meeting and keeping you lato today.
i 24 MR. MILL 2R:
We thank you for putting up with us 25 this late.
i
o 78 1
CO:CIISSIONZR A33EL3TINZ:
No problem.
2 If nothing else, the meeting is adjourned.
3
[Whereupon, at 3:22 p.m.,
the meeting was 4
adjourned.)
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 30 21 22 23 24 1
25
a s
1 CERTIFICATE OF OFFICIAL REDORTER 2
3 4
5 This is to certify that the attached preceedings 6
before the United States Nuclear Requ i s tory Ccmi ss ien 1 r.
tho
.7 matter of:
CO CIISSICN.'!CETING e
9 Name of 3ree wfing-2 i-2 f i M Cn a:tl.M :ni;1ative3 f ?dlic
. ! 0 c cir c. )
1C 11 Cocket No.-
12 PIace:
Washington, D. C.
13 Date-Wednesday, February 26, 1986 14 15 wars held as herzin sopases anc thst t h i -s is tna original 16 transerept thereof (or tne 4ile et the Unit +d 9 tat 4s Nuctese 17 R92u i e t ory Com i s s i on.
19
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(Signatura)
[p 4(,, p,i 39 (Typed Ns=e of Reporter) pamo.L./jtiggio 21 22 23 Ann Riley 4 Associates. Ltd.
24 25
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AGENDA:
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ACCESS AUTPGPIZAT;GM IECHNICAL SUECCMMITTEE ACTIVITIES JACK FERGUSON, PGESIDENT VIRGINIA FoWER 1
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- MAINTENANCE ACTIVITIES C,0, WcODY, GacVP VICE PRESIDENT FLcRIDA PCWER AND LIGHT CHEMISTPY IMPROVEMENTS BART WITHERS, VICE PPESIDENT PORTLAND GENERAL ELECTRIC
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