ML20206B154
| ML20206B154 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2586, NUDOCS 8811150354 | |
| Download: ML20206B154 (18) | |
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^i CERTIFIED COPY DATE ISSUED: July 11, 1988
SUMMARY
/ MINUTES ACRS MAINTENANCE SUBCOMMITTEE MEETING JUNE 15, 1988 WASHINGTON, D.C.
I The ACRS Maintenance Subcoccittee met at 8:30 a.m., Room 1046, 1717 H Street NW., Washington, D.C. on June 15, 1988. The purpose of the meeting was to be brit'ed by the NRC Staff in Maintenance initiatives and rulemaking options. Mr. Car jle Michelson was the Chairman of the subcomittee and Mr. Charles Wylie attended as a member. Mr. Heman Alderman was the Cognizant ACRS Staff Member for the meeting.
Attached are the tentative schedule for the meeting, the Federal Regis-l ter Notice, a list of attendees, and a list of the handouts. The handouts are filed with the office copy.
I Introductory Remarks Mr. Michelson noted the purpose of the reeting was a briefing by the NRC Staff.
He remarked that he didn't anticipate any subcomittee response to the treeting.
He stated that the next Maintenance n.eeting is I
tentatively scheduled for September 15, 1988. He noted that the subcom-mittee anticipates seeing a draft of the proposed rule at that tiene and i
having a discussion of the proposed rule during the October 1988 full l
Cce ittee reeting.
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.I Minutes / Maintenance Subconnitt:e 2
Peeting, June 15, 1988 j
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Moni Dey Project Manager. Maintens ice Rule Task l
He noted that the purpose of the presentation was to inform the subcom-l mittee of the staff's plans, schedule, orogress and some of the options being considered in the development of the rule. He noted that no
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f letter or action is required at this time. Mr. Dey remarked that the Comission has directed the staff to consult with interested persons including industry representatives and to consider maintenance approach-I es in other industries where reliability of equiprint plays a key role.
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i He also noted that the Commissisn has directed the staff to hold a public workshop to solicit early feedback and input from the public and regulated industry on the proposed rulemaking options and approach.
Mr. Dey discussed why rules king is desired.
He stated that the Commis-sion believes that safety can be enhanced by improving the effectiveness of maintenance programs. This is based uren a limited examination of licensee m intenance progru s and events which indicate a wide variation in the effectiveness of m intenance programs in plants.
In order to review industry initiatives the s'eff has had meetings with INPO, EPRI and NUMARC on industry initiatives in the m intenance area.
The staff is reviewing Standards comittee initiatives in the various professional societies and determining what is being done in terms of developing m intenance standards.
Minutes / Maintenance Subcomittee 3
Meeting, June 15, 1988 Hr. Jankovich pointed out that ASME has a number of standards. He noted that they are sm il in scope and are adhessed to servicing and main-taining specific systems and sub-systems and equipment.
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Mr. Dey noted that thPO is developing maintenance guidelines which they see as forming the basis of a standard which the industry is following.
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Mr. Dey stated that the staff has been infonnally directed by the i
Comission as to the preferred option the Comission would want to j
follow in the maintenance rulemaking effort. The plan is to go into the
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workshop with a nur.ber of options but indicate the preferred option and solicit feedback at the workshop on that particular preferred option.
Pr. Walter Scott. Battelle Pacific Northwest Laboratories 1
l Mr. Scott noted that the transcripts will be taken at the workshops. He noted that minutes will be taken and would be available in about a month. Battelle will propere a NUREG and this will be available by September 30th.
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Mr. Dey noted some of the key questions that they are lookirg for input 1
frort the public on the maintenance rule.
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o Should the rule be proscriptive or general?
o Should it standardize nintenance practices?
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Should it be based solely on perfonnance indicators?
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What defines a good mainterance program?
