ML20209G800

Informs Commission About Approval of Maint & Surveillance Program Plan & Repts on Proposed Interaction Between NRC & Nuclear Utilities Mgt & Human Resources Committee within Program

ML20209G800
Person / Time
Issue date:	04/12/1985
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20209G797	List: ML20209G792 ML20209G800
References
FOIA-85-532, RTR-NUREG-0885, RTR-NUREG-885, TASK-PII, TASK-SE SECY-85-129, NUDOCS 8509190696
Download: ML20209G800 (40)

Text

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POLICY ISSUE (Information)

April 12,1985 SECY-85-129 For: The Commissioners From: William J. Dircks Executive Director for Operations

Subject:

MAINTENANCE AND SURVEILLANCE PROGRAM PLAN

Purpose:

To inform the Commissioners about approval of the Maintenance and Surveillance Program Plan and to report on the proposed interaction between the NRC staff and NUMARC  :

within the Program.

Background:

In response to the Commission's 1984 Policy and Planning Guidance (NUREG-0885, Issue 3), the staff has identified technical and regulatory issues in nuclear power plant S maintenance and surveillance and developed a Maintenance and Surveillance Program Plan (MSPP). The MSPP has been prepared by the Office of Nuclear Reactor Regulation, and has been coordinated with the offices of IE, RES and AE00 in order to integrate all NRC programs related to maintenance and surveillance into a concerted program. The ACRS Subcomittee on Maintenance Practices and Procedures was briefed on the program development on March 14 and May 8, 1984, and the full ACRS received a briefing on l May 11, 1984.

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During the course of the MSPP development, the Nuclear Utilities Management and Human Resources Committee (NUMARC) has been formed. NLNARC has expressed strong interest in the MSPP and, consequently, has been given the opportunity to coment on earlier drafts of the Plan in July and October 1984. NRC management has also met with NUMARC representa-tives on numerous occasions. NUMARC has identified a number of industry activities currently underway or planned which t are related to Phase 1 projects.

Contact:

William T. Russell, NRR 492-4803 g91 6 850906

, PEARSON85-532 PDR l

T,he Commissioners ,

i The MSPP has been revised to respond to NUMARC coments provided by letter dated January 28, 1985. ,

The initial MSPP activities will focus on problem identification and evaluation of industry initiatives to improve plant maintenance and surveillance performance. The intent is to coordinate NRC and industry programs to achieve an accurate evaluation of maintenance program effectiveness and avoid duplication of effort.

. In my January 11, 1985, memorandum to Office Directors and ,

, Regional Administrators. I approved Phase I, " Survey and Evaluation," of the MSPP for implementation. A copy of the Plan is enclosed. A Maintenance / Surveillance Section in the

!. Licensee Qualifications Branch, NRR, has been established.

Discussion: The plant maintenance activities addressed in the MSPP i includes those plant functions required to carry out a i

systematic maintenance program. It extends, therefore,

beyond the conventional corrective and preventive j maintenance and repair to include functions such as surveillance and testing, operations / maintenance interface, ,

maintenance management, procedures, and technical

documentation.

Six technical issues in nuclear power plant maintenance practices were identified on the basis that they are comon i

< occurrences, have no solution at the present time, received I inadequate attention in the past, and may warrant NRC attention in the future. The technical issues are:

i _ Human error in maintenance Indicators of maintenance effectiveness Role of preventive maintenance in counteracting aging and

service wear effects Management and organization impacts on maintenance effectiveness-Maintenance program criteria and standards Maintenance and operations interface

! The MSPP describes a number of technical projects designed

to address the above issues. The Plan has identified i related NRC programs and defined the area and scope of l

interfaces between the programs. In addition to integration l

cf activities within NRC, the MSPP is serving as a vehicle I to coordinate related industry activities of MUMARC. INPO, l EPRI, the standardization organizations (ANS, ASME, IEEE),

l and individual utilities. The Plan places strong emphasis on the industry initiatives.

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. i The Commissioners It recognizes, for example, ongoing industry maintenance assessments being conducted as part of the following INPO activities:

Operating plant evaluations; NTOL plant assistance visits;

• Corporate evaluations and assistance visits conducted in conjunction with operating plant evaluations or NTOL assistance visits; Construction evaluators' reviews of maintenance activities in transition to start-up and testing.

Independent projects include reviews of operating events, analyses of operational and equipment failure data, maintenance procedure writing guidelines, performance indicators, accreditation of training, maintenance workshops, and dissemination of good practices.

Also, the recent initiatives enumerated by NUMARC for maintenance (described in i 3.4 of the enclosure) have been coordinated with staff activities. The planned near-term industry initiatives and related staff activities are sumarized below:

1. Maintenance Performance Indicators NUMARC has developed 10 performance indicators in order to monitor and trend industry performance in the maintenance area. Industry plans are to initiate data collection through INPO and to begin monitoring, trending and publication of selected indicators in 1985 using 1984 and 1983 data as a baseline. At present, the industry has described an intent to use the performance data only for analysis of trends and comparisons between similar plants. This would result in sumary statistics describing industry averages (medians) for like categories of plants but would not identify specific plant performance indicators for comparison to the median.

The staff plans to initiate a project which complements the industry effort. The staff efforts in this area are: (1) To independently assess the progress of industry in maintenance through the data provided to INP0. A special NRC Task Force has reviewed the industry indicators during their development and determined that the indicators could play an important assessment function provided the validity'and reliability of the indicators can be confirmed by the NRC. Accordingly, staff efforts during 1985 would concentrate on assessing the validity and reliability of the data collected as well as the analyses performed by i

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, 7he Comissioners INPO to derive sumary statistics of industry maintenance performance; and (2) Continue development of a multivariate model for deriving indicators of plant maintenance effectiveness which would be useful in predicting overall plant perfomance. The staff has already completed significant preliminary research to demonstrate the feasibility of such a model. Data provided through the industry indicators work would allow further development and verification of the model in the most efficient manner. To date, industry has not proposed any similar analytical effort for deve!.mug an overall quantitative assessment tool for plant performance.

