ML20206B315
| ML20206B315 | |
| Person / Time | |
|---|---|
| Issue date: | 10/07/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2602, NUDOCS 8811150408 | |
| Download: ML20206B315 (16) | |
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CERTIFIED COPY DATE ISSUED: October 7, 1988 l l
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SUMMARY
/ MINUTES ACRS SUBCOMMITTEE ON MAINTENANCE l' PRACTICES AND PROCEDURES HEETING d
SEPTEMBER 7, 1988, 7920 NORFOLK AVENUE, BETHESDA, 4 MARYLAND j t
J The ACRS Subconnittee on Maintenance Practices and Procedures met on September 7, 1988, to review the proposed advan:ed notice of rulemaking on maintenance at nuclear power plants.
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C. Michelson was the Chairman for this meeting. Other ACRS Members in l t
attendance were W. Kerr, C. Wylie and J. Carroll. Mr. G. Reed was an !
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j ACRS Consultant for this meeting. H. Alderman was the ACRS Cognizant j r Staff Member for the meeting. h i
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- The meeting commenced at 8
- 30 a.m. The handouts are filed with the ,
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! h I Introductory Remarks - Subcomittee Chairman C. Michelson j
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$ Mr. Michelson introduced the other ACRS Members in attendance and the I' I consultant for the meeting. He asked the other ACRS Members and consul-i tant if they had any coments. He the'i introduced Mr. Moni Dey as the j first speaker,
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Sept. 7,1988 Maintenance, Practices 2
'and Procedures Subcomittee Mtg.
A itoni Dey, Advanced Reactor and Generic issues Branch, Division of Regulatory Applications, Office of Nuclear Regulatory Research Mr. Dey noted that with him was Tom King, Branch Chief, Ron Frahm, !
Section Chief, John Jankovich, NRR, and Walt Scott, PNL-Battelle.
Mr. Dey presented the schedules for the proposed notice of rulemaking.
] He noted the Full ACRS meeting on September 8th, the meeting with CRGR :
1 on September 14th and submittal of the notice of proposed rulemaking to 1
. the Comission by October 3rd, i
He said that key milestones for implementation of the proposed mainte- !
nance rule would be:
l Following the Comission review of the proposed rulemaking package, the
) proposed rule would be published about November 1, 1988. Following ;
4 publication of the rule, there will be a two months public coment !
period. The staff will analyze the public coments and incorporate them f
- into the rule and have a final rule available for Comission review by April 1, 1989. The final rule will require licensees to submit a 1 schedule for full implementation of the rule within 90 days following '
i j promulgation of the rule, j 4 ;
- As a parallel effort to rulemaking the staff is proposing to develop a regulatory guide. This guide will outline expectations for an industry maintenance standard and possibly endorse an industry standard. The
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staff intends to issue the regulatory guide about a year prior to full implementation of the maintenance rule which is scheduled for May 1991.
Mr. Oey discussed the conclusions reached after coment on the rulemaking option. He stated that the staff believes that prescriptive rulemaking options have ininimum flexibility and might impede industry initiation. He noted that the staff recomends a rule which would give industry the incentive to develop a standard for a maintenance program.
J Mr. Dey discussed the industry standard. He noted that the staff expects the industry standards to be comparable in scope and depth to the INP0 maintenance guidelines. He said the industry standard should include provision for performance assessment and feedback of the results to irrprove the program.
Mr. Dey remarked that the purpose of the rule is to improve licensees [
maintenance programs where warranted. He noted that they believe there are a lot of existing programs that are good that would not need any major modification, and that the rule would maintain a satisfactory level cf performances. He said it is a future possibility that I utilities with good pregrams may have their programs decline and the rule would ensure that those plants keep up to an acceptable level. l The question was raised by the consultant and a member regarding the i amount of documentation that would be required. The concern was exces- [
sive documentation which may detract efforts from maintenance work. Mr.
Dey noted that that was a valid coment. He remarked that documentation l l
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'and Procedures Subcommittee Mtg.
would help to pass on experience when well trained people retire. Mr .
Reed did not agree with the observation about documentatiori helping to pass on experience.
Mr. Dey noted that the purpose of the rule is not based on an exact measure on threshold of maintenance effectiveness. He said that mainte-nance effective cannot be measured exactly.
Mr. Michelson asked what the standard might include that the INP0 maintenance guidelines doesn't already cover.
Mr. King noted the INP0 guidelines doasn't get into performance indica-tors in the depth that the staff would like.
