ML20204B781

Transcript of 881014 Meeting in Rockville,Md Re Proposed Rule for Maint of Nuclear Power Plants.Pp 1-56.Supporting Documentation Encl

ML20204B781
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Issue date:	10/14/1988
From:	NRC COMMISSION (OCM)
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References
FRN-53FR25169, FRN-53FR47822, FRN-53FR9430, FRN-56FR31324, REF-10CFR9.7 AD-1-25, AD-2-3, AD00-1-25, AD00-2-003, NUDOCS 8810200317
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{{#Wiki_filter:- - _ - - - _ _ _ ORG\\A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i l

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BRIEFING ON PROPOSED RULE FOR MAINTENANCE OF NUCLEAR POWER PLANTS Location: ONE WHITE FLINT NORTit, ROCKVILLE, MARYLAND Date: FRIDAY, OCTOBER 14, 1988 l Pages: 1-56 i i l l Ann Riley & Associates 1 Court Reporters l ~ 1625 i Street, N.W., Suite 921 Washington, D.C. 20006 l (202) 293-3950 / l I f I I ssio;o0317 8;:-:1014 l hh5,7 FDC -l

9 o' DISCLAIMER This'is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on 10-14-88 in the Coilimission's office at One White Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This transcript has not been rev'tewed, corrected or edited, and it may contain inaccuracies. The transcript is intended solely for general informational parposes. As provided by 10 CFR 9.103, it is i not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any j statement or argument contained herein, except as the Commission may authorize. O e* e G S e 4 e y-

7 -- 1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 4 COMMISSION BRIEFING ON PROPOSED RULE FOR 5 MATNTENANCE OF NUCLEAR POWER PLANTS 6 t 7 (PUBLIC MEETING) 8 9 Nuclear Regulatory Commission 10 One White Flint North 11 Rockville, Maryland 12 13 FRIDAY, OCTOBER 14, 1988 14 15 The Commisalon met, pursuant to notice, at 10:00 16 a.m., the Honorable LANDO W. ZECH, Chairinan of the Commission, 17 presiding. 18 COMMISSIONERS PRESENT 19 IANDO W.

ZECH, Chairman of the Commission

) 20 THOMAS M. ROBERTS, Member of the Commission 21 KENNETH CARR, Member of the Commission 22 KENNETH ROGERS, Member of the Commission 23 24 25 e

0 l o 2 ,'VRC STAFF AND' PRESENTERS SEATED AT THE COMMISSION TABLE: 1 2 3 S. Chilk W. Parler l 4 J. Taylor E. Beckjord 5 T. King B. Morris 6 T.Murley E. Jordan 7-T. Novak T. Gody S 9 AUDIENCE SPEAKERS: 10 B. Lee, NUMARC 11 12 1 13 14 i 4 1 15 16 17 18 ,s. I 19 20 i 21 l 22 j 23 ) 24 25 9 e

0 1 PR0CEEDINGS 2 CHAIRMAN ZECH: Good morning, ladies,and gentlemen. 3 On August 16, 1988, the NRC Staff briefed the Commission 4 concerning the results of a public workshop held in July to 5 explore issues related t.o the development of a proposeo rule on 6 maintenance of nuclear power plants. The proposed rule w0s is 7 being prepared by the Staff, consistent with the Commission's 8 policy statement on maintenance of nuclear power plants. The 9 Staff recently forwarded a paper to the Commission which 10 requested a vote that provides the details of the proposed 4 11 rulemaking on maintenance of nuclear power plants. 12 The Staff has also recently forwarded a paper to the 13 Commission for information.concerning preliminary results of 14 the trial program on maintenance performance indicators. There 15 is no question in my mind concerning the strong relationship 16 between effective maintenance performance and nuclear safety. c 17 This relationship becomes even more apparent as the current [ t 18 generation of nuclear power plants age. In my view, it is 19 important that this agency have the regulatory tools necessary 20 to assure that maintenance is properly and effectively 21 performed in order to assure the continued safe operation of f l 22 nuclear power plants. I 23 This morning, the NRC Staff will'brief the Commission I l 24 concerning the proposed rule for maintenance and the statussof 25 its efforts to develop indicators of the effectiveness of [ e

s 4 1 maintenance at nuclear power plants for the use in monitoring 2 individual plant maintenance performance. 3 I understand that copies of the Staff's presentation 4 are available as you entered the room. 5 Do any of my fellow commissioners have any opening 6 comments before we begin? 7 (No response.) 8 CHAIRMAN ZECH: If not, Mr. Taylor, you may proceed. 9 NR. TAYLOR: Good morning, Mr. Chairman. The Staff 10 presentation today will be basically in two parts; first, by 11 the Office of Research and then by AEOD. With me at the table 12 today are Eric Beckjord, Bill Morris, Tom King from Research; 13 Ed Jordan and Tom Novak from AEOD, and Tom Murley and Tony Gody 14 from NRR. 15 As you emphasized, Mr. Chairman, this proposed rule 16 has as its objective the enhancement of safety by strengthening 17 the effectiveness of maintenance throughout the nuclear 18 industry. Although there are a number of licensees who are 19 conducting excellent maintenance programs, there are others 20 where there is room for substantial improvement. 21 The proposed rule defines in very, general terms what 22 the Staff believes constitutes a good maintenance program and 23 specifies the datu'when all licensees should have such programs 24 in place. The EDO's po'sition is that there is a need for such 25 a rule.- The Federal Register Notice, which would accompany the

I 5 1 proposed' rule, indicates the commission's preference that the 2 industry assume considerable responsibility for implementing 3 the rulo. Specifically, the industry is called on to develop a 4 standard for maintenance, which would incorporate the good r 5 practices being followed by those utilities who have 6 outstanding maintenance programs -- and there are those -- and I i 7 it builds upon ongoing industry initiatives. You heard about F i 8 some of these initiatives during the presentation on August 9 3rd. 10 The Notice also requests comments on the possibility 11 of establishing a third-party maintenance certification 12 program, again the idea that maybe the industry will l \\ 13 participate in certifying maintenance programs at the 14 utilities. 15 In summary, the nuclear industry is being invited to 16 participate in implementation of the maintenance rule in a way L l 17 that will take advantage of the best knowledge, experience, and ( l 18 initiatives in conducting maintenance that the industry has to [ r 19 offer. 20 The rule is general, because there are many different 21 ways to accomp.ish good maintenance, and this is reflected in 22 varying program in the plant. 1 I 23 Although the ACRS is not yet convinced, the EDO and I 24 .both bellave that the maintenance rulemaking strategy that the f I l l 25 Staff has pioposed to you will be effective in enhancing i P I

y ~ 6 1 1 safety. We will come back to the ACRS letter later in the 2 presentation. .3 At this time, I will turn the discussion over to the l 4 Office of Research and Eric Beckjord. 5 CHAIRMAN ZECH: Thank you very much. You may 6 proceed. 7 MR. BECKJORD: Thank you, Mr. Chairman. j 8 We are here this morning to present the proposed rule 9 on maintenance of nuclear power plants. The important in this { 10 action are the following: December 30, 1987, the Staff sent an l 11 interim policy statement on the maintenance of nuclear power i 12 plants to the Commission for its consideration. i 13 February 16, 1988, the Advisory Committee on Reactor 14 Safeguards sent its letter of comment on this statement to you. 4 l 15 February 25, 1988, the Commission approved the 16 interia policy statement as modified for publication as a final i 17 statement and directed the Staff to develop a proposed rule. March 23, 1988, the statement was published in, the 18 I i 19 Federal Register. I 20 The action for rulemaking was assigned to Research, l 21 the Office of Research at the end of March, and the Staff sent 22 its proposed plan and schedule for rulemaking to the Commission 23 on May 23rd. 24 Since that time, the Staff has held a public workshop 25 already referred to, to obtain the views of interested parties. G e e

7 1 It initiated and has received a raport by consultants on 2 observations and recommendations for this tule -- that is, the 3 Inaba Report. It has met with the FAA, with EPRI, INPO, and 4 people from France, the Federal Republic of Germany, and Japan, 5 who are knowledgeable in maintenance practices of nuclear power 6 plants in those countries, and it has prepared the proposed 7 rule and the regulatory analysis. 8 The proposed rule requires that licensees develop a 9 documented maintenance program that addresses all the 10 activities listed in the policy statement. The rule also 11 encourages the industry to develop a standard that defines an 12 acceptable approach to satisfying the rule. The schedule for 13 industry compliance with the proposed rule is two years after 14 Commission approval. 15 Mr. Tom King of the Office of Research is prepared to 16 make a detailed presentation to you on the proposed rule. 17 CHAIRMAN ZECH: Thank you very much. You may 18 proceed. 19 MR. KING: The purpose of the presentation is to 20 summarize the contents of the Notice of Proposed Rulemaking 21 which was sent to you at the end of September in SECY-88-277, 22 including our plans and schedule for implementation of the 23 proposed rule. 24 Briefly, the presentation today will cover a summary i 25 of the work done leading to the Notice of Proposed Rulemaking, e I

1 a brief description of the supporting documentation developed, 2 our conclusions and recommendations for the rule, comments on 3 the ACRS letter that we received, a discussion of the schedule 4 and implementation plan, and a review of the contents of the 5 Notice of Proposed Rulemaking package. 6 Beginning on page 2, just briefly, we had submitted 7 our plan and schedule for this proposed rulemaking to the 8 Commission in May of this year, developed a rulemaking options 9 paper in June, which was provided to participants in the 10 workshop, and included in that paper was a strawman rule for 11 one of the five options that were included in the options 12 paper. We held the workshop in July; we briefed the commission 13 on August 16th on the results of the workshop, and in parallel 14 with these efforts, we reviewed foreign country and other U.S. 15 industry maintenance practices, as Dr. Beckjord mentioned. 16 Our Notice of Proposed Rulemaking reflects and takes 17 into account what we've learned from all these various 18 activities. We have developed some. supporting documentation to 19 go along with the Notice of Proposed Rulemaking. That's listed 20 on pages 3 and 4 -- a summary of the proceedings of the 21 workshop, a draft NUREG that summarizes our maintenance -- the 22 maintenance approaches and practices that we looked at in the 23 U.S. and in foreign countries, and we received a report from 24 our consultant, Dr. Inaba, and his views on the proposed 25 rulemaking. The reports will be available to go into the PDR G

9 i l 1 at the time the rule is published for comment. These are the i 1 2 reports that will give you an idea of the extensive work that 3 was done. 4 Basically as a result of the workshop and the review i 5 of these other activities, the maintenance practices, the Staff 6 recommends that the Commission proceed with a general rule. ] 7 Basically, the thrust of that rule is, one, that it will i 8 specify those attributes in the policy statement, which the 9 Commisalon considers essential for an effective maintenance 10 program, and this will include provision for monitoring program i 11 effectiveness and feedback to improve the maintenance program, t ) 12 and its an approach which we believe promotes and encourages [ 13 industry participation and responsibility for defining, 14 monitoring, and improving maintenance programs, thus building -f 15 upon the ongoing industry initiatives. i 16 On pages 6 through 8, there is a brief summary of the l l 17 rulemaking approach. f 18 As I mentioned, it's a general rule; we propose it as l 19 10 CFR Part 50.65. It will require licensees to have a 20 documented maintenance program addressing all the activities l 21 listed in the Commission's policy statement. We believe these 22 activities as listed in the rule essentially represent those 23 items which, through, experience and judgment, contribute to 24 effective maintenance. t i 25 The rule has only made minor wording clarification l ( l l I