Fundamental to the successful completion of the staff ,

efforts in this area is access to industry generated data on a plant-specific basis. If this cannot be achieved, the staff would need to collect data directly from plants to complete its efforts. This would probably entail collection of data on fewer indicators than NUMARC/INPO but some duplication would be necessary.

- 2. Evaluate Maintenance Performance Trends Near-term industry plans to evaluate maintenance performance trends are not specifically defined at this time. However, the means available for this type of activity include (a) the use of indicators, as described j above, to compare similar plants and (b) the continued i use of plant evaluations and assistance visits to evaluate individual plants' maintenance performance.

The NRC maintenance and surveillance program includes a i project to survey the current status of U.S. nuclear power plant maintenance using field visits and analyses '

of operational data. The survey will provide an

- assessment of the present status of maintenance programs

! existing in the industry as well as baseline data for assessing improvements in plant maintenance. In addition,. assuming the industry data being collected for maintenance indicators can be made available to the NRC, the staff plans to conduct statistical correlations between indicators of plant maintenance performance and indicators of safety.

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3. Maintenance Training Programs f

Near-term industry efforts to improve maintenance '

training programs by INPO accreditation of instrument and control, electrical and mechanical maintenance l

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, The Comissioners 1 personnel are beginning. Presently one station instrument and control personnel training program has i been accredited and seven utility self-evaluation reports for maintenance training have been submitted to INPO in 1984. The staff's primary activities are to monitor the effectiveness of the accreditation program as it continues in 1985 by performing independent reviews of training programs in accordance with the Policy Statement on Training and Qualifications. The staff also plans research using job and task analysis data to determine requisite maintenance personnel knowledge and skills for job performance.

- 4. Conduct Maintenance-Related Workshops INPO maintenance-related workshops are an igartant adjunct to an industry-wide maintenance improvement program. INPO-sponsored maintenance superintendents' I workshops and other participative workshops are an important vehicle for dissemination of experience data regarding maintenance effectiveness. The staff has participated in INPO workshops and has found that they are a major forum.for industry comunication and technical problem-solving. The NRC will continue to encourage these activities.

l 5. Maintenance Standards Activities Industry plans to participate in maintenance standards

! activities and to further develop INP0 guidelines and 4 good practices in maintenance. The staff considers development of national standards being initiated by ANS, IEEE, ASME, and ASQC to be important means of prescribing technical maintenance program improvements.

i The staff currently has representatives participating in all standards activities related to maintenance. NRC endorsement of industry-developed standards, guidelines, and good practices will be evaluated during Phase II of the MSP as one alternative for achieving maintenance

- program improvements. INPO, NRC, and EPRI have all sponsored development of maintenance guidelines documents. Guidance in the area of maintenance procedures, job-performance aids, personnel qualifications, and specific equipment or system i maintenance is currently under development by INPO and EPRI.

6. Plant Evaluations INPO has added criteria for maintenance to their plant evaluation performance objectives and criteria. The I

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, t The Comissioners maintenance evaluations are conducted at scheduled intervals as part of the evaluations for each operating plant as well as for near-tem operating license plant assist visits and corporate evaluations. Maintenance is also evaluated during INP0 construction project evaluations. Reports with findings and recomendations for improvement are provided to utility management.

Follow-up is conducted to check on progress and attainment of improvements.

The NRC observes the progress of INPO plant evaluations via the Performance Appraisal Team program in accordance with an NRC/INP0 memorandum of understanding. The staff will continue to coordinate with and participate in IE and Regional inspections of plant maintenance.

The staff is continuing to negotiate specific arrangements l with NUMARC about the sharing of data and information useful for the development, validation, and use of perfomance indicators. Other NRC and NUMARC initiatives, as described above, are complimentary efforts which will ,

allow the NRC to collect data and monitor industry progress while INPO and NUMARC develop and disseminate specific technical infomation for implementation of effective maintenance activities.  !

To accomplish the objectives of the MSPP, a phased approach was selected. A senior management review and evaluation period is scheduled at the conclusion of each phase in order to provide feedback on results and to redirect the program if needed. Phases I and II of the Maintenance Program have the following objectives:

Phase I. Survey and Evaluation - to describe the current  ;

status of maintenance in the industry by surveying present '

maintenance practices and evaluating their effectiveness.

Phase II. Identification of Maintenance Problems and Impact on Safety - to define the role of maintenance in safety, develop recomendations for good practices, and encourage i the development of industry standards. i

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. i The Commissioners Recommendation: The staff will inform the Commission at the end of each 4 phase of progress made toward resolution of the above MSPP technical issues and the staff's views on the effectiveness of NUMARC's activities.

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William . Dircks Executive Director for Operations

Enclosure:

Maintenance and Surveillance Program Plan 1

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s MAINTENANCE AND SURVEILLANCE PROGRAM PLAN s

i U.S. NUCLEAR REGULATORY COMMISSION APRIL 12, 1985 O

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% h TABLE OF CONTENTS Page

1.0 INTRODUCTION

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1.1 PURP0SE......................................................