Mr. Dey pointed out the INPO guidelines doesn't cover the interface between maintenance and other activities in the plant.
Mr. Dey discussed the form and content of the rule. He said the staff is proposing a general rule which requires each licensee to have mainte-nance program, and the program should include a manditory system to monitor its effectiveness and make improvements where warranted.
The general rule would require the maintenance programs to iriciude the activities defined in the policy statement.
- e Sept. 7, 1988 Maintenance, Practices 5
'and Procedures Subcommittee Mtg.
Mr. Dey noted that the standard and the rule addresses all component systems and structures. However, the requirements would be comensurate with safety.
There was some discussion regarding the scope of maintenance to be covered by the rule. The staff noted that they expected industry to define it in the maintenance standard. Several ACRS Members noted that industry would have a problem defining the scope. The staff noted that they could consider putting their own thoughts about the scope into the proposed rule.
Mr. Reed pointed out that if the maintenance rule extends into the balance of plant, the scope should be clearly defined.
Mr. Michelson asked why a rule is necessary. He noted that a regulatory guide can be prepared at any time.
Mr. King responded that generally a regulatory guide is written to define an acceptable way to meet a rule. In this cases, there isn't a rule on maintenance.
l Mr. Michelson asked the staff to determine the position of the Office of General Counsel as to whether the maintenance rule is necessary to provide a legal basis for enforcement actions regarding maintenance.
! Mr. Dey rentioned implementation of the maintenance rule. The licensees l would be required to fully implement the rule within two years of the I
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'and Procedures Subcomittee Mtg.
effective date of the amencment, and within 90 days of the effective date of the amendment. The licensees would be required to submit a plan of the full implementation.
Mr. Dey noted the advantages of the recomended approach to rulemaking.
He stated that it guides industry initiatives which are undenvay toward an acceptable standard which is endorsed in a regulatory guide with the enforcement capability of a rule. It allows and encourages industry participation in preparation of the standard which will give them added incentive, opportunity, and responsibility for improving plant programs.
The approach would transfer information from good plant maintenance programs to those that need improvement.
lir. Dey discussed the attributes of an acceptable maintenance standard.
The first is that it should define the scope of plant systems, struc-tures and components. It should provide clear and specific programatic requirements that can be practically implemented by the licensee. It should be comprehensive and address all the activities in the proposed rule which are from the policy statement including the provisions for self-assessment and feedback. The standard should include provisions to allow flexibility for adoption of new innovative technologies as they are validated. The standard should reference other standards or guide-lines. The standard should provide sufficient documentation for program effectiveness and compliance with the requirements, so the standard can be evaluated.
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'and Procedures Subcomittee Mtg.
Mr. Dey noted that as a result of maintenance practices in other coun-trits and industries the following points should be stressed in the maintenance standard, o A systems approach should be used.
o The standard should focus on long-term objettives. A proactive maintenance program should be stressed rather than a reactive program, o The standard snould provide guidance on how to select appropriate parameters for monitoring the effectiveness, o The standard should include maintenance technician training and certification of programs, o The standard should include guidance and planning, o The standard should require engineering support and evaluation of failure data.
Mr. Dey pointed out that the notice of proposed rulemaking asked three specific questions, o Will industry comit to development of such a standard?
o Wnat level of detail should be included in the industry standard?
o Is two years a reasonable time to develop and implement such an inaustry standard?
Mark Pullen - Battelle Northwest
. . s Sept. 7, 1988 Maintenance, Practices 8
'and Procedures Subcomittee Mtg.
fir. Mullen discussed the regulatory analysis of the proposed maintenance rule. He noted that on a balance, the maintenance rule has a positive l net benefit. There is a substantial reduction in public risk. He said that on a balance there is a net reduction in occupationa' exposure as a result of the maintenance rule, i
! There are expected to be some increased costs, at least initially, for ,
l more maintenance technologies. There will be expanded preventive j t
i naintenance, more trending and failure analysis activities. There will I be some efforts required to improve procedures. This effort will be ;
concentrated in certain plants which currently have weak maintenance programs.
r There should also be some substantiel cost savings from factors like reduced down time, reduced corrective maintenance and a reduction in the !
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- amount of rework that would need to be perforrred. !
I I Regarding NRC costs, these costs would be relatively small, small both relative to the industry costs and small relative to the NRC budget.