? I 10 7 1 changes to those attributes as listed in the Commission's 2 policy statement. The rule would apply to all systems, 3 structures and components in the plant, commensurate with their 4 safety significance. 'fhat means that everything in the plant j r 5 would be covered, but perhaps some of the attributes may not l 6 apply to certain systems or components that have little or no 7 safety significance. 8 COMMISSIONER ROBERTSt Would you repeat that last? 9 MR. KINGt The rule would apply to all systems, 10 structures and components in the plant; that some specific [ 11 attributes that are listed as part of the maintenance program 12 might not be applicable to certain systems or components that 13 have little or no safety significance. For example, root cause 14 analysis may not be necessary on some electrical system that 15 doesn't have any safety connection. 16 COMMISSIONER ROBERTS: But if I read the supplemental 17 information section, it says the rule is intended to cover all 18 systems, structures and components, including these in the 19 balance of plant. 20 MR. KINGi Yes. That means the basic provisions of 2.1 good maintenance; following procedures, having good 22 communications and so forth, would apply to everything. There 23 may be some specific engineering evaluations that perhaps you 24 wouldn't need to do on systems or components that really don't 25 have much to do with safety of the plant.

11 1 COMMISSIONER ROBERTS:.Well, I guess my question is 2 to the Gener'al Counselt do we have the authority to initiate j 3 rulemaking on things that are not, quote, "important to { i 4 safety"? l 5 MR. PARLER: A question such as that was addressed to i 6 se in connection with the Surrey matter, as I recall, and 7 perhaps also in connection with how our requirements a 4 interrelate with those of other agencies such as OSHA. I i 9 As long as there is some possible basis for relating l 10 that which we are trying to reach to radiological health and l 11 safety, we have the authority to reach it from a regulatory [ 12 standpoint.- If someone concludes -- which one rarely concludes [ ) 13 in this business -- that there's absolutely no possibility of I 14 such an intarrelationship that could affect safety, then we do 15 not have the authority to reach it, unless there are 16 environmental considerations that are involved, and then f , ossibly we could reach it under the National Environmental i 17 p l 18 Policy Act. l t i 19 COMMISSIONER ROBERTS: The short answer is we could 20 reach it. { 1 l l 21 (Laughter.) [ 22 CHAIRMAN ZECH: All right, you may proceed. l 23 (Slide.) I j 24 MR. KING: Continuing on to page 7, the rule includes j j 25 a requirement for licensees to assess their program i r 1 ..L-... '=.-.-

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12 1 offectiveness and make improvements where warranted, although I L 2 the rule does not require the licensees to report performance j 3 indicators. We believe this provision in the rule adds the t 4 performance-based considerations to the rule, although at this l t 5 time we are not prepared to spell out specific performance I 6 indicators to be reported. 7 The rule, we believe, encourages industry to develop l L 8 a standard to define an acceptable way to meet the rule. Our 9 intent would be that NRC would review and endorse that standard 10 in a Regulatory Guide. As I mentioned before, this is an l l l 11 effort to promote industry participation and responsibility for l l 12 . good maintenance, and allows the utilization of the industry l 3 j 13 initiatives in this process. 14 (slide.) J 15 Finally, on page 8, compliance with the rule would be 16 determined by NRC auditing inspections. And as another provision we've added into the Notice of Proposed Rulemaking, f A< 18 we solicit comments and proposals for third-party certification f J 19 of plant maintenance programs. We've put this in as a further [ I j 20 effort to promote industry responsibility and participation in f i 21 problem identification and resolution. i 22 (slide.) i 23 Page 9, on September 13th Ve received a letter from l 24 ACRS as a result of our review with them of this Notice of I 25 Proposed Rulemaking package. That letter basically had two -{ i l I I i

13 1 points in it. One was that they weren't -- it wasn't clear to 2 them that the maintenance rule would reduce risks at nuclear 3 power plants; and they were concerned that it may detract from 4 good maintenance at some power plants. i l 5 (Slide.) 6 Our views on this are discussed on pages 10, 11 and 7 12. I don't think there's any question that well-maintained I l l 8 plants represent lower-risk plants versus those that are poorly 9 maintained. I don't think ACRS disagrees with that nor does anyone on the Staff. 10 ) i 11 What we did with the rule was try and structure it so 12 that licensees' maintenance programs,will be required to ) 13 include those attributes that have been determined by [ i t 14 experience and judgment to contribute to effective maintenance. -l 15 Although it's tough to measure effective maintenance l 16 quantitatively, we believe that such a rule if properly i i 17 implemented would contribute to reduction of risk at power f 18 plants. L 19 (Slide.) 20 on page 11 we've provided the Staff's regulatory l i 21 analysis which made an attempt to quaritify such risk reduction. i i l 22 We also believe that the rule is not solely directed toward 23 today's poor performers. In other words, it should not be l 24 looked at as just an effort to bring up today's poor performers l l 25 to some acceptable level, but really is directed toward I c t i

.[ 14 1 ensuring consistent performance over time. 2 (Slide.) 3 Regarding the second point of ACRS, that it would be 4 detracting from good maintenance programs, we believe the 5 provision for encouragement of industry to take the lead and 6 develop a standard and perhaps pursue a third-party 7 certification program provides an opportunity for them to i 8 develop a maintenance program thet would not detract from their 9 initiatives and would not detract from good maintenance J 10 practices at existing plants today. 11 COMMISSIONER ROBERTS: Before you leave the ACRS, I 12 quote directly from their letter. "The regulatory analysis 13' provided by the Staff makes an arbitrary assumption that a 14 reduction in risk will occur ac a result of the rule, and bases l 15 its cost-benefit conclusions on a guess about the amount of 1 16 risk reduction expected." I think that's a rather strong i 17 criticism. i 38 MR. KING: We don't believe it's an arbitrary ~ 19 assusption that there is a reduction in risk. The regulatory 1 20 analysis looked at the reduction in risk several different j 21 ways, and there was some basis for the numbers that are in the 22 regulatory analysis. I can go through that now or I can go 23 through that at the end of the presentat, ion when we get to the I j 24 slide and talk about how we estimated the risk,' what the l l 25 assumptions were. Whichever you prefer. l i

4 15 1 COMMISSIONER ROBERTS: Just for my own information, 2 did you meet with the ACRS and make a presentation to them? 3 MR. KING: Yes. We've met with them four times; two 4 with the subcommittee and two times with the full committee. 5 COMMISSIONER ROBERTS: You certainly didn't persuade 6 them. 7 MR. KING: Obviously we didn't persuade them. 8 CHAIRMAN ZECH: Proceed. 9 (Slide.) 10 MR. KING: On page 13, the schedule for the final 11 rule, to meet the Commission's desired complation date of April J 12 of '89 to have a final rule we have developed the schedule that 13 is shown on page 13. We would hope co be able to publish the 14 proposed rule by November 1st of this year, have a 60-day l. 15 public comment period which would and in January. That gives 16 approximately two months to look at the public comments, make I 17 any revisions to the rule we believe are necessary, prepare a 18 final package, go through ACRS and CRGR reviews, and provide to i 19 the Commission a final'rvle package the beginning of April. 20 And we would hope then about a month later the final rule would { 21 be published. 22 (Slide.) j l 23 The plan for implementation is shown on pages 14 and I i 24 15. As proposed in the Noticc of Proposod Rulemaking package, i 25 the rule would require full implementation two years af ter the O 4 S 9 e n

16 1 final rule is approved. It calls for licensees to develop 2 their own implementation plans 90 days after approval. It 3 calls for or encourages the industry to develop a standard that 4 we could review and endorse in the Reg Guide; however, we also 5 propose a parallel effort -- that the Staff in parallel with l 6 the industry developing a standard. The Staff would develop a 7 draft Reg Guide basically for two purposes; one, it could be 8 used as a benchmark with which to evaluate the industry 9 submittal, and two, it provides a fallback in case an industry 10 submittal does not come forward. 11 We would plan to issue the Reg Guide, whether it 12 endorses an industry standard or whether it's our own, in April 13 of 1990 to provide approximately a year to the industry to 14 implement the requir.ements or the guidance in that Reg Guide 15 prior to the time the rule is fully effective. 16 If there is an industry standard, we would hope to 17 receive that approximately a year from now in September of ' 89 18 so that we can review it and go through our process of 19 developing a Reg Guide and going out for public comment on that 20 Reg Guide to meet that April of 1990 date. 21 (Slide.) 22 On page 16, the contents of the Notice of ?roposed 23 Rulemaking package. In 5ddition to the proposed rule itself, 24 the package has supplementary 1nformation, particularly some 25 guidance on what we telt were attributes in an acceptable 9 e 9 e

+ - - - - - - - 17 1 standard, some additional items for considsration which came 2 out of our look at other industries and other countries' 3 maintenance programs and practices, some specific comments that 4 were requested of industry, and the regulatory backfit 5 analysis. 6 (Slide.) 7 Pages 17 through 19 we list the attributes we believe 8 are necessary for an acceptable maintenance standard which are 9 included in the Notice of Proposed Rulemaking. Basically, they 10 are that (1) it should define the plant systems, structures and 11 components included in the maintenance program -- that's just a 12 common sense item. It should be based upon or require a 13 systematic evaluation of the functions and objectives of the 14 plant systems, components and structures -- in other words, we 15 vant to make sure that the maintenance requirements in the 16 standard on itidividual components and systems are consistent 17 with and support the overall plant performance objectiv,es. 18 (Slide.] 19 Page 18, we state it should provide clear and 20 specific programmatic requirements that can be practically 21 implemented. Too general a standard doesn't accomplish much; 22 too specific a standard doesn't allow flexibility, and we think 23 there needs to be a balance in there to provide enough guidan'ce 24 to the licensee so that he can develop the details of his 4 9 m 9

18 1 the standard get into the specific requirements for components 2 and systems and technical requirements, but would provide 3 enough information for a licensee to develop those in his 4 standard that he would maintain at the plant. 5 We believe it should address all the activities and 6 functions included in the proposed rule including a provision 7 for self-assessment. It should reference standards or 8 guidelines that are already on the street developed by ASME, 9 INPO, EPRI and so forth. We believe this standard is a good 10 place to tie together all the various ongoing maintenance 11 initiatives and activities that are on the street today that 12 are directed toward improving maintenance. 13 (Slide.) 14 We believe the standard should allow flexibility for 15 adoption of new innovative technologies so that it doesn't 16 prohibit improvement in the way maintenance is done, and should 17 require sufficient documentation so that progran effectiveness 18 and compliance with these requirements can be determined. 19 The final rulemaking package will be in a position to 20 expand on these attributes and provide further detail as to 21 what we believe constitutes an acceptable standard. 22 (tilide. ) 23 Starting on page 20 is a summary of the items that we 24 feel ought to be discussed and ought to be considered as part 25 of developing a standard, based upon the things we learned in e