1.2 BACKGROUND

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2.0 DESCRIPTION

OF THE PR0BLEM........................................ 3 2.1 DEFINITION AND SC0PE......................................... 3 2.2 PROBLEMS AND OBJECTIVES...................................... 3 2.3 REGULATORY ISSUE............................................. 4 2.4 TECHNICAL ISSUES............................................. 4

. 3.0 PLAN FOR PROBLEM RESOLUTION....................................... 8 3.1 MAINTENANCE AND SURVEILLANCE PROGRAM STRATEGY................ 8 3.2 MAINTENANCE AND SURVEILLANCE PROJECTS (PHASE I)............. 12

.3.3 RELATED PR0JECTS............................................ 16 3.4 INTERACTIONS WITH OUTSIDE ORGANIZATIONS..................... 29

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1.0 INTRODUCTION

1.1 PURPOSE l

The purpose of the Maintenance and Surveillance Program Plan (MSPP) is to provide direction for the NRC's efforts to assure effective nuclear power plant maintenance and surveillance and to do so in a manner that is consistent with and responsive to the Comission's 1985 Policy and Planning Guidance (NUREG-0885, Issue 4).

The Program Plan describes the problems and issues to be addressed and proposes development of alternative NRC approaches to regulating nuclear utility maintenance activities consistent with the Policy and Planning Guidance. The plan addresses those plant functions required to carry out a systematic maintenance program.

It includes, therefore, corrective and preventive maintenance and repair; surveillance and testing; operations / maintenance interface; maintenance management; procedures; and technical documentation.

1.2 BACKGROUND

1 The NRC's current regulatory approach to nuclear power plant maintenance is embodied in requirements for (1) quality assurance

. (QA) during design, construction, and operation for structures, systems and components to an extent consistent with importance to safety (10 CFR 50, Appendix B), and (2) surveillance requirements to assure that the necessary quality of systems and components is maintained (10CFR50.36). Despite these' requirements, the NRC's rules and regulations presently provide no clear programatic treatment of maintenance.

Many challenges to safety systems originate from systems and components which are not classified as safety-related. The principal contribution of maintenance and non-safety related activities to safety system performance will be addressed as part of the overall approach to maintenance improvement.

Faulty maintenance practices are a principal contributing factor to operating abnormalities. Preliminary estimates by the staff l indicate that aside from design deficiencies, more than 35% of the l nuclear power plant abnomal occurrences reported to Congress since 1975 may be directly attributed to maintenance factors, with the trend increasing as more plants become operational.

Reviews of operating experience by the staff show a high frequency of degraded system performance due to both the lack of maintenance (especially preventive maintenance) and improperly perfomed maintenance, including human error during repair and surveillance testing.

A recent AEOD study concluded that 70% of events involving wrong unit or wrong train were attributable to human error during 1

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2 maintenance (including surveillance and testing). The types of i maintenance errors described by Licensee Event Reports (LERs) and the Nuclear Plant Reliability Data System (NPROS) include such human maintenance errors as: failure to follow procedures; installing electrical connectors incorrectly; mounting equipment (e.g., check valves) backwards or out of alignment; using the wrong parts in equipment repair; removing from service and working on the wrong system or component; misaligning valves after maintenance; and failing to remove lockwire from critical switches after service.

The impact of maintenance on plant safety was illustrated by an engineering evaluation of a stuck open isolation check valve on the

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residual heat removal system at an operating boiling water reactor (BWR). Human error during maintenance resulted in a safety problem when the maintenance error was not discovered during postmaintenance testing nor during routine surveillance of control room position indication for the component. The safety significance of the undetected error increased the probability of aninterfacingLOCAfgrtheplant. The probability of the LOCA was estimated to be 2x10- during this period of four months whi errorwasundetectedascomparedtoanormalestimateof10~}ethe per reactor year. This is considered to be a substantial reduction in safety margin caused by a maintenance error.

Over the last two to three years, the NRC has initiated several studies demonstrating problems in nuclear power plant maintenance i activities. For the most part, studies have been conducted or

! sponsored by various NRC offices (e.g., Research; Analysis and Evaluation of Operational Data; Nuclear Reactor Regulation) with little or no coordination and no integrating programatic framework i for maintenance issues. To date, this has resulted in a fragmented effort that does not address all the relevant issues and may be duplicative in soria respects.

This Maintenance and Surveillance Program Plan is intended to r

integrate and plan the staff's maintenance activities, and responds

to the Commission Policy and Planning Guidance (NUREG-0885, Issue 4) goal to encourage a high level of quality in reactor I design, construction, operations, and maintenance and to understand l the causal factors leading to problems.

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2.0 DESCRIPTION

OF THE PROBLEM 2.1 DEFINITION AND SCOPE The scope of the Program Plan includes the entire maintenance process. Maintenance as a process is defined herein as a function

' with the objective of preserving the reliability and safety of plant structures, systems and components which provide assurance that the plant can be operated without undue risk to the health and safety of the public and/or restoring that reliability when it is degraded. As such, the senpe encompasses those components which may affect the performance of safety systems.

I For the purposes of this plan, maintenance and surveillance include (a) diagnostic or period.ic testing, calibration and inspection to detemine the condition of structures, systems and components, (b) preventive or corrective actions such as repair, replacement, lubrication, adjustments, or overhaul; and (c) proper removal of equipment from service, restoration to service, and post j maintenance testing. Maintenance is perfomed during all modes of plant operation by plant staff, vendors, or contractors.

It is not the intent of this Maintenance and Surveillance Program Plan to address the technical problem of how to maintain a particular component (e.g., a pump, valve, pipe or steam generator) but rather to consider the progrannatic aspects of maintenance.

The objective is to identif maintenance effectiveness (y the e.g., factors that procedures, contribute training, and to management) and how they may best be integrated into a functional

maintenance program.

2.2 PROBLEMS AND OBJECTIVES i

These problems or combination of problems exist at some plants.