Minutes / Maintenance Subcomittee 4
Meeting, June 15, 1988 o
What industry standards are available for defining such a l
program?
o How should the effectiveness of that program be monitored" Mr. Michelson asked about perticipation of the regions in the workshop sessions. Mr. Dey responded that the regions wilt participate in the workshops. Mr. King added that they have particular individuals at each l
region identified as the points of contact to work with on the mainte-nance rule.
Mr. Dey mentioned categories under maintenance:
performance of mainte-nance, which includes preventive, corrective, end post-maintensnce testing aethities, planning of maintenance activities; measures as i
indicators of overall program effectiveness 6 comunications including l
corrnunications between maintenance and plant operations and comunica-tions between plant and corporate canagement.
l Jan Otton Battelle Huran Affairs Research Center Mr. Olson noted that he would discuss foreign experiance in maintenance regulatten and erperience. Mr. Olson pointed out that in the cases of France and Japan over the last decade, there has been consistent pro-gress in the minimization of forced and schedule cutages. He noted that the U.S. experience has not been as consistent in the direction of improvesent.
Minutes / Maintenance Subconcittee 5
Meeting. June 15, 1988 l
Mr. Wylie asked about the German experience. Mr. Olson replied that their forced outage rate was pretty low.
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l Mr. Olson discussed the regulatory approaches of Japan, France and the Federal Republic of Germany. Forced outage rates, significant events, f
and scrams appear *o be under control. Japan has a very prescriptive maintenance approach to maintenance. France's approach stressed predic-i live maintenance. The Federal Repubite of German (FRG) has a mectum level of prescriptiveness that comes from private or quasi public I
bodies.
FRG has a high emphasis on corrective maintenance. All three programs have at least a ten-year history of an aggressive attempt to irprove the basic reliability of coeponents.
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The overall reliability of components has been improved. There is a high level attentien to planning of maintenance. There is an emphasis on cocrdination with other plant functions. There is management support for naintenance, f
I Fr. Michelsen asked about preoperational testing of a plant. He asktd I
if that would bi part of the maintenance policy.
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'ch replied that pre-operational testing is not specifically inclu.
st is irplicitely included.
Mr. Michelson asked if there are any technical specifications, in the United States, that state on any periodic basis that yr.u rust do a certuin maintenance. Mr. Jankovich said definitely not. That is the t
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Minutes / Maintenance Subcormiitte]
6 Meeting, June 15, 1988 Japanest, approach, Mr. Jankovich noted that the Germans don't have that in their technical specifications either.
It is in their maintenance plan.
The Japanese raintenance program emphasizes systematic preventive maintenance. There is an effort underway to reduce the scope of preven-tive maintenance providing that it doesn't reduce safety. The success of the Japanese maintenance program depends on the consensus between the utility and the regulators and the long tem relationships involved.
The French have developed very detailed predictive maintenance programs with some elements of preventive maittenance. The French programs have flexibility to adopt to situations that develop. Since France has basically one utility there is a high degree of centralization and standardization. The centralization and standardization results in a high level of learning fron operating experience. This 1150 is shown in improved components design and ranufacturing leading to fewer mainte-nance and operational problems. Other benefits are: centralized support activities, centralized training, developtrent of specialized tools and centralized spare parts.
Mr. Olson discussed the Gerran maintenance system. Gemans technical i
specificctions appear to be similar to those of the U.S.
The role of the German Federal Government is expected to be more fomalized in the regulation of nuclear rower.
The German maintenance philosophy intends i
to place a great emphasis on corrective raintenance about 40 to 50 percent of all maintenance in corrective raintenance.
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l Minutes / Maintenance Subconsaittee 7
M:2 ting, Jun) 15, 1988 Alan Chokie. Battelle Human Affairs Research Center. Seattle l
I Mr. Chokie discussed FAA's role in the regulatiori of the Civil Aviation Naintenance Progran. The reason for the review of FAA's rose in mainte-nance is that both the NRC and FAA are responsible for the safety l
operation of complex technologies.
The big difference is that the FAA
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is alsa respontible not only for the rtgulation but also the promotion of civil aviation.
