ML20207P002
| ML20207P002 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1987 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Conway W INSTITUTE OF NUCLEAR POWER OPERATIONS |
| Shared Package | |
| ML20207P003 | List: |
| References | |
| NUDOCS 8701140545 | |
| Download: ML20207P002 (3) | |
Text
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,9 JAN0 9Igp Mr. William F. Conway Group Vice President Industry and Government Relations Institute for Nuclear Pcwer Operations 1100 Circle 75 Parkway Suite 1500 Atlanta, GA 30339
Dear Mr. Conway:
Subject:
NRC Evaluation of the Nuclear Plant Reliability Data System This letter responds to yours dated December 5, 1986 on the above subject.
First, let me assure you that we share your concern regarding the use of contractors to evaluate INP0 programs. However, our report on the status of the NPRD System was not prepared by a contractor. We did use a contractor to extract and process the raw data, but the evaluation was performed by NRC staff members. This method has been determined to provide the most efficient utilization of NRC staff resources for the evaluatio1.
We have exercised strong control over the contractor's use of the NPRDS data and have assured that unit-specific information is protected as proprietary in nature.
- Further, I note that this process is the same as that discussed with INP0 personnel in the past (see Attachments 1 and 2) and is fully consistent with our past agreement and understanding.
Regarding the " state" of the NPRDS program and data base, we welcome your invitation for further discussions. The NRC and INP0 staffs have had dis-cussions concerning alternative methods to evaluate and ensure the quality of the NPRDS program. As you know, the NRC considers the NPRDS to be the primary source for component and train level data.
Ready availability of this informa-tion is very important to us and the industry in the implementation of many safety programs and we would like to work with INP0 to explore possibilities for sharing data and methods to assess and ensure its quality and suitability for various applications by NRC licensees and staff.
I know that Mr. Jack Heltemes has had some preliminary discussions with you in this regard.
I understand that plans are in progress to continue the development of a cooperative approach. Jack will continue to be our point of contact for this activity.
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y Mr. William F. Conway I would like to take this opportunity to again commend INPO on their past and continued efforts in the impressive improvement and maintenance of the NPRDS.
Sincerely, Origirmi cigned bg' Vic ter Stel10/
Victor Stello, Jr.
Executive Director for Operations Attachments:
As Stated cc:
C. J. Heltemes, Jr., AEOD Z. Pate, INPO Distribution:
Full PTB CF PTB SF AE0D CF AE00 SF ED0 RF V. Stello J. Heltemes F. Hebdon M. Williams B. Brady J. Roe T. Rehm J. Sniezek M.Bridgers(EDO2382)
J. Taylor H. Denton J. Davis E. Beckjord J. Murray l
T. Murley, RI l
J. N. Grace, RI!
J. Keppler, RIII R. Martin, RIV J. Martin, RV r
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DATE :12/ /8
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Nuclear Power i
w Operations 2J 1820 Water Place Atlanta. Georgia 30339 Telephone 404 953 3600 April 2, 1982 Mr. Carlyle Michelson, Director Office for Analysis and Evaluation Of Operational Data U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Request for NPRDS Data Base Tape Dear Carl We appreciate the opportunity to discuss with you and Jack Heltemes your plans for using INEL to review the NPRDS program.
We recognize your commitment to provide semi-annual reports'to the Commissioners and we will be happy to assist you and INEL in any way we can.
Our discussions, relative to this INEL Work effort, are summarized below:
1.
INPO is prepared to supply the NPRDS data base for use in support of this contract under the condition that the data base be treated confidentially and not be used by the contractor for purposes other than those stated in the contractor's scope.
It should be further understood that the contractor is not to supply information or a copy of the data base to any third party.
2.
We would like to review the reports and conclusions generated under the contract to ensure there is no mis-interpretation of the data base.
As you know, there are many areas where unfamiliarity with the system can lead to erroneous conclusions.
3.
The analysis of compatibility of NPRDS event description with LER event descriptions should be approached with caution since the two systems have different requirements, different uses and are generally developed by different groups within the utility.
4.
The timeframes specified under Paragraph 1(b), 2 (b), and 2 (d) are far too short to show any changes in the data base.
Typically inclusion of failure data in the NPRDS data base lags the event by approximately 5-6 months.
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5.
The Manufacturer's serial Number is not a mandatory field in the engineering data form.
Therefore, a check for completeness of this field would be meaningless.
6.
We would like a list of the 100 LERs selected to be used in the analysis so that INPO can perform a similar
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analysis.
7.
The use' of PIDs alone will not be suf ficient to provide EG&G with enough information to evaluate whether a system has been completely scoped or not.
The contractor will also require instrumentation and electrical schematics.
8.
The scope of work states that the analysis of
- engineering data is to be made against the " proposed system boundaries."
We assume this refers to the new reportable scope drawings currently under development.