19 1 telking with foreign countries and other U.S. maintenance 2 programs at FAA, Boeing and so forth. 3 These are basically items at this point in time that 4 we want to put on the table for discussion; we're not putting l 5 them forth as hard and fast requirements at this time, but they 6 derive from discussions where people we talked with said, these 7 are things that we feel are key to out programs, and we wanted 8 to get those laid out and on the table for discussion ir. the 9 development of this standard. I will just run through those 10 quickly. 11 Numbers 1 and 2 are basically tied together. We feel 12 that the standard should focus on long-term maintenance [ 13 objectives and promote a proactive maintenance program versus a f i 14 reactive maintenance programs. In other words, emphasize -i i 15 things like preventive maintenance, predictive, reliability-16 centered approach to maintenance. This would include looking 17 at what needs to be done when you do maintenance as vs.1 as how j 18 often yoQ do it, and optimize both of those activities. 19 (Slide.) 20 Page 21. Root cause analysis. Engineering 21 evaluation of failure data (root cause analysis). We feel l 22 that's an important factor to a good maintenance program. l 23 Using an integrated information system for collecting data and i i - 24 using that to monitor effectiveness and feedback to improve [ f 25 maintenance. t L l

20 1 Maintenance technician training and certification 2 programs. There was a statement in the attributes in the 3 commission's policy statement and in the rule dealing with i 4 maintenance personnel training and qualification and we wanted i 5 to emphasize it here as something other people said as very 6 important. t j 7 Providing, planning and scheduling from overall 8 program objectives -- that ties in again with Items 1 and 2; a 9 top-down approach, making sure what you do is consistent with i 10 the overall plan objectives. 11 (Slide.) t I 12 Page 22. Enhance the environment / motivation of 13 skills and maintenance technicians through what we~ call, some i 14 people call, cross-training or crew chief concept. In other i 15 words, have certain crew's be experts on certain systems or i j 16 components in the plant. They will be able to apply their 17 expertise we believe and become more efficient and more j 18 accurate in terms of doing naintenance'. i l 19 Would define interfaces between maintenance and other 20 activities. That certainly would seems a common sense thing te f 21 do but again, it was pointed out by a number of people that f 22 this is a key area that needs attention to make sure you've got i 23 the proper work control and the proper communications going on 24 when you're doing maintenance. I l 25 And finally, include in your maintenance program i j

1 21 j 1 those things we're learning from the plant aging studies. As 2 you know, the office of Research has an extensive aging program 3 underway and there's valuable information coming out of that. 4 A lot of that information deals with what should be looked at 5 in maintenance, how do you do good maintenance to counteract 6 some of these aging concerns. We feel that ought to be 7 considered in any maintenance standard. 8 (slide.) 9 Pages 23 and 24, specific comments that we requested 10 in the Notice of Proposed Rulemaking. 11 First, is it appropriate for the nuclear power 12 industry to develop a maintenance standard, ai? if so, would 13 the industry develop such a standard. We would 1.ike to get 14 feedback early on at this stage of the rulemaking development 15 trom the industry as to whether they will step forward and take 16 the lead to develop a standard. 17 A furthy. follow-up question: what level of detail 18 should be included in the standard. We'd like to have specific 19 comments back regarding that. And the timeframe we proposed: 20 two years to develop and implement such a standard. We asked a 21 question specifically directed towards the reasonableneus of 22 that approach, that schedule. 23 (Slide.) 24 There's a question on the third-party certification 25 process -- would someone be'willing to do tnat, is it '1 O g p _

~ 22 1 appropriate to do that. 2 And finally, a discussion on maintenance performance 3 indicators and some feedback from the public and industry 4 regarding should they be in the rule and is there a set out 5 there that someone believes is a validated set that would give 6 us an indication of performance and' effectiveness of 7 maintenance. 8 (Slide.) 9 Finally, the last slide on the regulatory and backfit 10 analysis. The basic conclusion is that the rule will have an 11 overall positive benefit; it's based upon looking at public 12 risk reduction, it's based upon looking at costs, both the cost 13 to the inductry and cost savings that result from increased 14 plant capacity factor. ~ 15 Regarding the risk reduction, we looked at it two 16 ways. In Generic Issue, HF-8, it was titled "Muintenance and 17 surveillance Program." It was prioritized a couple years ago 18 and just recently resolved. In the prioritization resolution t 19 of that generic issue there were risk estimates developed for 20 what a good maintenance program does to reduce risk. 21 Basically, it builds upon Japanese experience and was based 22 upon looking at the reduction in the number of scrams caused by 23 having a good maintenance program. It l'ooked at the U.S. 24 industry average number of scrams per year, and based upon the 25 Japanese data made an assumption on how that number would come O v G a

) 23 1 down as a result of a good maintenance program. And using 2 Oconee and Grand Gulf PRA's, estimated the reduction in the 3 risk from that reduction,in the number of scrams. 4 As a result of that analysis, there's an estimate of 5 300,000 person rem reduction in risk over the life of the 6 existing plants. 7 The second way that we looked at risk was using NUREG 8 1150 risk numbers and based upon information that we have on 9 safety system failure rates of plants that have what we believe 10 are poor maintenance programs versus those that we believe have 11 good maintenance programs, came up with an estimate that plants 12 with poor maintenance programs have a factor of 2 to 3 greater 13 s' e.y system failure rate than those with good maintenance 14 programs. We factored that back in to NUREG 1150 risk numbers 15 and estimated a risk reduction. That risk reduction came up 16 with a range of 120,000 to 720,000 person rems -- the point 17 estimate we used was 2f9,000, and that we fesl is pretty 18 consistent with'the risk reduction estimated from the 19 resolution of Generic Issue HF-8. So that's the number we used 20 as our point estimate in risk reduction. 21 As far as costs go, we looked at a number of costs; 22 we tried to include everything whether they were benefits or 23 whether they were costs to the industry or costs to the NRC. 24 The two' basic ones were the cost to the industry to do better 25 maintenance, and va felt that cost would be limited to

24 1 approximately 25 percent of the plants that would have to come 2 in and do maintenance in a better way than they're doing it 3 today. And we eatimated a cost on that b'ased upon experience 4 and reportC from the Salam Nuclear Power Plant. 5 The cost-benefit primarily comes fr7m the reduction 6 or the improvement in plant capacity factor, and that's based 7 upon a correlation of looking at plants that receive low scores 8 in the SALP process.from maintenance and surveillance. Perry 9 knows that it received high scores in maintenance or 10 surveillance in looking at their difference in capacity factor. 11 And again, that only applied to 25 percent of the plants 12 because those are the ones we feel will actually get an 13 improvement as a result of this rule, and we estimated a cost 14 based upon a five percent increase in capacity factor for 25 15 percent of the plants. 16 The rest of the costs were fairly minor, but when we 17 went through and added all of that up we estimated a net cost-18 benefit to industry from implementing this rule. 19 That quickly. summarizes che Notice of Proposed 20 Rulemaking package and completes my presentation. 21 CHAIRMAN ZECH: Thank you very much. 22 MR. TAYLOR: Mr. Chairman, we're prepared to proceed 23 with the AEOD portion -- 24 CHAIRMAN ZECH: Yes, I think you should proceed with 25 that. e 4

e 25 1 COMMISSIONER ROBERTS: Do you want to save all 2 questions for the end? 3 CHAIRMAN ZECH: We can do it either way. If you'd 4 like to ask questions now, go ahead. 5 COMMISSIONER ROBERTS: Well, you mentioned scrams, 6 and I'm looking at the document and as I understand it, by NRR 7 -- and I'm looking at the 1985 weekly average of scrams as 8 10.4, in '86 8.9, '87 8.5, '88 weekly average year to date 6.0. 9 Now, certainly scrams, in evaluating plant safety, is a two-10 edged sword, and I fully understand that. But this is a pretty 11 compelling trend. 12 MR. KING: You believe it's coming down already, 13 without this rule. 14 COMMISSIONER ROBERTS: Absolutely. 15 MR. KING: We assumed an industry average of 5.3 16 scrams per year in the -- 17 COMMISSIONER ROBERTS: As a result of this rule? 18 MR. KING: No. As the industry average prior to 19 implementing the rule. So I think we're -- 20 MR. TAYLOR: The Staff does recognize the improvement 21 in scram rate in the U.S. We also recognize there are other 22 countries who have much better numbers than we have been able 23 to achieve. When I say we I mean of course the industry. And-24 it is something that is incremental improvement; 25 Those numbers d6 reflect I think improvement. Tom, I e

F 26 e 1 think you share that view. The Staff does feel it can improve 2 more, and that's just one part. The Staff is still concerned 3 at maintenance issues at numbers of plants across the country. 4 It comes up very frequently in our discussion of plants where 5 performance is not what it should be. It isn't always 6 reflected in trips. It's equipment out, it's getting into 7 LCO's, limiting conditions for operation. And I think it's on 8 that basis that the Staff -- we've looked at maintenance 9 through the years and the Staff definitely thinks there's room 10 for improvement still in the U.S. industry. 11 Tom, do you want to add to that? 12 MR. MURLEY: I subscribe to that completely. j 13 CHAIRMAN ZECH: Any other questions? Commissioner 14 Carr, Commissioner Rogers? ~ 15 COMMISSIONER ROGERS: I would rather wait. 16 CHAIRMAN ZECH: Let's proceed. 17 MR. TAYLOR: I will ask Mr. Ed Jordan, AEOD Office 18 Director, to start with his portion. l I 19 CHAIRMAN ZECH: You may proceed, Mr. Jordan. 20 MR. JORDAN: Thank you. The purpose of our part of 21 the presentation is to give the status of the Staff's 22 ma.intenance performance indicator development, activities. This 23 development has been expedited, and could I have Slide No. 2, 24 please. 25 (Slide.) O O 4 9 g G w

4 4 27 1 This development has been expe'dited and is on a 2 parallel course with the development of the proposed rule. The 3 AEOD Staff effort since July concentrated on the collection and 4 analysis of pla t data in a trial program. This trial program 5 was designed te deve4op and validate maintenance performance 6 indicators. 7 The program included discussions with INPO personnel, 8 support from the Office of Research and from contractors. The 9 AEOD Staff effort is about four person years over this three-10 month period. We've had some additional inputs. I 11 participated in an IAEA workshop on the use of performance 12 indicators which was helpful. 13 In this program, the Staff examined three to four 14 years of data from 23 reactor units, plus a large sample of ~ 15 component level data from these and other units, and we are 16 only able to give you a glimpse of the analysis that we've done 17 to date in this particular meeting. The work is not complete; 18 these are preliminary results that they show promise in 19 assessing maintenance effectiveness. And Tom Novak will 20 explain the diffe,rences between maintenance effectiveness and 21 process and overall performance. So, Tom, I think it's a good 22 time to turn it over to you. 23 MR. NOVA'K: Thank you, Ed. As Ed pointed out, we did 24 visit 13 sites. I think it's important to mention initially 25 that the utilities, each one vai very cooperative. I asked 3

~ - 28 1 each of our teams as they came back how did the trip go, and 2 every time we got the answer that the utilities worked as hard 3 as they could to give us the kind of information that we felt 4 was necessary to develop these indicators. And I think it's a 5 point that we should make very early in our presentation, that 6 they were very supportive of our efforts. 7 Ed mentioned that we did go after a number of 8 different kinds of data. We identified in our previous 9 discussion the kinds of init!.ators that we were looking for and 10 we defined them as process indicators and effectiveness 11 indicators. The report that we provided to you last week has 12 all this informatica in there in a lot of detail, but very 13 briefly, the process indicators are typically those indicators

1. 4 that utility management uses to manage the programs dealing 15 with maintenance.