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The FAA functions in three rain areas. The first is the certification process. The second is the inspection programs. The third is the i
industry programs. The maintenance program is developed during the certification pericd.
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The certificttion process includes three types of certifier 11on. There is the certification for the aircraft. There is also a cartificate that t
the manufacturer has the capabilities to construct the aircraft accord-ing to type certification. There is an operational ctrtification which each plane receivts as it lease the aircraft facility to ensure that it meets the type certification.*equirerents.
j Any modification to the aircraft after it is ccapleted would necessitate changes to the operational certificate.
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The FAA requires that a scheduled raintenance program document accompany each type of aircraft. This is the basis for the atritne raintenance pr og rae:s. The FAA also requires an approved maintenance program for i
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Minutes / Maintenance Stbcommittee 8
Meeting. June 15, 1988 e' ch airhae, ho specific form of a maintenance program is required by a
the FAA.
The FAA lice % maintenance schools and mechanics. The FAA inspects oper:,cing aircraft and verifies that they are maintained according to their maintenance prograus.
Mr. Chokie discussed the development of the maintenance program. The m intenance steering group revie'vs significant m'intenance items and develops insrection schedules for critical maintenance itens on the aircraft. This group is corposed of representatives of the aircraft manufacturer, the power plant and those airlines that are going to purchase the aircraft. The FAA sits in as an observer during all of these reetings.
The Maintenarce Review Board, ce:nposed of FA/. inspectors and people from the engineering group, review the infonnation, review the inspection schedules, and then publish the approved m intenance schedule document for that tircraft type.
The airplane s nufactures also issues service bulletins. These are infonnation notices oeveloped from manufacturer's studies and from airline operating experience. The airplane unufacturer conduct supple-rental maintenance investigations.
They go out under contract to the airlines to review their m interance programs to see how they stock up against what the ranufacturer f;als is an appropriate program.
Minutes /Maint: nance Subconcittee 9
Meeting. June 15. 1968 To be certified as a maintenance inechanic requires about 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> of classroom training and an equal arount of on-the-jnb training.
Then there is an oral and practical test to be certified.
To be certified as an inspector required three years experience as a i
licensed rechanic including twt years of recent experience.
There are l
l ccrtain tests prior to being certified as an inspector.
The Designated Engineering Representatives are inoividuals who are selected by the management a', the manufacturing organizations and work for the manufacturer. They are approved by the regional FAA I
administration as representatives for the FAA to verify that new draw.
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iags, new systems, arid designs per new aircraft types are being devel-oped according to tne FAA requirements. They can sign off as a rep-resentative of the FAA that this inforr.ation ineets the code.
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Yatter Scott, Eattelle, pacific Northwest laberatories Mr. Scott noted that he stuld discuss the assessr,ent of U.S. industry I
practices. Appendix B of 10CFR50 has several criterid addressing maintenance related activities.
Regulatory Guide 1.33 specifies proce.
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dures that a plant should have. There are sore te-hnical specification f
requirements for maintenance. The tech, spec. requirement having a major irpact on reintenance is the requireeent that the on Site Safety Review Group review any changes to plant procedures that are safety related and that they review the procedures on a nominal two year basis.
This includes raintenance procedures.
b Minutes /Maintensnee Subcomittee 10 Pecting, June 15, 1968 Mr. Scott remarked
- hat thPO and EPRI had established a working group on maintenance. These working groups have been terminated.
The reason given for the terraination was that there wasn't a clear course of action. They had been unable to identify what they terred generic maintenance problers that would require generic maintenance solutions.
They four4 that items that were plant specific in nature had to be add *essed on a plant by plant basis and therefore a coordir,ated industry effort was not appropriate.
t The.ndustry seers to prefer p'*eparing guidelines for not only r.ainte-5j nance but other dreas as well, lhe industry is working on the self assessner t program bas 0d upon INPO guideltres for the conduct of maintenance.
INFO sponsors the rsintenarce assistance and Review Team (or MRT).
MRT includes many disciplines and is coeposed of representatives from the industry that go out to the plants and review the reintenance programs.