This seems to be very premature since we will not be formally transmitting the new scoping manuals to the utilities until later this year and since we have not decided upon an appropriate time frame for utilities to update the reportable scope of their facilities.
As our discussion indicated, the study appears to be keyed to assessing changes due to INPO management on a time frame significantly shorter than we would reasonably expect.
Please let us know if the limitations on the data base are ace,eptable so we can arrange for a dump of the data base to INEL.
If we can be of further assistance, please let me know.
Sincerely, R. L. Haueter Director, Information Services Department lek cc:
C. J. Heltemes E. P. Wilkinson e
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NOV 061965 Dr. Zack T. Pate, President Institute of Nuclear Power Operations 1100 Circle 75 Parkway Suite 1500 Atlanta, GA 30339
Dear Dr. Pate:
SUBJECT:
STATUS OF THE NUCLEAR PLANT RELIABILITY DATA SYSTEM This is in response to your October 22 letter commenting on the NRC's seventh Semiannual Evaluation of the Status of the Nuclear Plant Peliability Data System (NPRDS). As you suggested, I have provided your letter to the appro-priate NRC staff, and I would like to share with you their reaction and coments.
When INPO took over the management and direction of the NPRO System in mid-1981, it was recognized by INPO to be a test of the industry's ability to self-regulate. That is, through industry's efforts, including plant evalua-tions, discussions with utility management, and peer pressure, all plants would strive to reach a standard of excellence and in so doing would at least reach the level of performance of component failure reporting that would be present through government regulation.
Now you indicate that the NPRD System has achieved its objectives, that the point has been reached which "... represents virtually full utility partici-pation...", and that, as a result, all INPO needs to do is "...to keep track of and act on occasional lapses."
NRC staff members familiar with individual plant perfonnance in the NPRD System believe your assessment is not correct. Neither the data provided in your letter nor the information available to the NRC support such a conclusion.
Despite intensive and aggressive action by INPO management, data available to the NRC indicates that as of the first quarter of CY 1985, the NFRD System had not yet reached the point where all plants are participating in accordance with NPRDS procedures. Thus, it is our view that the NPRDS objectives have not been achieved, and substantial numbers of reportable component failures are not being entered into the system.
Thus, Zack, as I see it, the issue is not whether significant improvements have been made in the NPRD System over the past several years.
Everyone agrees that this has occurred, and this fact has been repeatedly stated in the NPROS evaluation reports to the Commission. The issues are whether all plants are
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-2 fully participatino in the NPRD System and, accordingly, whether the industry The data has demonstrated the capability for self-regulation in this area.
available to us does not yet allow us tn share the conclusion that all plants are satisfactorily participating in the NPRD System.
I am hopeful, however, that this goal will be reached, and if it is, I will be pleased to report this milestone in a future semiannual evaluation report.
With regard to our most recent evaluation report itself, evidently you are not aware that the report was not developed by a contractor. We did use a contrac-tor to extract and process the raw data, but the evaluation was perfomed by senior NRC staf f members. This process is the same as that discussed with INPO personnel in the past and is fully consistent with our past agreements and understandings.
Additionally, evidently you are also not aware that the evaluation report to the Comission included your July 25, 1985 letter for information and perspec-tive. Our analysis, however, was based on the specified report period, and thus we comitted to evaluate the "more current" data in our next report.
Finally, we are r.ot aware of any deficiencies in our methodology which would cause these evaluation reports to be "uninfonned" or " misleading." I am told that in past discussions with your staff, no deficiencies in methodology were identified that required changes. However, I agree that additional discussions between our respective staffs would be helpful, particularly to review the INPO data which supports your conclusion that the NPRD System obfectives have beenIn achieved, i.e., all plants are now satisfactorily participating in NPRDS.
the meantime, I believe the NPRDS evaluation reports continue to be needed since they serve a useful function for both of us in focusing our attention on the status of the NPRD System and on the areas warranting further improvement.
Sincerely, pggesWilas1.Ertts William J. Dircks Executive Director for Operations
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ACTl0N FDO PRINCIPAL CORRESPONDENCE CONTROL DtlE t 12/29/86 EDO CONTROL: 002382 FROM DOC DT 12/05/86 FINAL REPLY:
WILLIAM F. CONWAY INPO TO:
STELLO OREEN SECY NO:
FOR SIONATURE OF EXECUTIVE DIRECTOR ROUTINO:
DESC:
STELLO CONCERNS RE SEMI-ANNUAL EVALUATION OF NPRDS ROE PROGRAMS USING A CONTRACTOR REHM SNIEZEK DATE: 12/11/86 AGSIONED TO: AEOD CONTACT: HELTEMES TAYLOR DENTON DAVIS BECKJORD SPECIAL INSTRUCTIONS OR REMARKS:
MURRAY REGIONS REF. EDO 1122
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