These are the kinds of information that is 16 routinely provided to INPO and you have seen these in earlier 17 discussions. 18 The other kind of information we were looking for was 19 on component tsilures. We are interested in knowing just what 20 kind of data we could develop from these site visits to better 21 understand equipment history. We would visit the plants and 22 ask for data regarding rework on certain components, how long a 33 particular component may have been out of service and it was 24 that kind of data that wo tried to c,ollect. 25 Now, the report identifies those kinds of information 0 9 _p

e e 8 e' 29 1 and I won't go into it in very much detail today. May I have 2 Slide No. 3, please. 3 (Slide.) 4 What I'm going to just try to do in a few minutes is 5 give you the high spots of our report. AEOD Report S804 was 6 really broken down into three parts. We thought it was very 7 important to get a firsthand knowledge of how utilities today 8 use maintenance performance indicators; whether their processes 9 were effective, and these indicators are what we refer to as 10 overall indicators and that might be plant availability or 11 capacity factor. How are they used in the day-to-day operation 12 of the plant, what kind of distribution of that information is 13 made throughout the utility's corporation. And we did that. 14 And in our final report we will have each of the 15 plants -- we'll have effectively 13 trip reports, and I think 16 this is very valuable information because it's good firsthand 17 information on how utilities use maintenance data in their day-18 to-day activities, and we will have a separate section on that. 19 The report also then will cover and does cover the 20 data that we collected. I mentioned in August that we had 21 brought back all kinds of data, some on floppy disks, some in 22 cardboard boxes. That was true. We've put it into a database 23 and we came up wich over 7000 pieces of data

• rom which to 24 develop correlations to see if in fact process indicators or 25 effectiveness indicators could in fact be correlated to e
• ___________.____n

__._______._.__________....._________..______.______.-m

30 1 something like an overall indicator, like a forced outage rate 2 or a capacity factor. So that was done, and it is contained in 3 the report. 4 Also, we have described for you our validation 5 efforts; how did we proceed with attempting to show if in fact 6 there was a relationship between a candidate indicator and an i overall indicator. That was discussed 8 Lastly, and I think probably the key to where we are 9 going in the future, is our review of the NPRDS database. 10 NPRDS, which is the Nuclear Plant Reliability Database, has 11 been in existence for more than 10 years. It's a very 12 comprehensive database. Roughly there are over 60,000 13 component failures which have been reported to INPO which now 14 monitors and operates this program since its inception. 15 Additionally, there are approximately a half a 16 million engineering records on components, so we look at this 17 as a very robust database with the potential of giving us the 18 kind of data from which.to see if indicators can be caveloped 19 to measure maintenance effectiveness. 20 our final report then will cover all of this and 21 we're expecting to provide this to you in about a month. 22 (Slide.) 23 What we found is that most licensees collect and use 24 process indicators. I have a backup slide which I'll show you 25 in a moment which gives you some feeling for how a utility 4 ^ __._.7___,

31 1 management would use some of these kinds of information. We 2 saw a variety of management tools used to und6rstand 3 maintenance activity at a plant. But we didn't see is anything 4 that specifically monitored maintenance effectiveness. For 5 example, if you went and asked to see any trend on component 6 rework they could not show it to you. We could develop some of 7 that information by going back to their database and sitting a down and saying let's try to develop an understanding of rework 9 on certain components, so it was possible to do it, but as a 10 day-to-day tool that a manager in maintenance might use, he did 11 not have that at his fingertips. 12 They all monitor overall performance. If you go to a 13 plant you'll know the capacity factor, you'll know their 14 availability, you'll know their forced outage rate. ~ 15 Now let me see backup slide No. 4, please. 16 (Slide.) 17 This ic not in your handout but I think it's 18 illustrative of a point that I want to make. What you're 19 seeing here is a process indicator. This is the ratio of 20 preventive to total maintenanca. Basically, this information - 21 - let me first start with a working definition of what this 22 indicator is. The preventive maintenance includes things such 23 as surveillance, the typical things you.would do as part of 24 preventive main'tenance. And then total maintenance is just 25 preventive plus corrective maintenance. Now, these maintenance a

E. .~ 32 1 activities are restricted to those things you do in the non-2 outage condition, so that's important to know as well. 3 Now, what we then have here, and I just put this 4 slide together for illustration, typically if you look at trend 5 charts of preventive to total maintenance of values of 50 or 60 6 percent -- what you have here just for illustration is we have 7 summed up those values so they are cumulative values.. So in 8 two quarters, each quarter being 50 percent, the value would be 9 100 percent on that chart. 10 What you see there are some ranges. For example, 11 industry has a goal of about two-thirds PM to total. If you 12 were doing two-thirds preventive to total, then that's probably 13 a good place to be at. It may not be the optimum yet but it's 14 close to being where you want. Obviously, the lower that ratio 15 is, the more problems you're having with corrective 16 maintenance. 17 Now the thing that'.s interesting here is you can see 18 that that indicator can be managed; you can change the slopes, 19 and there are two indications there -- we're showing three plants'just for an example, and the,two lower curves peu can 20 21 see that somewhere in calendar year '87, about the second 22 quarter, the maintenance activities changed to where a higher 23 amount of preventive maintenance was being done, where they 24 were more successful in reducing the corrective maintenance. 25 Since it's a ratio you don't know exactly which is' changing. p 1

~ \\ l 33 1 But clearly you can see where they're coming back in and 2 running now parallel with more of the optimum or nominal type 3 of performance you would like to see. And I think this is 4 illustrative of how utility management can look at their t 5 performance and can affect changes and see if in fact what 6 they're asking for is being reflected in day-to-day 7 performance. 8 May I have Slide No. 4, please. 9 (Slide.) 10 Data acquisition was the second part of our effort 11 and what I want to mention here very briefly la that in each of 12 the cases that we visited you find very sophisticated plant I? computerized systems for maintenance management. I'm sure this 14 is standard across the country; we work with these systems as ~ ~ 15 best we can. The things that we noticed, though, is that they 16 do work for the kinds of information that maintenance managers use and tha. corporate management want to see. They track e 17 18 basically all the maintenance work activities. You put in the 19 information on each and every maintenance work request and you 20 can call it up and see where it is in the process. 21 We tried to use those kinds of systems when we cou,ld 22 to get equipment history, and in some cases we were successful 23 to some degres. It depends on the flexibility of the software 24' ,and the knowledge of the people who are operating those 25 systems. But in general, you could not get good equipment 9 O [

~ ~ 34 1 histories from these kinds of sy' stems. 2 As I said, there's just a limited amount of on-site 3 equipment failure data available. When we did find it we went 4 to maintenance work requests, operating logs, LCo logs and so 5 forth, so it was only after you really got into the control 6 room and went through some of the operating logs that you could 7 get real firsthand information on equipment performance. 8 (Slide.] 9 We took this data back. As I said, we had about 7000 10 pieces of information. We had a lot more but when we put it 11 into our database and said now we'll start to see if we can %2 correlate any of this information, we had over 7000 pieces of 13 information that could be worked with. What we did -- and I 14 tniuk it's interesting just to take one nore backup slido. ~ 15 Would you show backup slide No. 7, please and leave it on until 16 I ask you to move it. 17 (Slide.) 18 Now bear with me. This slide is in the report; a 19 number of these types of figures are there. I want '.o use this 20 just for illustraticn. This is basically how we did the validation. What you see here is for a plant. We're looking 21 22 at the number of automatic scrams that occurred over a three-23 year period, and then also we're looking at the c.orrective 24 maintenance backlog for that same plant over that same period. 25 Now, this is the way We put our data together: we would sum up

35 1 all the data by quarters so along the X axis you'll see 13 or 2 14 quarters of data. Now the data here, the black solid ones 3 as.the legend suggests are the automatic scrams that were 4 recorded. So in 1985, third quarters, there were two. In '86 5 first quarter there was one and another one following. 6 Now, those pieces of information sere what we called 7 our validation parameter. What we were trying to do through 8 this validation approach was to see if from the candidate 9 maintenance indicators -- and let's assume now and it was 10 assumed that the corrective maintenance backlog was one of our 11 candidate maintenance indicators -- could it predict the number 12 of scrams that you were going to have. So what we did, and we 13 did this for each and every correlation, for each of all our 14 candidate indicators against each of our validation parameters 15 we would show these kinds of curves. 16 So the first thing we did was kind of an engineering 17

analysis, our people would look at each of these figures and 18 try to understand if there was a logic to it; was there a flow 19 to the data as we saw it.