They focus on plants that can be irproved and riake recomendations to the utilities.
The Maintenance Peer Evaluation inrolves sharing of raintenance emperi-ence between plants. A team ef utility r:, inter.ance emperts go to another utility and work with the utilities r.ainterance staff to try and share good practices and things that have occurred at other plants to irprove the program at the plant being evaluated.
Minutes / Maintenance Subcommittee 11 MeeHng, Juna.15, 1988 TheIN0TrainingandAccreditationProgramimpactsmaintenanceinthe sense that it deals with the training and qualifications of maintenance personnel.
s' INPO has started a pilot program in the area of reliability centered y
maintenance. The first part of the program involved 3 system assess-ments.
Tney looked at the Turkey Point Component Cooling Water System; the McGuire Main Feedwater System and the San Onofre Auxiliary Feedwater System.- The thrust of the pilot program is to apply the systematic approach of reliability centered maintenance to planning and evaluating the preventive maintenance program at the plants.
EPRI has established the Maintenance Equipment Application Center at
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Charlotte, North Carolina. The objective cf this Center is to accumu-late emerging maintenance technologies for evalr iion and transfer to the utility industry. The information is transferred through technology seminars, equipment demonstrations, evaluation and testing and responses to individual utility requests for information on a puticular technolo-gy.
EPRI has established the Component Mor,itoring and Diagnostic Center.
l They have published a vibration monitoring guide.
They are working on j
l two guidelines. One is on loose parts monitoring and the second is on vertical shaft pump monitoring. The Center is preparing topical reports on methodologies. They are looking at operating experience reports.
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r Minutes / Maintenance Subcomittee 12
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Meeting, June 15, 1988 They are conducting workshops and seminar to transfer the infor111ation to the utilities.
EPRI has recently formed the Nuclear Maintenance Assistance Center. The objective of this center is to collect, analyze and integrate the utility experience without being a burden to the utilities. They would do an analysis of operating experience and supply it to the utilities on a subscription basis without being a resource burden to the utilities.
The Nuclear Maintenance Assistance Center will have a hot line for utility problems. They will have a cadre of maintenance experts that will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and they will be able to provide maintenance advice.
Mr. Scott noted that they are continuing to follow the industry initia-tives. They will see what the benefits of the industry initiatives are.
i They want to correlate and do more work on seeing how these particular maintenance initiatives from the industry correlate with the activity areas delineated in the policy statement.
Moni Dey, Project Manager for the Maintenance Rulemaking Task l
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Mr. Dey noted that he would discuss the options that staff is consider-ing for maintenance rulemaking and also a preferred option.
l The starting point for the maintenance rulemaking is the maintenance policy statement which outlined the Comission's expections for a plant l
raintenance program and listed a number of activities that the
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F Minutes / Maintenance Subcomittee 13 Meeting, June 15, 1988 Commission considered to be essential in a plant maintenance program.
The five options were:
1.
General performance based rule 2.
Prescriptive perfomance based rule 3.
General rule / industry standard (FAA approach) 4.
General rule / Reg. Guide 5.
Prescriptive rule (Japanese / Navy approach)
F Mr. Dey noted that the Comission prefers Option 2.
In conjunction with Option 2, a Reg. Guide would be issued providing guidance on acceptance performance indicators. AE0D has a program to develop maintenance performance fadicators.
For the performance based option, the informa-tion would be reported to the NRf The NRC would audit their program for determining those indicators as netded.
Based upon the performance indicators the NRC will determine if special inspections are needed.
Poor maintenance indicators will probably require special inspections.
Mr. Dey noted some of the eierents of the proposed rule.
The rule should cover all equipment that could affect safety systems, perfor-mance, or cause a safety system to accuate.
The rule should n0t divert or hinder good industry initiatives directed toward improving mainte-nance. The rule should state objectives but not describe solutions and particular ways of conducting maintenance.
It should provide for flexibility to the plants for developtrent of their maintenance program, It should have a provision to ensure the feedback of results to improve i
the progran and measure the overall program effectiveness.