I Based upon the way the rule is structured, the reliance on an i'idustry ;
standard should have the the effect of minimizing the impact on the industries initiatives. This will tend to minimize the regulatory ;
burden associated with the regulation. l
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Regarding risk evaluation, Mr. Mullen pointeo out the difficulty in this analysis. He noted that several different calculations tended to agree P
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at an approximate total risk reduction on the order of a hundred thou-sand to a million oerson REM. This is a total for all the ef fected plants over their remaining plant lifetime.
Mr. Mullen discussed the basis of the calculations. He noted that based upon volume 2 of the draft NUREG/PE, one can estimate that the average ;
or nominal risk of a typical plant is about 300 person rem per reactor !
year. The assumption is made that 20 or 30 plants are maintenance outliers with weak maintenance programs and their risk levels could be two to five times as high, it was assumed that maintenance improvements as a result of this regulation will eliminate two thirds of that extra risk. It is assumed that industry initiatives might account for half of the improvement. When one sums overall the affected plants over a r lifetime of thirty years, the estimated risk reduction turns out to be 60,000 to 360,000 person rem.
Mr. Michelson pointed out that the studies dealt with only internal events. He notea that external events can be maintenance initiated.
Mr. Mullen agreed. He said that internal events are only part of the total risk spectrum. He said improved maintenance won't solve all of the risk problems. He noted that perhaps two thirds of risk reduction could be achieved through maintenance improvecents.
l Mr. Carroll pointed out that maintenance generally doesn't operate in real times. Usually maintenance is performed on equipment that is not ,
operating. This doesn't affect the safety of the plant as much as an l
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operator error, for example, whose error can affect the safety of the i plant.
Mr. Hullen noced that the maintenance rule would reduce occupational exposure. He said that maintenance acccunts for a large fraction of all ,
the occupational exposures in the plant.
Mr. Mullen remarked that plant savings will accrue due to improvement in <
plant capacity factors due to improved maintenance. He said this was based upon a statistical study of plant capacity factors versus mainte-nance performance as measured by the SALP program.
Mr. Muller sumarized that the regulatory analysis indicates that the proposed rule will have a positive net benefit. There will be a sub- [
stantial reduction in public risk, reduction in occupational exposures ,
and some cost increase that will be balanced by cost reductions.
Walter Scott - Phl Battelle '
l Mr. Scott said he would discuss what has been found from the reviews of f L
ether maintenance practices and programs. He noted they had looked at l l !
i F.A.A., Japan, the Federal Republic of Germany, the French program and e f l l limited review of 18.5. naval practices.
There was some discussion of the Designated Representative concept. Mr.
Chockie said that the airlines have certified mechanics who serve this function, i
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'and Procedures Subcomittee Mtg. '
4 i j Mr. Scott noted there are three typos cf inspectors that the FAA cer-tifies. One is involved in the design process. One is involved in the [
manufacturing process. One inspector is at the carrier's facility and [
looks at the maintenance work that is performed. ;
f The French have a system of prioritizing maintenance and allocating !
i their resources. This system identifies the safety significance of I systems and components as well as the availability significant of systems, structures and components. Their approath is to use that a
significance both from the safety standpoint and the availability
! stai.dpoint to focus their resources for conducting maintenance.
The Japanese require a ten year in-service inspection plan which encom-passes their yearly inspections that are conducted during the outages.
Their ten year plan is somewhat general, and their yearly plans are much i
more specific and these reflect a prioriti:ation of items that will be conducted. The yearly inspections are composed of a fairly stable list of items but these are c.trived at through iteration which tell them which areas are important. They constantly review the results of the l yearly inspections and base the next years inspection on the results of previous inspections.
The FAA requires the t.elopment of a standard maintenance program document. This goes with each aircraft and it contains the scheduled maintenance activities that should be conducted on that aircraft.
Sept. 7, 1988 Maintenance, Practices 12 and Procedures Subcomittee Mtg.
P.egarding the staff recommendation that the progran should focus en long term objectives, and establish a proactive rather than a r active program, this is to indicate that the attainment of the objectives of the maintenance rule may take some time. The maintenance program should be focusing on what they are going to accomplish long term rather than the short term.
l Mr. Scott noted that three of the programs have been reviewed have long term programs for improved component reliability. The French program and the FAA use reliability centered maintenance programs. Japan uses a preventive maintenance program which is evaluated and the results are used for design changes.
Mr. Scott discussed the third MC staff recomendation which calls for a monitoring system that can be used to feed back information on the effectiveness of the pregram. The French have a extensive root cause analysis program that they use tc modify their precedures, training material content and their preventive maintenance schedules.
The Japanese are looking at ways that their prev 3ntive maintenance program can reduce the scram frequency.