20 The next thing we would do would be a statistical 21 test, and you'll have to bear with me just a little on this. 22 What we were looking for was -- and this would be a good 23 example -- is corrective maintenance backlog a leading 24 indicator. By that we mean, does the amount of corrective 25 maintenance backlog accumulate in advance of a* reactor trip, e

36 1 and can you predict then from looking at your plots of 2 corrective maintenance backlog that eventually you're going to 3 have a reactor trip. 4 What we did then for each of these plots and for each 5 of these tests, we shifted it up to six quarters. So in other 6 words, we would advance the candidate indicator up a year and a 7 half in three-month intervals to see if in fact th'ere is a 8 correlation. And the correlation was -- we picked.75; it just 9 was a low enough threshold that gave us more information to 10 look at. So this example then came out of the statistical 11 test. What this said is if you advance -- in other words, the 12 corrective maintenance backlog was leading the reactor trips by 13 about four quarters. If you shifted it and you make the test, 14 is there a.75 correlation, if it came up yes we got a hit, and 15 then we would get this kind of a printout and look at it and 16 try to understand it one more time. In other words, it was 17 just another screening tool. So the statistical correlation 18 was just another way to loc' at this attempt to see if in fact 19 some of these indicators were leading. 20 So we did all of this, and really what we found was 21 there was no consistency. As hard as we did try to look for 22 this we didn't find any process indicators that gave you an 23 indication of how your validation parameters -- things liko 24 forc~.d outage rates, the reactor trips, -- that you could 25 predict them either in the same timeframe or in advance of it. G 9 b

37 1 I think I've answered -- that was the point I wanted 2 to get at it. There are many of these that will be in the 3 final report; information of that type. 4 Now with regard to the effectiveness indicators -- '5 again, those are the thingo that we went after to understand 6 component failure rates. We went through the same process in 7 looking for them. We found substantively fewer correlations. 8 We just did not find enough information from our databases that 9 we collected to show any correlation between the candidate 10 indicators either process or effective tnat could be correlated 11 to some validation parameters. 12 Now let me have Slide No. 6, please. 13 (Slide.) 14 What we did learn from these site visits was that in 15 a number of cases, the utility would go to NPRDS to give us 16 some of this da'ta. We would sit down and we would call it out 17 and bring it back and look at it. So when we went through all 18 of the data that we had collected through.the site visits, wo 19 decided to' explore NPRDS in more detail. 20 So what we did for the same set of sites, the same 21 plants that we visited, we used NPRDS then. What we did is we 22 constructed a number of indicators, a total of seven, and 23 they're spelled out in the report; four of which were very 24 similar to the same indicators where we went to the plant and 25 tried to collect the information -- for example, rework. We O O e "O e e

38 1 constructed a rework indicator from some definitions you can 2 use in NPRDS. So we went through that and we got a lot more 3 correlations. I would say about a factor of three to four. So 4 ve were encouraged that there was more potential there. 5 Now we also recognized there are certain limitations 6 in NPRDS. We've been following this for several years from 7 Commission directives starting in 1983, so we've been looking 8 at the timeliness, the completeness. We also learned a little 9 bit about the limited scope of equipment, and I'll mention that 10 a little bit later if we have time or if there are any specific 11 questions. But overall we were very encouraged by NPRDS, even 12 as it is presently being used. So we are planning to continue 13 efforts in that area. In the final report we will study some 14 of these additional indicators and we'll report that to you at 15 that time. 16 (Slide.] 17 The conclusions are relatively straightforward. We 18 cdrtainly encourage utility management to use the process 19 indicators; things like PM to total, maintenance, corrective 20 maintenance backlog. The things that they have been doing 21 should be used. We would suggest that they try to get a little 22 better in recording the information. We saw a certain amount 23 of variety bdtween how thorough they are in. reporting this 24 information, but overall we were very encouraged that it is a. 25 very useful tool for mananement. G e o e e ,6

39 1 We're convinced that maintenance effectiveness, the 2 quality of maintenance, can only be really assessed by 'looking 3 at component reliability. That will be your best test and your 4 only test that we see for judging the true quality of 5 maintenance at a plant. We believe that NPRDS has the 4 6 potential certainly of providing the database from which some 7 of these maintenance effectiveness indicators can be developed. 8 And lastly, our recommendations. Slide No. 8, 9 please. 10 (Slide.) 11 Our recommendations -- encourage the utilities to 12 work hard at improving and further development of the process 13 indicators. We saw a wide variety of uses. We would certainly 14 thun also encourage utilities to utilize NPRDS. We find it a 15 valuable tool. Even before we started this effort we had 16 opportunities to look at NPRDS and it has given us insights 17 jnto maintenance quality at the plants. 18 And lastly, we do intend to work in this area and soo 19 if we can be successful in developing effective maintenance .? O indicators. Thank you very much. 21 MR. TAY LOR: That concludes the Staff's presentation 22 -- excuse me.

• MR. JORDAN:

I would like to make an ad'ditional 23 24 comment. The Staff has provided, through the.EDO,'a 25 recommended working change to the rule package, and that only e e O

~ 40 1 came to you this morning, I believe. It does reflect the 2 findings that we've made in terms of encouraging industry use 3 of the process indicators -- I'm sorry, the effectiveness 4 indicators -- in measuring, evaluating the effectiveness of 5 their maintenance programs. So we would be recommending a 6 little stronger words and the use of the NPRDS system by 7 utilities. 8 We also clearly feel that the Staff -hould continue 9 our work with reviewing the potential for effectiveness 10 indicators from the NPRDS data. We feel encouraged with that. 11 MR. TAYLOR: I was going to mention that we just sent 12 that to the Commission so you may not have,had an opportunity 13 to review it, but we did change a few words to reflect the work ~ 14 that has been completed so far. 15 CHAIRMAN ZECH: All right, fine. 16 MR. TAYLOR: Tom, you had something you wanted to 17 add? 18 MR. MURLEY: Yes. In judging this rule, I think a 19 key aspect is going to be the implementation of it, and we 20 probably have some preliminary thoughts that I should mention. 21 This rule, as you know, is not like station blackout or ATWS 22 where you can judge whether a certain piece of hardware has 23 been installed and the rel.iability of it and so forth. It in 24 many ways deals with subjective judgments of effectiveness of 25 programs. So overall, we believe the effectiveness of the rule e

41 1 is going to be closely tied to how the NRC Staff evaluates 2 compliance at each plant. 3 'In the near term, we think there will be no better 4 means for judging compliance than we have done traditionally, 5 and that is by having experienced inspectors go through the 6 plant, look at the history and look at how well maintenance is 7 actually being done. 8 These have traditionally been done, of course, by the 9 regional inspection Staffs and collected in SALP reports. So 10 we think that the SALP evaluations are probably the best 11 indications we have right at the moment of maintenance 12 performance. 13 We've taken that initiative to see if we can collect 14 the experience from the regions and the headquarters Staffs and ~ 15 develop perhaps a better maintenance inspection program. We've 16 conducted three pilot inspections up until now and those are 17 continuing. I'm encouraged to see that these inspections will 18 be, we think,' rore effective tools to evaluate compliance. 19 If you'd like, maybe we could take about two minutes 20 and have Tony Gody, who is our Brsnch Chief in charge of this 21 program, summarize the three pilot inspections that we've done. 22 CHAIRMAN ZECH: Please, let's do that. 23 MR. GODY: We conducted pilot inspections, 24 maintenance team pilot inspections, at Diablo Canyon, Oconee 25 and Peach Bottom. We did those in the late summer. The O e

42 1 reports will be issued ir October. 2 These inspections were six-man team inspections. We 3 have developed a TI, a maintenance inspection guidance package, 4 along with a logic tree to aid as an inspection tool. We've 5 stressed perf'ormance-based inspections and observation of 6 maintenance work in progress was concentrated on. 7 No surprises really came out of the inspection 8 findings. In two of the three pilot inspections they 9 concentrated on balance-of-plant systems and came up with some 10 identified strengths and weaknesses in those areas. 11 Several violations were identified but the important 12 thing,was the identification of these strengths and weaknesses 13 and the evaluation of the licensees' ma'intenance practices. 14 We also have been conducting regular inspections; ~ 15 inspections have been going on at Trojan, Wolf Creek, Davis-16 Besse and Palisados. The regions have already implemented the 17 regular program, and in one case at Trojan they had performed a 18 self-assessment on their maintenance practices over a year ago. 19 The inspection validated sever'l of those findings, identified a 20 a few new ones and even identified some that the licensee had 21 previously identified that had not been dorrected. 22 These inspections will go on for two years, and we 23 intend to take a look at the majority of the plants in the 24 country. 25 MR. MURLEY: As we go along, of course, we're going O e e e e e

43 1 to feed back and see if we can continue to improve the 2 inspection programs. If we conclude that we need to make big 3 changes or stop them for some reason we vill do that, so we're 4 not totally committed to a program other than to keep going. 5 We think it is a good means for assessing maintenance at the 6 plants and we're going to continue improving. 7 MR. TAYLOR: I might add that without a rule, those 8 inspections of course are directed to whatever programs are in 9 effect and commitments that the licensee itself has made in 10 this area, so that's the way the Staff, the inspection force, 11 has traditionally looked at maintenance; that is, whatever 12 commitments and so forth -- 13 CHAIRMAN ZECH: And for the. time being you'll 14 continue in that regard. ~ 15 MR. TAYLOR: Yes, sir. Of course we're continuing. 16 Snort of a new industry standard, were one to be developed, 17 we'll continue to watch it in that fashion. 18 I believe that concludes the Staff presentation at 19 this point, sir. 20 CHAIRMAN ZECH: Thank you very much, appreciate the 21 presentation. Questions from my follow Commissioners. 22 Commissioner Roberts? Comnissioner Carr? 23 COMMISSIONER CARR: Yes, I've got some of the same 24 problems Commissioner Robers= had with "The Commission intends 25 the scope of th~e rule to cover al) systems, structures and e g 9 "O 9 e

44 1 components including those in the balance of plant, 2 commensurate with their importance to safety." I feel that for 3 my purposes I'd put a period after "balance of plant". Who's 4 going to make the judgments as to what is commensurate with? 5 MR. TAYLOR: That's part of the standard. One of the 6 things we hope that the' industry will participate and develop 7 in because as you know, there are a large number of systems 8 described in the FSAR that in some way or other contribute 9 ultimately to safety, and it is -- I think that's one of the 10 reasons the standard we hope will address that. 11 COMMISSIONER CARR: I guess I'm trying to figure out 12 why don't we put a period there and forget about "commensurate 13 with their importance to safety"? What have you lost if you do 14 that? 15 MR. KING: I guess maybe the best example to use to 16 explain that is if one of the attributes of a good standard is 17 to have a root cause faill:re analysis program, there are 18 probably some items in the balance of plant where it wouldn't 19 make sense to go do that. You know, if you use the extreme -- 20 COMMISSIONER CARR: I can't think of any. 21 MR. KING: Well, you might use the extreme of light 22 bulks or some kind of space heating type system. The intent of 23 putting those words "commens' urate with safety" was to try and 24 exclude those kinds of items from having to go through the 25 fullblown engineering analysis that would be required on things e e