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Minutes / Maintenance Subcommittee 14 Meeting, June 15, 1988 Mr. Oey noted that the staff will go into the Maintenance Workshop, July 11-13, 1988, with the five options but will focus attention on the preferred option. The etaff hopes to have some maintenance indications ready prior to the workshop for discussion.
At 3:45 p.m., the meeting was adjourned.
NOTE:
A transcript of the meeting is available at the NRC Public r
Document Roem, 1717 H Street, NW., Washington, D.C. or can be purchased from Heritage Reporting Corporation, 1220 L Street, NW., Washington,D.C.20005, Telephone (202)628-4888.
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,a HERM: JUNE 15 TENTATIVE SCHEDULE ACRS MAINTENANCE SUBCOMMITTEE MEETING JUNE 15, 1988, ROOM 1046, 1717 H STREET NW WASHINGTON, D.C.
8:30 a.m.
Opening Remarks - C. Michelson 8:45 a.m.
Overview and Status of Rulemaking effort M. Dey, RES
- 1. Responsibilities
- 2. Schedule
- 3. Activities
- 4. Plan for Workshop 9:45 a.m.
Sumary of Maintenance Practices and Initiatives Foreign Program - A. Chokie, PNL 10:30 a.m.
BREAK 10:45 a.m.
Aviation Industry - A. Chokie, PNL U.S. Nuclear Industry - W. Scott, PNL E. McKenna, NRR Military - PNL/RES 12:00 N00t:-
1:00 p.m.
LUNCH 1.'00 p.m.
Rulemaking Options - M. Dey 3:00 p.m.
Subcomittee Discussion 3:30 p.m.
ADJOURI.
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l 20037 Federal Register / Vol. 53, No.105 / Wednesday, June 1,1988 / Notices 7
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Dste:May 24.19sa.
NUCl. EAR REGULATORY Morton W. ubsAin, For a more complete statement of the C
MISSION Assis tant Executive Director /ar Pinstet facts and representations supporting the Amew.
13 Filed %31-# E45 acQ r Department's decision to grant this AdyJsory Committee on Reactor (HL Doc. es-u:
exemption refer to the notice of Sateguards,Suocommittee on suo coot mo-aws proposed esemption published on April Maintenance Practicea and 22,1988 at 53 FR 13358.
Procedures; Meeting Advisory Committee on Reector For Further In/onnotion
Contact:
he ACRS Subcomr6ittee on Safeguards, Subcommittee on -
Joseph L Roberts 111 of the Department.hiaintenance Practices and Procedures Reliability Assurance; Meeting T
telephone (202) 523-8881. (This is not a will hold a meeting on June 15,1988.
toll free number')
Room IN8,1717 H Street, NW.,
Reliability Assurance will hold a The ACRS Subcommittee on Generalinformation Washington,DC' meeting on june 14,1908. Room 1No.
The attention of interested persons is The entire meeting will be open to 1717 H Street NW., Wathington, DC.
di7ected to the following:
public attendance.
ne entire meeting will be open to (1)The fact that a transaction is the The agenda for the subject meeting public attendance.
subject of an exemption under section shall be as follows: Wednesday, /une 15, ne agenda for the subject meeting CD8(a) of the Act and/or section MS-aJo o.in. untilthe conclusion of shall be as follows: Tuesday, /une H, 1.cas-d 30 a.m. until the conclusion of 4975(c)(2) of the Code does not relieve a busmess-fiduciary or other party in interest or The Subcommittee will be briefed by business.
disquabbed person from certain other RES on the cunent status of the The Subcommittee will be briefed on provisions of the Act and/or the Code,Mainte-ance Rule.