The FAA requires a system for continuing with analysis and surveillance of the performance and effectiveness of maintenance progran:s on the aircraft that are flown by the airlines.
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'and Procedures Subcommittee Mtg. l t
Mr. Scott discussed recorrendation Number 4 about training and certi-fication of naintenance technicions. He noted that Japan has created a national maintenance training center. Germany has national requirements i
for training that include standardized examinations. The French with l their centralized utility and the standardization of their designs are able to have centralized raint nance training programs. '
Mr. John Jankovich, Performance Evaluation Branch, NRR ;
l Mr. Jankovich discussed the maintenance team inspections. He noted tha use of the maintenance guide as a basis for inspection. He remarked j that three pilot inspections have been performed. Otablo Canyon, Os onee ana Peach Bottom. He noted that the staff projects about 67 in ope a-tion during the next two years. In response to question about why 50 many inspections are being performance. Ns., McKenna replied that tiese inspecticns are taking the place of many of the routine inspections now being perforned. She also noted that the staff is continuing to evaluate the results of the inspections and if they find they aren't l cost effective they will reconsider this efforts.
Mr. Jankovich pointed out that the basis for the maintenance inspection guideline is a naintenance based upon the so-called HORT trees (manage-rent oversight anti review team work). There are three major branches of l the tree. Gener 0 "formance indicators, management support of nainte-j nance, and implek .. ton of the maintenance process.
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nia t Mr. 'Jankovich said the inspection teams were composed of seven people ;
4 and(they'tpent about three weeks for each inspection. !
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~ Dr. Kerr' asked if any member of the team had been responsible for maintenance at a nuclear power plant.
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The staff did not know if any members of the team had been responsible for maintenance at'a nuclear power plant. '
Dr. Xerr asked if it was the view of the staff that people who have not 3
had experience in maintenance can effectively inspect a maintenance
- program.
2 3 Mr. Jankovich repli.ad that based on the pilot inspections, it appears i that with sufficient preparation, they can do an effective inspection. :
! I Mr. Jankovich stated that the insoection reports were able to achieve t
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their objective to provide a good essessmec of the maintenance process.
The reports have sections on the strengths, weaknesses, and potential i violations identified in the inspection.
t ij Dr. Xerr repeated his concern regarding the inspection. He noted that l i
- j j. he couldn't see how people who aren't experienced in maintenance can }
draw a judgment that has very much validity.
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. I Sept. 7,1988 Maintenance, Practices 15
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l Mr. Jankovich saio the staff planned to use inspections to develop j recommendations for agency and office management use. The plan to -j provide overview for these inspections from a national perspective. l m
I Mj.JoeColvin,NUMARC 4 .
1 Mr. Colvin stated that the industry position is that the rule is unlec- !
, essary and it will be disruptive and costly to the industry and without !
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J any gain in safety and reliability. He said he thought the result would i be a very prescriptive maintenance program. l l
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He said the industry standard on maintenance has been and is the INP0 i
maintenance guideline. He quoted from the INP0 guidelines. "Deviation ;
from any particular guidelines would not in itself indicate a problem in
) station maintenance. However, difference between the guideitnes and f
- station practices should be reviewed to determine whether station I
, practices should be changed. A change in station practices would bc
- appropriate if performance weaknesses were determined to exist."
L l He pointed out that the guidelines sets the intent. He noted that every l plant in the United States is using indicators to assess their mainte-nance program. He said he didn't believe that tnere fs any benefits [
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j that would be gained to prcvide guidance as to whM. those indicators ,
) should consist of. l t
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! Regarding SALP data, Mr. Colvin stated that to date in 1983, enly one t .
plant has a SALP 3 in maintenance. He said to his understandirg only l l
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three plants had a SALP 3 in maintenance last year. He said that everybody knows which plants have problems in maintenance and both the industry and NRC are placing tremendous emphasis or :crrc: ting thc
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problems.
Mr. Colvin said the bottom line is that industry is achieving results.
1 He said these results would be achieved without a rule.
There was some discussion regarding whether maintenance would improve I without a rule.
Dr. Kerr asked whether industry can solve the problem if left to itself.
I Mr. Colvin replied that shcught the answer was yes.
The meeting was adjourned at 3:10 p.m. -
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NOTE:A transcript of the meeting is available at the NRC Public Document Room, 1717 H St. NW., Washington, D.C. or can be purchased from Heritage Reporting Corporation, 1220 L Street, NW.,
Washington 0.C. 20005, Telephone (202) 628-4888. :
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