Other plants appear to have effective, well run maintenance l programs. The maintenance safety problems and the objectives being addressed by the plan consist of the following:

1. There is indication that needed maintenance is not being accomplished or is not performed effectively. The objective is to determine the effectiveness of current nuclear power plant l

maintenance programs, to detect the causes and effects of equipment performance degradation, and to identify corrective ]

action to minimize equipment failures and unavailability.

2. Many failures result from improper perfomance of maintenance. f The objective is to reduce failures from improper maintenance I by identifying the fundamental causes of human maintenance errors, by identifying practices which reduce the error rate and which increase the probability of error detection prior to i

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3. The interface between maintenance and operations is presently inadequate. The objective is to determine the causes of poor coordination among activities, to assure proper integration of maintenance, operations and other organizational interfaces for ,

maintenance activities.

l 4 The number of maintenance-related challenges to safety systems is excessive. The objective is to determine the causes of the high rate of challenges and improve the effectiveness of nuclear power plant maintenance programs in assuring l operability of safety systems.

5. A major portion of occupational radiation exposure (over 75%)  :

and many radiological hazards occur to personnel perfoming maintenance activities (NUREG-0713). Improved planning and  !

control of maintenance activities may significantly reduce 1 I

occupational exposure to as much as half cf the present exposure. The objective is to assure that by performing preventive and corrective maintenance in a nlanned and i optimized manner, the unnecessary and unanticipated radiological exposure of maintenance personnel will be reduced. i 2.3 REGULATORY ISSUE E

I The regulatory issue to be addressed is deciding on an NRC approach to assure effective maintenance performance.- Several alternative ,

i approaches are being considered. They are:  !

L NRC monitoring and endorsement of. industry activities and  !

initiatives to improve maintenance effectiven'ess~(e.g.,

j INPO or national standards development activities)

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i NRC guidance in the form of Policy Statements, Regulatory l l

Guides, or regulations to ensure maintenance effectiveness in l

! the U.S. nuclear power industry; or Some combination of the above alternatives.  ;

2.4 TECHNICAL ISSUES Resolution of several technical issues will be accomplished by a program to provide data and methods for evaluating industry l maintenance. These technical issues are:  ;

1. Human Error in the Performance of Maintenance Operatorsandmaintenancepersonnel(inaboutequalproportion) account for about 2/3 of all human error incidents resulting in I

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LERs. Many maintenance errors have had serious safety consequences. Most of these errors result'from poor human factors design of plant equipment, inadequate procedures, and/or insufficient per:onnel qualifications and training. Although Probabilistic Risk Assessment (PRA) studies have treated human error, it is difficult to quantify the '

impact'of human error in maintenance on risk, and to assess the effect of proposed changes to reduce the incidence of human error in the perforinance of maintenance. Consequently, there are no currently acceptable criteria for determining the ,

optimum methods for reducing human errors occtrring during maintenance activities.

2. 'Ir.dicators of Maintenance Effectiveness i

Measures of maintenance effectiveness may include indices of the effects of aging, the frequency of reactor scrams or safety system challenges, equipment perforinance data, SALP ratings, plant housekeeping, reportable human errors in maintenance, and work force man-rem expcsure. However, the NRC has not, as yet, identified valid and reliable measures of maintenance effectiveness. It is believed that multiple measures may provide an accurate picture of plant maintenance effectiveness l .since factors such as management and organization, personnel selection and training, and procedures all affect maintenance performance. There is a need to develop methods of measuring maintenance effectiveness of individual utilities (neededtoidentifyplantswithpoormaintenance histories) and to compare maintenance perforinance across the nuclear utility industry as a whole (needed for feedback on effectiveness of regulatory and industry initiatives). If NRC elects to rely heavily on INPO programs to upgrade maintenance

- performance in the industry, a measurement methodology to determine maintenance program improvement or lack of improvement is needed. An NRC Task Force will review and f L

evaluate industry progress in developing the maintenance indicators proposed by NUMARC. Independent review of operational data, trends, and analyses may be necessary to evaluate industry progress. In addition, means of determining acceptable levels of human error for maintenance activities are needed.

3. The Role of Preventive Maintenance in Counteracting Aging and Service Wear Effects The degradation of operational characteristics and reliability of plant systems with age and service wear needs to be documented and expressed in quantitative terms or by performance trending. The appropriate resolution of the aging issue depends on answers to some basic questions: (a) what aging effects are likely to impair plant safety; (b) what i

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i methods of testing, calibration and inspection will be effective in detecting system degradation due to aging prior to the loss of the system function; and (c) what is the appropriate mechanism for implementing remedial actions identified from testing, surveillance, and inspection? It is likely that a partial resolution of the aging issue will determine the appropriate role of preventive and corrective maintenance programs in detecting and correcting aging and service wear effects in selected electrical and mechanical components.

Significant technical questions must be resolved to ensure the effectiveness of a preventive maintenance program in enhancing safety. These questions include: (a) what are the components to be maintained; (b) what type of maintenance is to be perforined (e.g., replace components, overhaul, etc.); and (c) what is the appropriate schedule for each maintenance action?

4. Management and Organization Impacts On Maintenance Effectiveness Management practice and organizational structure have an important bearing on performance of an organization. Proper management of maintenance has been cited as an essential element of an effective maintenance program (NUREG-1000). The j NRC currently does not pursue extensive identification and  ;

analysis of management-related maintenance problems. There  !

also appears to be insufficient means to document and disseminate lessons learned and to objectively compare maintenance performance in the industry. Management comitment to improved maintenance and dissemination of effective ,

maintenance practices and industry experience are needed.

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5. Maintenance Program Criteria and Standards l

Many effective maintenance practices have been identified from j programs which have resulted in improved reliability and l

performance in other industries such as the FAA and the 1 military. Also, the nuclear industry has begun to document some effective maintenance practices, e.g., EPRI's maintain-

ability guidelines. There is a need to identify acceptable maintenance practices for application to plants with poor maintenance histories and for guiding routine NRC inspection, i

Standards and criteria for maintenance practices are needed for generic application and for development of improved inspection methods.