the final outcome of the Egalpment Including any prohibited transaction Oral statements may be presented by Qualli cation Risk Scoping Study. An provisions to which the exemption doesmembers of the public with the update on the implementation of the not apply and the general fiduciary concunence of the Subcommittee resolution of US! A-48,"Seismic responsibibty provisions of section 4N Chairman; written statements will be Quahfication of Equipment in Operating of the Act,which among other things accepted and made available to the Nuclear Power Plants,"is also planned, require a fiduciary to discharge his Committee. Recordings will be permitted Oral statements may be presented by duties respecting the plan solely in the only during those portions of the mernbers of the public with the interest of the participants and meeting when a transcript is being kept, concunence of the Subcommittee beneficiaries of the plan and in a and questions may be asked only by Chairman: written statements will be accepted and made available to the prudent fashion in accordance with members of the Subcomrnittee,its section (N(a)p)(B) of the Act.nor does consultants, and Staff. Persons desiring Committee. Recordings will be permitted it affect the requirement of section to make oral statements shou!d notify fer a tr n a being kept, e
401(a) of the Code that the plan must the ACRS staff member named below as p
me t n operate for the exclusive benefit of the far in advance as is practicable so that and questjons may be asked only by members of the Subcommittee,its employees of the employer maintaining appropriate anangements can be made.consultants, and Staff. persons desiring the plan and their beneficf anes.
During the initial portion of the to make oral statements should notify (2)These exemptions are meet;ng, the Subcommittee, along with the ACRS staff member named below as supplemental to and not in derogation
.ny of its consultants who may be far In advance as is practicable so that of. any other provisions of the Act and/present, may exchange preliminary appropriate ancngements can be made.
- j or the Code. including statutory or views regarding matters to be During the initial portion of the administrative exemptions and considered during the balance of the meeting, the Subcommittee, along with t
transitionalrules Furthennore,the fact meeting.
any of Ita consultants who may be that a transaction is subject to an The Subcommittee will then hear present, may exchangt preliminary administratise or statutor) exemption is presentations by and hold discussions views repiding matters to be j
not dispositive of whether the with representatives of the NRC Staff, considered during the balance of the d
transaction is in fact a prohibited Its consultants, and other interested meeting.
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persona reptdmg tlJs review.
ne Sabcommittee will then hear presentations by and hold disussions l'j (3)The availability of these Further information regarding toples with representatives of the NRC Staff.
exemptions is subject to the express to be discussed,whether the meeting
)i condition that the materialf cts and has been cancelled or rescheduled, the its consultants, and other interested
- P'"0^888'dlM d '*I'**
I representations contained in each Chairman's ruling on requests for the Further inforation regarding topics
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4 application accurately describes all opportunity to present oral statements to be discussed, whether the meetitut
'I material terms of the transaction which and the time allotted therefore can be has been canceled or rescheduled, the a11
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at Washington, DC, tha loth day of
{btalned by ry d teleph n Chairman a ruling on requests for trie I3 is the subject of the exemptiun.
to ud oral statements herman Alderman (telephone 202/634-opp r and the time al otted therefor can be 1414) between 7.30 a m and 415 p m.
btained by a prepaid telephone ca!! to
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- il Od*',Dercror.for&niotions Persons planning to attend this meeting the cognisant ACRS statt member,Mr.
are urged,to contact the above named Rjchard Major (telephone 202/634-1414)
Actics Associor
' N W e'io"8IV"8/088"d W'!!#'
indMduo one or two da)s before the B. ens!,ts Adminatratien. v$ Dqrtmentof scheduled meeting to be advised of any between 7.30 a.m. and 4.15 p.m Persons planning to attend this taeeting are
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change in schedule,etc., which may urged to contact the above named
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have occuned.
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LIST OF HANDOUTS JUNE 15, 1988 ACRS SUBCOMMITTEE ON MAINTENANCE MEETING 1.
Maintenance Rulemaking - overview 2.
Task 1 Preliminary Review of Japanese Maintenance Regulations and Practices 3.
Task 2 - Preliminary Review of European Approach to Maintenance Regulation 4
Take 5 - Assessment of Industry Practices and Initiatives 5.
Task 6. Preliminary Review of FAA Regulatiois of Civil Aviation Maintenance Programs 6.
Maintenanca Rulemaking - Option b
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