) 4.5 1 that do contribute to safety or things that could challenge.a 2 safety system. And again, the standard would have to provide 3 more guidance on how you would make that distinction. That's 4 the reason for the words being in there. 5 MR. TAYLOR: That brings to mind a story that Stello 6 likes to tell about sanitary -- this goes back many years -- 7 about sanitary piping in an imp.ortant space that was 8 inappropriately designed and suddenly became important. But I 9 think the Staff at this point is looking to the industry to 10 help us in that area so the appropriate measures go as far as I 11 think you're concerned. 12 COMMISSIONER CARR: Well, I'm concerned about that 13 and I'm still not easy that I know what's going to happen with 14 it. ~ 15 The second one is on component reliability as a 16 maintenance effectiveness indicator. I think that's a good 17 idea but you've go+, to avoid the trap of having lemons. I mean 18 the're are some components you run across now, men, that you 19 just can't keep running and you have to ultimately make an 20 engineering decision to change it and get rid of that one and 21 buy one that works. So that should turn up in your NPRDS 22 system or in the plant's system somehow, but there is that 23 potential for a possible problem. 24' 'I'm a little uneasy that nowhere in this have we tied 25 the accountability of the maintenance personnel to the work

l 46 1 accomplished, as to whether they are doing good work; 2 otherwise, we're training maintenance personnel. But I think 3 until we get some way of tying the accountability of the guy 4 who did the maintenance, the results of it, we're going to have 5 a hard time improving maintenance. Did you give that any 6 aonsideration? 7 MR. NOVAK: We didn't specifically look to see if we f 3 could establish a link between the worker and his product. 9 This rework was kind of the closest thing we went after; can we 10 see trends where equipment is failing. And then it would be 11 reasonable to go back, -- and through these management systems, 12 they can identify the people, the individuals who are I 13 responsible for that activity. That's recorded and can be 94 recovered. So it would be -- I guess you'd go down ono more 15 layer and see if you could do it. It's there, if you can 16 establish that there's a correlation between the equipment and i 17 the people. 18 COMMISSIONER CARR: I' guess as a final comment I 19 would complAment you on hurrying up and getting this work. We l 20 pushed you hard, I think you've done a good job. I think also 21 the industry has gotten the message; I think they're beginning 22 to do a much better job. I agree with Commissioner Roberts l l, 23 that the trends are in the right direction. But I think we l 24 'have a hard time pi6ning that improvement on maintenance. It I 25 could be training or it could be a lot of other reasons S e

r-47 1 including just industry's attention. 2 COMMISSIONER ROBERTS: But the only reason I pointed 3 that out was the Staff was using scrans as a measure. 4 COMMISSIONER CARR: I think we've got a lot of work 5 .left to do. I agree, I don't sc.e how you could make a case 6 that maintenance is not important to what we're trying to 7 accomplish, so I encourage you to carry on. ( 8 CHAIRMAN ZECH: Thank you very much. Commissioner 9 Rogers? 10 COMMISSIONER ROGERS: Yeah, I've got several 11 comments. First, I think it is very timely to compliment the 12 Staff on all of the work that's been done, the maintenance rule 13 and the examination of performance indicators. 14 With respect to the performance indicators work, I ~ 15 think this is really a first class piece of work. It's an i 16 example of an NRC leadership activity. When we listened to the 17 comments at the workshop that was held, I certainly didn't get 18 the impression that you were going to get an awful l'ot of help J 19 from industry in developing those PI's at that time -- help in 20 terms of supplying data, yes, but in terms of any kind of 21 conviction that anything would come out of the PI business, it 22 didn't sound to me very hopeful or very encouraging. ?3 And I thl'nk,you folks continued to move ahead and did 24 the job. It's not finished yot, but what you've done is' 25 excellent. I'think it's not only commendable; it's really 4 e-,.

48 1 first rate. And it is important that you keep pushing on this 2 to really finish the work that you've done in honing in on 3 possible performance indicators. I think you're absolutely 4 right that you're going to have to go to the component failure 5 area. But whatever it is that you've been doing that shows new 6 encouragement based on the statistical results that are coming 7 out, I feel should be pursued assiduously and complettd and 8 that we really ought to try to make sure that the resources are 9 there to keep that effort up and completed as quickly as 10 possible. 11 So I really want to ompliment you on the first great 12 work that's been done to date. 13 The addition to the rule or additional paragraph that l 14 just hit us the last day or so, this morning maybe even, I 15 think is very impo.etant and it suggests that perhaps the work l 16 that comes out of performance indicators can ultimately be 17 folded into this program as an assessment tool, and I'd like to 18 hear a little bit about your thoughts on that. Because it 19 seems to me that we have the possibility of a longer-range 20 effort here that goes beyond what we've seen so far in just the 21 guidance that comes out of the Pegulatory Guidet that there 22 actually might be some measurables that might help to supply 23 some of the concerns that Commissioner Carr has addressed-in 24 t1rms of accountability. That we do need measurables; this is 25 a difficult area to regulate, and it seems to me that if we can I

v 49 1 come up with performance indicators that the industry accepts 2 and we feel are valid, that provides a reasonable basis for a 3 regulatory action. 4 So that you've writt3n a rule now to include two 5 elements; assess the effectiveness of the maintenance progs-a.1, 6 and based on this assessment make improvements as appropriate. 7 So an assessment should incorporate quantitative measur.' -- I J 8 think that really is addressed in this other paragraph that 9 you've added. .) 10 So do you think that these quantitative measures 11 could be identified in time to actually be built into the final 12 rule? I 13 MR. JORDAN: I would like to answer that, 14 Commissioner Rogers. I think it's more impoitant-for the ~ 15 utilities to have measures of effectiveness and for the NRC to 16 monitor those, so the additional paragraph was aimed at urging 17 industry to collect and use data component failure type data in

l 19 their assessment program.

And I would say incidentally that 19

• he NRC would then monitor appropriate measures.

20 But I personally don't believe that we would have ,21 indicators that we would recommend putting into a rule..Even i 22 though ve feel there's great promise in indicators, I also 23 believ'e that indicators change with time, and the illustration 24 I would give is that if the Japanese applied -- and they've 25 tried -- the U.S. pe'rformance indicators to their plants, it (

~ ) ~ 50 1 doesn't work because they have zeros and ones, and there's 2 absolutely no value to our data or our system applied to their 3 plants. i 4 So I think we have to look at flexible assessment 5 methods that change with the time, and to put it into a rule 6 I'm afraid would be locking it forever or until a rule change 7 many years later. So thst's an opinion on my part,but it's 8 based on what we've done so far and what internationally we've 9 seen in the way of data 10 COMMISSIONER ROGERS: Well, do you think they would 11 be available to at least be included as suggested elements of a 12 Regulatory Guide when -- 13 MR. JORDAN: Vas. sir. The indicators that we've 14 found to be most valuable out of the study, we would certainly 15 propose for NRC use and urge industry to adopt them to the 16 extent practical. 17 COMMISSIONER ROGERS: Just turning to the rule itself 18 where it's constructed'with the expectation that there will be 19 industry participat!on in the development of a standard, I'd 20 really like to know just how much you know about the likelihood 21 that that will be forthcoming. It's a rather short time that's 22 provided in the schedule for this standard to be developed, and 23 I just wonder to what extent industry, whatever that means, 24 that means soo'ebody outs,ide NRC, I guess -- is ready to step 25 forward and take this on. Have you identified a utility group e e e

1 51 1 such as INPO, NUMARC or EPRI, that has expressed ar / positive 2 response to this expectation on our part that there would be 3 industry stepping forward to help with this? 4 MR. TAYLOR: Commissioner Rogers, I don't believe I'm 5 in a position to say that that is an assured point right now. 6 Tom mentioned that the Staff intends to proceed on its own. We 7 are hoping to get that. My Byron Lee I believe is in the 8 audience from NUMARC and perhaps he would care to comment on 9 that. We are hopeful this will happen. In fact, we'd like 10 that very much, to get the knowledge of the industry. 11 CHAIRMAN ZECH: Mr. Lee, would you care to comment? 12 Please step to the microphone if you would, please. 1J MR. TAYLOR: He didn't know this was going to happen. 14 MR. LEE: Yes, sir. My name is Byron Lee, Jr., I'm 35 the President of NUMARC, the Nuclear Management and Resource 16 Council. 17 I think that, as you are all well aware, we've said 18 it many times, the industry position is, and has not changed, 19 that we think a rule at this point is premature. And I guest 20 nothing I've heard today changes my mind in that regard. It 21 seems to me there are still a lot of open issues, 22 uncertainties. There are a lot of ideas on things that we need 23 to uo over and above what we're doing. I've not heard much 24 that says specifically we've got maior holes or problems in our 25 area. O e e 9

s 52 1 I think that we need to work on that. We have pledged to work together with the NRC. The question becomes 3 one of do we presume a rule is passed and then will we work on 4 a standard? I guess that's really the question that's being i 5 asked. I think we,,again, have said obviously, we want to try 6 and make Whatever is done the best for the industry and the 7 best for the whole process, the whole regulatory nuclear 8 program in this country. But as I said, I think we feel the 9 timing is not right. 10 We have talked about certification as one of the 11 suggestions that was made at one point in time. I think that 12 industry's position on that is very clear; that certification 13 by INPO of maintenance programs under a rul; would not be 1 14 consistent with their policy. We believe that just puts us -l i i 15 into the regulatory process which we don't think is our role. 16 CHAIRMAN ZECH: Thank you very much. 17 COMMISSIONER ROGERS: Well, I take it that you have a i i 18 fallback position if industry participation at a suitable level 19 of effort is not forthcoming, and that is for NRC to proceed to 20 do it itself. I would hope that we could have industry 21 participation in the development of a standard; that in fact 22 the philosophy that's been expressed here; nam 61y, that this is 23 a rule which is somewhat different from other rules we've dealt l l 24 with in the past and one which has the intent of not l 25 interfering with good maintenance

• programs but encouraging the

53 1 experience of good maintenance programs to be transmitted more 2 cross the industry, would in fact be an outcome. I personally 3 feel that is a very laudable objective and an achievable one. 4 With respect to this third party designation to 5 review and certify licensee maintenance programs for 6 conformance with the maintenance standard, just what do you 7 have in mind there'as a third party? Are you talking about an 8 industry group or a contractor, that type of organization? 9 MR. TAYLOR: We would have preferred an industry 10 group to do this because of the depth of experience in 11 industry. Tom, do you want to add to that? 12 MR. KING: That's true, we would prefer an industry 13 group. That's what we had in mind when we put the statements 14 in the Notice of Proposed Rulemaking to see if there was any ~ I 15 interest out there and to solicit proposals on how this would 16 work. We have no preconceived ideas as to how it would work at 17 this point: we're putting the question on the table. 18 COMMISSIONER ROGERS: Thank you very much. 19 CHAIRMAN ZECH: Let me just say first of all, I l 20 disagree with Mr. Lee's conclusion that it's premature for a 21 rule. I think, frankly, it's long overdue, that's my personal I 22 opinion. I don't think anybody would disagree that maintenance [ l 23 is very important. Certainly it's important in my judgment to 24 goo'd performance, and good performanco in my view relates y t 25 directly to reliability and to safety. It also relates to e ~ s r- --~-w

54 1 economic performance in that plants that are well maintained 2 and and up with a higher capacity factor and less challenges to 3 the safety systems certainly are the plants that we would judge 4 to be safe and reliable and economic. And as I've said before, 5 I think they all go together. 6 But it's clear that a maintenance program, I believe, 7 and maintenance perhaps has not been given -- at least again to 8 my judgment -- the priority * :at it should have over the years. 9 I'm convinced that maintenance has a very direct relation to 10 safety of operations and to reliability, as well as to economic 11 considerations. 12 Again, if I were a utility executive, I would think 13 that perhaps putting more resourcen into maintenance would 14 allow me to operate my plant with a higher capacity factor, 15 again contributing to better performance and again, directly to 16 safely, more reliable operations, as well as a ain, more v 17 economic operations. That's the vay I look at it. So I 18 disagree that it's premature to focus on maintenance as we're 19 trying to do. ~ 20 I would like t,o extend my very sincere 21 congratulat, ions to the Staff for a real team work effort in I 22 this regard. We've heard this morning from Research, from NRR, 23 from AEOD. I think we've' heard some very fine analysis, a lot 24 of hard work has gone into this program. I think Mr. Ning's 25 presentation, as well as Mr. Novak's an'd others, the NRR ~ ~

55 1 presentation also, show a very responsib'le action on the part 2 of the Staff. 3 I'd like to point out specifically the AEOD's part of -4 this presentation, and how difficult of course we all know it 5 is to come up with performance indicators and we're still 6 struggling, but I think we are making progress. I certainly 7 agree with the conclusions you've come up with. But I'd like 8 to command AEOD on taking on a very, very big challengo and 9 moving as far as you have, and to encourage you to continue the 10 efforts that you're undertaking. Just because it's a difficult 11 task that doesn't mean we should stop short of the goal of 12 trying to move ahead, and I commend the AEOD in particular for 13 the efforts that you've made. 14 It is difficult; we're kind of plowing new ground in But again, in my view maintenance is an area that is 15 a sense. 16 clearly in need of improvement and can help us with our public 17 health and safety responsibilities in particular, as well as 18 help the industry with regard to performance of their plants. 19 Let me just say this, too, I think it's a leadership 20 role that NRC is maintaining. 'We're trying to raise the 21 priority, trying to raise'the awareness of the importance of 22 maintenance. It's not as exciting a subject as operations, but 23 it clearly is a big part of operations in my judgment. So for 24 the afforts on the part of the Staff and the leadership role l 25 you're undertaking, I commend you for that.