The national standards organizations, such as IEEE, ASME, ANS, or ANSI, presently do not have comprehensive standards on maintenance for industry use in developing effective l- - - .. . . . . . - _ _ . - . . . . . _ . -_

' l 7-maintenance programs. Industry self-regulation through such standards could create a common reference for maintenance practices. With such standards NRC regulatory activities could focus on developing approaches such as review guidance, revised inspection modules, or statements of good practices as general guidance documents.

6. The Maintenance and Operations Interface Safety-related systems are sometimes taken out of service or bypassed during surveillance testing and maintenance. Errors in surveillance testing and maintenance have resulted in the wrong equipment being taken out of service or in continued unavailability of equipment following maintenance or testing due to a failure to properly return equipment to service.

The proper integration of maintenance and operations is needed to verify correct performance of activities and reduce human errors. The provision of accurate information for monitoring the status and availability of systems and equipment before, during, and following raintenance may reduce operational as well as maintenance errors. Interactions among operations.

maintenance, and radiation protection personnel in planning and preparing for maintenance work are important in ensuring that exposures to' maintenance' workers are as low as reasonably achievable (ALARA). Means of identifying and optimizing important areas of interaction between maintenance and ,

operations are needed.  ;

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3.0 PLAN FOR PROBLEM RESOLUTION 3.1 MAINTENANCE AND SURVEILLANCE PROGRAM STRATEGY Resolution of the technical and regulatory issues will be ,

accomplished by a number of projects conducted in phases. In many instances, fundamental work needs to be completed which addresses portions of several issues. For example, a reliable measure of maintenance performance effectiveness is required for the resolution of issues related to management and organization impacts, maintenance criteria and standards, and the maintenance and operations interface.

- The Maintenance and Surveillance Program will be conducted in phases to provide for EDO interim evaluation of results and reconsnendations prior to initiation of additional activities. The phased approach will also provide the industry an opportunity to take an active role in identifying and proposing solutions to maintenance problems.

The initial program consists' of two phases, as shown in Figure 3.1:

Phase I Survey and Evaluation

• Phase II Identification of Problems and Impacts [

i The objectives and expected products to aid the EDO evaluation at  !

each phase of the program are as follows: -

Phase I: Survey and Evaluation of Maintenance Effectiveness i Objective: to survey current maintenance practices in the nuclear .

industry and to evaluate their effectiveness.  !

Expected products:

Description of cur: ent industry practices in maintenance and surveillance and methods for NRC use in assessment of plant maintenance effectiveness Preliminary objective indicators of maintenance performance effectiveness Survey and comparison of Japanese and U.S. nuclear power plant maintenance Staff assessment of industry maintenance program effectiveness

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, , FIGURE 3.1 PROGRAM PHASES PROGRAM  ?>

INITIATION / A YEAR 1 YEAR 2 . YEAR 3 QUARTER 1 2 3 4 1 2 3 4 1 2 3 4

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Phase I Survey and Evaluation ^ A l

EDO Review AA -

Phase II Identification 8

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of Problems and l {

Impacts l^ ^ A:

EDO Review AA $A l l l

_ Industry Efforts ~ {

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INPO A k E EPRI e

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Description of maintenance job performance requirements and requisite maintenance personnel qualifications Descriptien of in-service inspection methods and human error potential

• Identification of factors contributing to wrong unit / wrong train human errors Participate in industry standards committees to initiate maintenance standards develcpment activities Recommendations for subsequent maintenance program activities Phase II: Identification of Maintenance Problems and Impact on Safety Objective: to identify distinct maintenance problem areas and determine their impact on plant safety and worker dose.

Expected products:

Data to support a definition of the scope of HRC concern and prioritization of individual maintenance problems Technical information to determine the contribution of maintenance human errors to risk and necessary corrective actions Validated indicators of maintenance effectiveness related to plant safety Assessment of data to determine plant maintenance effectiveness Survey and comparisen of foreign nuclear power plant maintenance Recomendations for endorsement of good maintenance practices Input to draft industry standards for maintenance 1

Staff assessment of industry progress in self-improvement '

Recommendations for further NRC action Coordination with other NRC offices will be necessary to utilize results of planned and ongoing activities related to maintenance and its impact on safety. Human factors research and other related projects are shown in Figure 3.2, emphasizing milestones ano their anticipated integration into the maintenance and surveillance program. Vertical arrows on Figure 3.2 show where related project results will be utilized. Interim products of planned activities will provide data to evaluate the safety impact of maintenance problems and improvement strategies early in the Maintenance Program.

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FIGURE 3.2 - MSP MILESTONES AND INTERACTIONS

• Program --PHASE I + < PHASE II y <

Initiation 12 Mo . 24 Mo 36 M OHFS PROJECTS l

^ '^ I SURVEY OF CURRENT PRACTICES ^ +^--- - - - - - (A. - - - - - - lA DEVELOPMENT OF MAINTENANCE PERFORMANCE INDICATORS ^ ^ --- - - - - - 8A- - - - - - JA MONITOR INDUSTRY ACTIVITIES ^ *^ -- - - - - - 6.A. _ ___ 6A

'A PARTICIPATE IN STANDARDS GROUPS -^ *^ '^

TECHNICAL SUPPORT / PROJECT INTEGRATION ^ 'A i I

' l ANALYSIS OF JAPANESE /U.S. NPP MAINTENANCE PROGRAMS --

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8 '^ l I MAINTENANCE PERSONNEL QUALIFICATIONS ^ ' '^

HUMAN FACTORS IN IN-SERVICE INSPECTION (NRR/RES) ' g l 8 MAINTENANCE & SURVEILLANCE PROBLEMS SPECIFICATION ^  :

^ O (TECHNICAL PROJECTS IN PHASE II)

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L *l WRONG UNIT / WRONG TRAIN g .