I 56 1 I think its encouraging the trips you've made and 2 the interface you've had with the field at least, with the 3 utilities, that they have been cooperative and willing to work 4 with you. I think that's very encouraging. And so I would 5 just note that the schedule you've put forward as a result of 6 the Commission's encouragement is an ambitious one but it would 7 look to me like it thould be a reasonable one. 8 I'd like to encourage my fellow Commissioners to give 9 this important matter their attention, and after due 10 deliberation to act in responsa to the Staff's request for a 11 Commission decision regarding the Staff's proposed schedule. 12 And I would just conclude by saying again to the Staff, well 13 done; a very important job. We're moving, in my judgment, in 14 the right direction. I commend you for that. 15 Are there any questions from my fellow Commissioners? 16 (No response.) 17 If not, thank you very much for an excellent 18 presentation. Wa stand adjourned. 19 (Whereupon, at 11:35 a.m., the Commission meeting was 20 adjourned.) 21 22 1 23 24 25 G J-______ _ - _1- _ _

CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled: TITLE OF MEETING: BRIEFING *0N PROPOSED RULE FOR MAINTENANCE OF NUCLEAR POWER PLANTS PLACE OF MEETING: Washington, D.C. DATE OF MEETING: FRIDAY, OCTOBER 14, 1988 l were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and I accurate record of the foregoing events, a \\_ r V f\\ & M l / 9' n y i i Ann Riley & Associates, Ltd. e 4

- -vc..aon oynov9.n.~. s COMMISSION BRIEFING ON THE PF.0 POSED RULEMAKING ON MAlhTENANCE OF NUCLEAR POWER PLANTS T. L. KING OFFICE OF RESEARCH OCTOBER 14, 1988 S e e e

--na ...<.,--i 4 r i OUTLINE OF PRESENTATION

SUMMARY

OF WORK DONE LEADING TO NPR l

• SUPPORTING DOCUMEtiTATION DEVELOPED

[

• CONCLUSION AND RECOMMENDATION

SUMMARY

OF PROPOSED RULEM'AKING I j

• COMMENTS ON ACRS VIEWS I
• SCHEDULE AND IMPLEMENTATION Or FINAL RUtt d

C0t. TENTS OF NPR PACKAGE I + i i I t t r l [ l i I i i

m. 4 i

SUMMARY

OF WORK DONE LEADING To NPR SUEMIT FED STAFF PLAN AND SCHEDULE IN SECY 88-142 (5/23/88) TRANEftlTTED RULEl4AKING OPTIONS PAPER ON JUNE 27, 1988

• CONDUCTED PUstic WORKSHOP (JULY 11-13, 1988)

REVIEWED FOREIGN COUllTRY AND OTHER U.S. INDUSTRY MAINTENANCE PRACTICES NPR REFLECTS RESULTS OF ABOVE TASKS e 4 9 9 8 9 e 4 9 S e g 7. L

s h I V l t t SUPPORTING DocVMENTATION DEVELOPED NUREG/CP-0099 "PROCEEDINGS OF WORKSHOP" l DRAFT NUREG-1333 "MAINTENANCE APPROACHES AND PRACTICES IN SELECTED i 1 t f0RElGN NUCLEAR POWER I -i FAGGRAMS AND OTHER V.S. l INDUSTRIES: REVIEW AND f LESSONS LEARNED" i i } t I l i I 1 i f i-j l l 3 ~

v- -o-v-- v-. o-e,- . oy ,o o CONSULTANT REPORT "0BSERVATIONS AND RECOMMENDATIONS ON THE PROPOSED RULEMAKINC FOR THE MAINTENANCE OF NUCLEAR POWER PLANTS" - DR. K. INABA, XYZYX CORP. 9 9 l l f

_.,,,,..,,,, m,,, y, ,7.,,,, .y,,.,,,- 4 n. CONCLUSION AND RECOMMENDATION THE STAFF REC 0KMENDS THAT THE COMMISSION PROCEED WITH A GENERAL RULE WHICH: - SPECIFIES THOSE ATTRIBUTES IN THE POLICY STATEMENT WHICH THE COMMISSION CONSIDERS. ESSENTIAL FOR AN EFFECTIVE MAINTENANCE PROGRAM AND - PROMOTES INDUSTRY RESPONSIBILITY FCR CEFINING, MON!TORING AhD IMPROVING ~ MAINTENANCE PROGRAMS. b-9 e 4 6

... _ - - - - - - -. - +. - - -.....ar....-.-...-.. .u..,........, a.--.1..v

SUMMARY

'0F PROPOSED RULEMAKING APPROACH GENERAL RULE (10CFR50.65) REQUIRING LICENSEES HAVE A DOCUMENTED MAINTENANCE PROGRAM ADDRESSING ALL ACTIVITIES LISTED !!; THE POLICY STATEMENT REQUIREMENTS WOULD APPLY TO ALL SYSTEMS, STRUCTURES AND COMPONENTS COMMEhSURATE WITH THEIR SACETY EIGNIFICANCE G G e O 9 6 n

,m. ,,,,,,,,,xo, 0. r 9 9 I i I l a RULE INCLUDES REQUIREMENT FOR LICENSEES l TO ASSESS PROGRAM EFFECTIVENESS AND ( MAKE IMPROVEMENTS, WHERE WARRANTED, i l ALTHOUGH REPORTING OF PERFORMANCE l INDICATORS IS NOT REQUIRED. ENCOURAGES INDUSTRY T0 DEVELOP A i STANDARD WHICH WOULD DEFINE AN [ ACCEPTABLE WAY TO MEET THE 8tULE. NRC COULD THEN ENDORSE THE STANDARD IN A REGULATORY GUIDE. r i i I e O 8 y

• g g' =

e.,* e -* r *

• f,* * *. * * *
• se.* * *
• g.

.s e, e g-e e;,,, ,=,.., COMPLIANCE DETERMINED BY AUDIT AND INSPECT 10tl. SOLICITS PROPOSALS FOR THIRD PARTY CERTIFICAT!0h 0F PLANT MAINTENANCE PROGRAMS. 4 b o O h 9 4 V 9 e 8

y .e--- t COMMENT ON ACRS Views ACRS LETTER OF SEPT. 13, 1988: - h0T CLEAR THAT MAINTENAl,'CE RULE WILL REDUCE RISK. - CONCERffED THAT IT MAY CETRACT FROM GOOD MAlliTENANCE AT SOME PLAfiTS e e e S 4 e 9

• STAFF COMMENTS:

- RULE WILL REQUIRE LICENSEE MAlfJTENAf4CE PROGRAMS INCLUDE THOSE ATTRIBUTES DETERMINED BY EXPERIENCE AND JUDGMENT TO CONTRIBUTE TO EFFECTIVE MAINTENANCE i l l l 10

.... oo ...e ..... 0,.... 4 STAFF'S REGULATORY ANALYSIS COMBINED WITH QUALITATIVE JUDGMENT INDICATE REDUCTION IN RISK FROM !.MPLEMENTATION OF RULE NOT DIRECTED SOLELY TOWARD TODAY'S POOR PERFORMERS; PERFORMANCE CHANGES OVER TIME AND RULE WILL HELP ENSURF. CONS 1 STENT PERFORMANCE 9 4 b i l i ) I = 11

m-v,, u.; -.. -. j i INDUSTRY HAS AN OPPORTUNITY TO PROPOSE A STANDARD WHICH WILL NOT DETRACT FROM THElR INITIATIVES OR FROM GOOD MAINTENANCE PROGRAMS. ~ m e 9 e 12 e - - = -

.,..e , e o o.,6........c, y.- ;7. -..-- i SCHEDULE FOR I(ULE

• PUBLISH FOR COMMENT - 11/1/88
• Et4D OF CCPMEf4T PERIOD - 1/1/89
• F1,4AL RULE TO COMMISSIOri - 4/1/89
• Fit 4AL RULE APPROVED - 5/1/89 e

13 l

..3..... IMPLEMENTATION.CF RULE RULE REQUIRES FULL IMPLEMENTATION 2 YEARS AFTER APPROVAL. LiciNSEESTODEVELOPIMPLEMENTATION PLAN WITHIN 90 DAYS AFTER APPROVAL. e .g g4

3 REG, GUIDE ENDORSING INDUSTRY STANDARD AND/OR PROVIDING NRC GUIDANCE TO BE Is5UED BY 4/1/90, INDUSTRY STANDARD NEEDED BY 9/89, I t e g e e 15

b i CONTENTS OF NPR PACKAQE SUPPLEMENTARY INFORMATION - ATTRIBUTES OF AN ACCEPTABLE STD. i - ADDITIONAL ITEMS FOR CONSIDERATION . COMMENTS REQUESTED REGULATORY /BACKFIT ANALYSIS I I e -l m

j, y l I l i l ATTRIBUTES OF AN ACCEPTABLE j ',*e>N L;1AfCE STANDARD i l

• SkOULD DEFINE THE PLANT SYSTEMS, STRUCTURES AND COMPONENTS INCLUDED IN l

THE MAINTENANCE PROGRAM { SHOULD RE0VIRE A SYSTEMATIC EVALVATION ("SYSTEMS APPROACH") 0F THE FUNCTIONS AND CBJECTIVES OF PLAliT SYSTEMS, COMPONENTS AND STRUCTURES TO DETERMINE I i MAINTENANCE ACTIVITIES AND REQUIREMENTSJ e e e 9 17

e eo o0-ee.o, -.o m -a, 4 o e. o.., 4.0,... ....o. SHOULD PROVIDE CLEAR AND SPECIFIC PROGRAMMATIC REQUIREMENTS THAT CAN BE PRACTICALLY IMPLEMENTED SHOULD BE COMPREHEKS!VE IN ADDRESSING THE ACTIVITIES AND FUNCTIONS lhCLUDED IN THE PROPOSED RULE PLUS lhCORPORATE PROVISION FOR SELF ASSESSMENT) SHOULD REFERENCE STANDARDS OR GUIDEL!hES SUCH AS THOSE DEVELCPED BY ANS, ASME, IEEE, ASit',, INP0 OR EPRI, hHERE PRACTICAL i = l r -a. 9

... x.,,:. s, ~i.- .(. /

• SHOULD ALLON FLEXIBill'iY FOR ADOPTION OF NEW INNOVATIVE TECHNOLOGIES A5 THEY ARE VALIDATED! AND
• SHOULD PROVIDE FOR-SUFFICIENT DOCUMENTATION S0 THAT PROGRAM EFFECTIVENESS AND COMPLIANCE WITH REQUIREMENTS OF THE STANDARD CAN BE EVALUATED S

e a 6 o 19 q

-- ' - r. --

n. 3 I

ADDIT 10flAL ITEMS TO BE CONSIDERED IN MAINTENANCE STANDARD BASED PRIMAR!LY UPON REVIEW OF FOREIGN / DOMESTIC MAlhTENANCE PRACTICES.

1. FOCUS ON LONG TERM MAINTENANCE OBJECTIVES; ESTABLISH A PROACTIVE-MAINTENANCE PROGRAM AS OPPOSED TO REACTIVE MAINTENANCE;

2. USE OF A RELIABILITY CENTERFD APPROACH TO MAlhTENANCE, INC. UDING CONSIDERATION OF THE MAN-MACHINE INTERFACE; O

e 4 e 6 4 to

,..,.,..,., ' ~.,, s . ' -,...g....J. f, e e t +

3. COLLECTION AND ENGINEERING EVAll)ATION OF FAILURE DATA (ROOT CAUSE ANALYSIS);

4. USE OF Ah INTEGRATED INFORMATION

~ SYSTEM FOR COLLECTitiG DATA AND MONITORING THE EFFECTIVENESS OF A MAINTENANCE PROGRAM;

5. USE OF MAINTEhAllCE TECHNICI AN TRAINING / CERTIFICATION PROGRAMS;

6. DERIVE PLANNING AND SCHEDULING FROM OVERALL PROGRAM OBJECTIVES; 6

o e e O e 21

p f

7. ENHANCE ENVIRONMENT / MOTIVATION OF MAINTENANCE TECHNICIANS (E.G., THRU CROSS-TRAINING, "CREW CHIEF" CONCEPT);

AND

8. CLEARLY DEFINE INTERFACES BETWEEN MAINTENANCE AND OTHER ACTIVITIES (ENGINEERING S'.'PPORT, OPERATIOLS, OA, OC, CORPORATE OFFICES, SAFETY REVIEW).

9. EFFECTIVE MAINTENANCE PRACTICES DERIVED FROM PLANT AGING STUDIES.

t I i 6 e i g i .y t

_ _ _ ~. ~. m. v. ,........., g i e i COMMENTS REQUESTED IN NPR IS IT APPROPRIATE FCR THE NUCLEAR POWER INDUSTRY TO DEVELOP A MAINTENANCE STANDARD AND, IF SO, WOULD THE INDUSTRY DEVELOP SUCH'A. MAINTENANCE STANDARD? WHAT LEVEL OF DETAll SHOULD BE .i INCLUDED IN THE MAINTENANCE STANDARD? IS TWO YEARS A REASONABLE TIME TO DEVELOP, AND IMPLEMENT A STANDARD? i l t I ~ 23

6. e .e_ u... u, .e.e...- m,. i IS IT APPROPRIATE FOR A DESIGNATED THIRD PARTY TO CERTIFY PLANT MAINTENANCE PROGRAMS COMPLY WITH THE MAINTENANCE STANDARDJ AND, IF SO, WOULD AN ORGANIZATION BE WILLING TO PERFORM SUCH CERTIFICATION? SHOULD REPORTING OF MPIS DE INCLUDED IN THE RULE AND, IF So, WHAT SHOULD l THEY BE? r d l i i L 1 c I 24

t o.

SUMMARY

OF REGULATORY /BACKFIT ANALYSIS

• MAINTENANCE RLILE HAS POSITIVE NET BENEFIT
• SUBSTANTIAL REDUCTION'!N PUBLIC RISK NET REDUCTION IN OCCUPATIONAL EXPOSURE INCREASED COSTS FOR PREVENTIVE MAINTENANCE, TRENDING AND FAILURE ANALYSIS, IMPROVED PROCEDURES, ETC.

SUBSTANTIAL COST SAVINGS FROM REDUCED DOWNTIME, REDUCED CORRECTIVE MAINTENANCE 4 e e ~ 25 e 9

t ~. PREUMINARY RESULTS OF THE TRIAL. PROGRAM ON MAINTENANCE , PERFORMANCE INDICATORS I OCTOBE9 14,1988 i l l 1 1 I l

BACKGROUND o COMMISS!0N REQUEST TO EXPEDi1E 1Rl/4. PROGRAM TO DEVELOP & VAUDATE MAINTENANCE Pi AND TO PROVIDE RESULTS ALONG WITH PROPOSED rut.E o STAFF CONOUCTED 13 SITE VISITS (23 UNITS) TO OBTAIN OATA FOR 13 CANDIDATE INDICATORS o CONTINUED DISCVSSIONS WITH INPO ON CEVELOPMENT OF MAINTENANCE PI o FOUR STAFF YEARS PLUS fail 0N/4. LM, RES SUPPORT OVER 3 MONTHS 2 4 e 0 1 I

.s n a .~)' r I AE0D REPORT AE0D/S804 FOCUSED ON 3 AREAS o CURRENT INDUSTRY PRACTICE HOW MAINTENANCE PERFORMANCE INDICATORS ARE USED o DATA ACQUISITION, ANALYSIS & VAUDATION RESULTS o CAPAEllTY OF NPRDS TO PROVIDE DATABASE FOR ~ MAINTENANCE EFFECTIVENESS INDICATORS 6 3 6 e e e g e 4 e o 9-

= CURRENT INDUSTRY PRACTTE o u0ST UCENSEES COLLECT #10 USE MAINTEN#JCE PROCESS INDICATORS (e.g. RATIO 0F PREVENTP,E TO TOTAL LWNTENANCE) o NO Pt.#1T SPECIRC PROGRAuS WERE FOUND THAT MONITORED DIRECT INDICATORS OF MAINTENANCE EFFECTNENESS (e.g. REWORK) o UCENSEES 00 WONITOR ONERALL PIANT PERFORVN4CE TO EVALUATE LWNTEtWJCE EFFECTNENESS (e.g. FORCED OUTAGE PATE) m 9 e e e e o "o e e

e DATA AC0 VISIT 10N o PlwT COMPUTERl2E0 SYSTDJS PROM 0E C000 MNNTENANCE MANAGEMENT INFORMATION AND PROMOE DATA FOR PROCESS INDICATORS NOT DESIGNE0 TO PROVIDE C0uPONENT FNLURES OR EQUIPMENT HISTORIES NECESSAW TO SUPPORT MNNTEN#4CE EffECTP4 NESS INDICATORS o UMITED ON SITE EQUIPMENT FAILURE DATA AVAILABLE FROM MAINTENANCE WW REQUESTS AND OPEPhlNG LOGS ~ e 4 e 4 O G 9 e o e e A g

DATA ANALYSIS /VAUDATION o NO CONSISTENT RESULT WAS FOUND ACROSS PLANTS FOR ANY SINGLE MAINTENANCE PROCESS INDICATOR o LIMITED DATA FOR EFFECTIVENESS INDICATORS Y!ELDED FEW RESULTS AND NO CONSISTENT CORRELATIONS 5 e e 8 9 -___-r aA m g

APPUCATION OF NPRDS AS A DATA BASE FOR MAJNTENANCE EFFECTf4 NESS INDICATORS o NPRDS DATA APPEARS CAPABLE OF SUPPORTING MEAfMGFU. MAINTENANCE EFFECD'ENESS INDICATORS o CERTAIN ASPECTS Cf NPROS COULD UMIT ITS USEFULNESS. THESE INCLUDE: TNEt.' NESS OF REPORTING COMPLETENESS UulTED SCOPE OF EQU:PVEl# 9 6 O 9 4 s 9

l \\ ' C0ftLUS10NS o PROCESS INDICATORS MVE WERfT AS PLR47 SPECfl0 MAPMCEMENT TOOLS o INOCATORS THAT AR[ BASED ON ACTUAL CCMPONENT tlli@UTY PROVIDE BEST MEASURE OF MAINTENANCE EFFECTIVENESS o USE OF NPRDS PROV10ES REAS0tMBli AND ENC 0URAGiNG RESULTS AS A DATA 8/SE FOR DEVELOPING MAINTENANCE EFFECTIVENESS INDICATORS 9 7 O G m o G 4 4 O g

~, .O I REC 0uuENDATIONS o ENC 0VRACE UCENSEES 1G IMPROVE THEIR USE Of PROCESS IN0lCATORS o UCENSEES SHOULD BE ENCOURAGED TO UiluZE INDUSTRY WIDE CCMPONENT FAltuRE. DATA BASE. e.g. NPRDS o STAFF SHOULD CONTINUE TO DEVEl.0P M0 VAUDATE MAINTENANCE Ef FECTIVENESS INDICATORS US;NG NPRDS 9 8 G V 9 4 e a e 4 e 9 4

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M-%%%%%%%%%%%%%%%%%%%%%%%%)t(fd%%:g(fffW4r ggggpfrgt;pgtg g Document Control Desk, 016 Phillips TRAMSMITTAL TO: f f j ADVANCE 0 COPY TO: The Public Document Roem i /e//P/f! DATE: _5 / / j FROM: SECY Correspondence & Records Branch f 2 Attached are copies of a Comission meeting transcript and related mecting i document (s). They are being forwarded for entry on the Daily Accession List and 1 placement in the Public Document Room. No other distribution is requested or j required. Meeting

Title:

dta b a_ N kWJAM /Nu.C b ";?bseb+ W kb v Meeting Date: /e4//ff Open X Closed i J li Item Description *: Copies Advanced DCS '8 ll to POR C3 l l [i

1. TRANSCRIPT 1

1 b) / t wAws1 & / !? / v ) ![! f 2. 12 S! 3. 2: t 4. 5. 6.

• POR is advanced one copy of each document, two of each SECY paper.

a C&R Branch files tne original transcript, with attacheents, withcut SEC" pf0" papers. 3]M l l l l l I Il Ifll l lflNU}}