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A QUALITY ASSURANCE ^' '^l 4A SAFETY IMPLICATIONS OF CONTROL SYSTEMS (USI A-47) t;6 i 44 l TECHNICAL SPECIFICATIONS RESEARCH ,

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i TECHNICAL SPECIFICATIONS IMPROVEMENT PROJECT ^ "* I'I N; NPP AGING I* ^' ' I A

EFFECTIVENESS OF INDUSTRY ALARA PROGRAMS EQUIPMENT QUALIFICATION 0- - - - - 'dI ^L- - - l- M- A -IA'h- - - --

l ' ^ *- - - - h - -- - - - RELIABILITY PROGRAM TRAINING AND QUALIFICATIONS -

indicates input into MSP indicates MSP input to related programs

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. s 3.2 MAINTENANCE AND SURVEILLANCE PROJECTS (PHASE I)

The projects described below are intended to provide the technical basis for developing an NRC position on maintenance, to provide measurement techniques for use in evaluating maintenance programs of licensees and license applicants, and to provide a basis ter licensing decisions relevant to assuring adequacy of maintenance.

The following human factors projects will support development of the Phase 1 objective.

3.2.1 Survey of Current Maintenance Practices The objective of this project is to assimilate data for assessing the present status of maintenance in the nuclear industry and to develop a method to describe the performance of the maintenance programs at nuclear power plants.

Several sites (e.g., one in each Region) will be selected for evaluation by a team to determine the maintenance program effectiveness. The reviews will (1) ' provide baseline data as reference for the assessment of future developments due to implementation of new or revised maintenance practices, standards, etc., and (2) identify areas where improvements in maintenance programs are most

. needed to enhance. safety of operation.

This project will also include a review and analysis of inspection reports for operating reactors, development of a classification scheme for identtfied problems, and identification and review of additional information needs and sources (e.g., AE0D analyses, IMPO evaluations, PAT inspection reports) in order to identify the characteristics of current maintenance programs and practices in the U.S.

nuclear power industry.

The development, implementation, and the effectiveness of the preventive maintenance program at Salem will be evaluated as an example of a recent licensee response to a requirement for maintenance. Other industry experience with and need for preventive maintenance will be compared with the Salem progrse. As a result, important factors influencing the success of a preventive maintenance program will be identified.

A maintenance review protocol will be developed for direct assessment of licensee maintenance performance using, e.g.,

a workbook, chccklist, or other evaluation tool for NRC use.

Input to development of this protocol will be the experience gained from surveys of current maintenance practices. The objective is to determine licensee maintenance performance effectiveness and response to maintenance program

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f improvements. The measurement techniques developed in this task will be validated with site visits and appropriate i analyses.

3.2.2 Maintenance Performance Indicators  !

Objective and quantifiable variables will be identified for

' use in determining maintenance effectiveness as it influences safety. Preliminary investigations of plant performance safety indicators have shown that multiple variables may be selected which in combination, indicate the effectiveness of a nuclear utility's maintenance practices. '

The development of maintenance safety indicators will build upon preliminary analyses of variables to derive a set of indicators which may be used to describe industry

! maintenance performance, compare plant maintenance effectiveness, and assess maintenance trends and patterns.

This task will provide further baseline data as reference for industry progress in maintenance program improvement.

Alternative data sources and methods will be evaluated for applicability to maintenance performance assessment. A Task Force will be used to review and evaluate industry initiatius in developing and using maintenance performance indicators. Data and information from an industry survey beir.g conducted by INPO to develop maintenance performance

indicators will be evaluated for use in trending industry '

maintenance effectiveness.

3.2.3 Monitor Industry Activities

! Throughout all phases of the Maintenance and Surveillance -

Program, the NRC will monitor industry progress and experience in developing strategies for improved maintenance. Coordination with INPO will be necessary to monitor the effectiveness of the INP0 plant evaluations, accreditation of training, and good practices in enhancing maintenance performance in the nuclear industry. '

Implementation of EPRI pidelines and the results of industry initiatives wi 1 be monitored and their impact assessed. In addition, industry activities such as standards development and data reporting will provide input to the NRC development of performance measurement methods, guidelines, and criteria for maintenance and surveillance.

3.2.4 Participate in Standards Groups During all phases of the maintenance program, NRC representatives are encouraging and plan to participate in j development cf industry national standards for maintenance by IEEE, ASME, ANS and ANSI groups. Industry standards are

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perceived as a means of promoting maintenance program improvements without NRC regulation. NRC endorsement of industry standards will be considered during the maintenance program. L 3.2.5 Maintenance and Surveillance Program Integration Numerous projects sponsored or monitored by DHFS as well as by other NRC offices and industry groups are expected to produce data and information which is necessary to evaluate the safety significance of maintenance problems and i potential solutions. The purpose of this project is to as well as to review, evaluate and

- coordinate integrate the resu planning!ts of multiple projects in crder to i develop appropriate conclusions and make reconsnendations ,

based on available technical information. The results of -

the survey of current maintenance practices, plant maintenance reviews, and maintenance indicators investigations will be reviewed and assimilated to provide I conclusions and reconsnendations for maintenance program

improvement strategies and subsequent maintenance program plan activities.

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3.2.6 Analysis of Japanese /U.S. NPP Maintenance Programs

, This project involves a comparison of U.S. and Japanese r nuclear power plant maintenance programs in the following L

] areas: the differences in U.S. and Japanese NPP operating j

! experience, the organization and management of NPP maintenance in Japan, and the comparison and contrast of Japanese and U.S. preventive maintenance requirements. The i i

results of this project will be utilized in Phase II to l provide technical inputs as an aid to determining the >

appropriate balance between the requirements for surveillance testing and preventive maintenance. }

! 3.2.7 Maintenance Personnel Qualifications I

The purpose of this research project is to identify from job and task analysis data, the knowledges, skills, and

abilities required for the duties of electrical, mechanical, instrumentation and control, and supervisory maintenance-personnel. The pertinent education and vocational training backgrounds as well as any aptitudes which prov*de the appropriate knowledge, skills. and abilities will be determined. The goal is to determine the appropriate

, maintenance personnel qualifications for use in developing l

standards and by which to assess current induster practice

in ensuring the qualifications of maintenance personnel.

l The results of this project will be utilized in Phase II of i

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the Maintenance Program to provide infomation about the i present level of maintenance personnel skills and the

! necessary personnel qualifications, i.e., knowledges, skills, and abilities, for correct performance of maintenance tasks. The results of this research will be used to detemine format, content, and use of job performance aids as means of improving maintenance personnel performance.

f 3.2.8 Human Factors in In-Service Inspection (ISI)

NRC regulations (10 CFR 50.55a(g)) require that nuclear power plants have an effective ISI program in place. With respect to maintenance requirements ISI programs may not i provide sufficient data to support an effective preventive maintenance program.which requires considerable data on i equipment history and operation. Therefore, in order to obtain sufficient objective infomation to detemine the practicality of trade-offs between ISI requirements and predictive / preventive maintenance requirements, a feasibility study investigating ultrasonic testing (UT)

, techniques and associated human error potential will be performed. This project will be conducted in conjunction with the RES-sponsored program titled " Integration of NDE Reliability and Fracture Mechanics." Identification of 3

probable sources of human factors problems contributing to l ineffective UT/ISI processes and the need for and scope of

subsequent studies will be detemined during Phase I. i 3.2.9 Human Error in Events Involving Wrong Unit or Wrong Train (Generic Issue 102)

In January 1984, the Office of Analysis and Evaluation of Operational Data (AEOD) issued a special study report describing a number of events that resulted from human error' [

in removing equipment from service or restoring equipment following maintenance that involved the wrong unit or wrong train of equipment being rendered unavailable. Although the scope of the study was narrow, AE00 found that 19 out of 27 events identified resulted from human error during maintenance and surveillance testing. AE00 considered such events to be examples of events that could have high safety significance due to potential loss of safety system functions. Two Office of Inspection and Enforcement Infomation Notices (84-51 and 84-58) have been issued to alert licensees to the potential safety problem arising from wrong unit and wrong train personnel errors.

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The NRC will initiate short term action to identify existing 1 l practices that may lead to human errors involving wrong unit / wrong train and to recomend simple, low-cost improvements that may be appropriate. NRC will review operating experience, conduct site visits and interview licensee personnel of a select number of plants to determine

- the extent and nature of loss of safety function resulting from errors involving the wrong unit / wrong train.

The Maintenance and Surveillance Program will investigate the safety significance of personnel errors occurring during maintenance and surveillance testing during Phase II of the i Program. The survey of maintenance practices at U.S.

nuclear utilities and the review of operational errors and events during Phase I will identify factors (i.e.,  ;

labelling, procedures, training) that may contribute to human error involving wrong unit / wrong train. At the end of Phase I, the Maintenance Program will identify actions for  ;

resolution of the Generic Issue or for further investigation.

f 3.3 REl.ATED PROJECTS Related ongoing and planned projects have been identified which may provide technical data and other products useful to the maintenance and surveillance program. A listing of related projects in NRC

offices and industry organizations is given in Table 3.1. A description of the interfacing programs extends only to those elements that are related to the maintenance and surveillance program; it must be noted that the scope of these programs encompasses other objectives as well.

Although sufficient information has been developed to initiate

! Phase I projects, detailed milestones and interfaces have not been identified for all related NRC and industry programs. Specific project details are being coordinated with other offices and may i result in the need for changes or modifications to project j schedules to provide interim products as apnropriate.

Major programatic responsibilities for NRR include projects to measure maintenance performance, assess industry developments and <

scope NRC activities, with DHFS having lead responsibility. These goals are related to DHFS activities concerning maintenance j indicators, assessment methods, maintenance practices, personnel l

qualifications, and foreign experience in maintenance.

Coordination with IE is necessary for projects related to the evaluation of importance to safety issues and QA program impact on maintenance standards and criteria development. Participation of IE headquarters and Regional staff with NRR staff to evaluate i

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licensee maintenance performance and monitor industry programs is ,

envisioned. Inspection data will be an important source of 1 information for Phase I projects.

Coordination with RES will provide support for progran elements to review surveillance and Technical Specification requirements and investigate reliability methods and their applicability to maintenance programs. The projects described below have been identified as important interfaces for the Maintenance Program. ,

DRA0 will coordinate ongoing and planned activities to support these program elements. The Nuclear Plant Aging Research of RES/DET will provide information related to the role of maintenance in counteracting the effects of plant aging and make recommendations as appropriate for criteria and standards development for selected electrical and mechanical components.

AEOD will support IE and NRR review of licensee operating experience related to maintenance. LER data will be an important source of data for measurement of maintenance performance effectiveness. ,

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O -6 TABLE 3.1 RELATED PROGRAMS Responsible Organization NRC Quality Assurance Program Plan IE/9]ASIP Safety Implications of Control Systems (USI A-47) NRR/ DST (RES)

Technical Specifications Research NRR/DL (RES)

Technical Specifications Improvement Project NRR/ DST Nuclear Plant Aging Research RES/DET Effectiveness of Industry ALARA Programs NRR/DSI (RES)

Equipment Qualification - R.G. 1.89 NRR/DE Reliability Research RES/DRA0 Training and Qualifications of Personnel NRR/DHFS Industry Maintenance Activities Coordination NUMARC

. Standards ANS, ASME, IEEE, ASQC Plant Evaluations INPO NPRDS, SEE-IN INPO haintenance Superintendent's Workshops INPO Good Practices INPO Accreditation of Training INPO Maintainability Caidelines EPRI Reliability Centered Maintenance EPRI Personnel Selection EEI

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! l l 3.3.1 Quality Assurance Program The goal of the NRC is to assure a high level of quality in

management of reactor design, construction, operations. and maintenance. The NRC policy with respect to improving the quality of nuclear plants is to (1) assure utilities provide the appropriate management framework and capability for safe operation and maintenance of nuclear plants; i (2) to improve quality in utility operations and in i procedures, systems, and components used in operations; and (3) to develop better guidance for the treatment of plant i systems, components, and equipment that can adversely affect safe operation (Program Guidance, May 1984).

l The draft of the NRC's Quality Assurance Program Plan, developed by IE, was completed in October 1984. Several j major initiatives of the QA Program are anticipated to have important implications for Maintenance Program activities.

These include:

l

• development and use of QA performance indicators and trends for assessing the effectiveness of QA programs; the NRC inspection program (including.IE team inspections

( and agency SALP reviews);

QA/QC personnel issues;  !

revision to quality assurance standards (e.g., Regulatory Guide 1.33); and the important to safety issue and development of improved methodology for identifying and classifying systems, structures, and components. .

Use of performance indicators for assessing effectiveness of QA programs as well as revisions to NRC inspection programs are expected to involve revisions to or development of new inspection modules or techniques for assessing licensee performance. IE is working with WPPS to develop and implement a pilot program for this project at WPN-2.

Indicators of maintenance performance will be included in the program. The Maintenance and Surveillance Program, Phase I activities, will provide assessment methods and preliminary indicators of licensee maintenance performance elements which may be applied. Information from IE assessments of licensee maintenance performance from routine inspections, SALP reviews, and PAT inspections will provide information about the current status of maintenance e

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performance in the industry. These data will be used as one i source of information in order to develop techniques for objectively assessing licensee maintenance performarce during Phase I of the Maintenance Program.

The Maintenance Program project to study the qualifications ,

of maintenance personnel may have implications for the i qualifications of plant QA/QC personnel. Results from the l research project will be provided to IE for use in their study of personnel issues.

Revisions tn the QA/QC standards (i.e., Regulatory Guide 1.33) as part of the IE QA Program will likely involve coordination with IE for Regulatory Guide modifications.

1" IE plant surveys for the important to safety issue will be an important source of information for Phase I of the Ma'ntenance Program. IE has visited several utilities to i ex mine their overall approach to ensuring quality in nonsafety-related systems and activities. The IE surveys will provide data regarding plant practices in maintaining equipment important to safety. The scope of the Maintenance Program concerns maintenance of systems and equipment regardless of classification. The agency policy regarding systems and equipment important to safety will help to determine the scope of regulatory concern for maintenance.

The nature and safety significance of maintenance problems identified during Phase 11 may also clarify the definition of important to safety in terms of risk. For each of the QA program projects described above, working contacts have been established between IE/QAB and NRR/DHFS. ,

! 3.3.2 Safety Implications of Control Systems (Unresolved Safety Issue A-47)

The Division of Safety Technolony (DST), Generic Issues Branch (GIB), is the lead organdzation for this unresolved 1

safety issue. The project identifies nonsafety grade

! control systems in which a failure or malfunction could have l significant impacts on plant safety. The study is i designed to identify the control systems that are important to safety, to conduct computer simulations to determine the effects of failures, to evaluate licensee responses to relevant regulatory actions, and to propose criteria or i guidelines to improve the reliability of nonsafety grade systems.

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4 Areas of Interaction The investigation of the unresc1ved safety issue will be utilized in Phase II of the MSP to determine the safety significance of maintenance practices and problems.

The defini, tion and criteria used to identify systems that

are not safety grade, but have important impacts on

safety, will be considered in maintenance programs if the  !

Comission approves the use of such categorization. <

3.3.3 Technical Specification Improvement Project In December 1984. H. Denton, Director, NRR, established the Technical Specification Improvement Project (TSIP) in the Division of Safety Technology to reconsider the entire area of Technical Specifications, including philosophy, secpe, content, depth, and the process by which they are incorporated into licensing, implemented by utility and enforced by the NRC. The objective of this Project is to define the basis and philosophy of the Technical Specifications and to develop a methodology for incorporating that philosophy into the existing Technical '

Specifications and Standard Technical Specifications.

Guidance to the TSIP Group will be provided by an .

interoffice Advisory Group. This Advisory Group is expected [

l to bring an agency-wide perspective to the Technical Specification improvement effort; to establish a cooperative ,

effort with other NRC offices (including Regional offices)  :

and with industry efforts; and to assure appropriate [

programatic direction to related RES research programs. .

The TSIP Group is scheduled to complete a proposed plan of

• action in March 1985. This plan will include provisions ,

for: 1 (a) a clear delineation of the operational and licensing i problems associated with Technical Specifications, including the recomendations of the Task Group on Technical Specifications discussed in NUREG-1024 Technical Specifications -- Enhancing the Safety Impact  ;

(November 1983);

F (b) improvements which can be implemented in the short term as well as long tem improvements: F (c) the necessity to amend regulations to simplify the process for changing Technical Specifications, including revision to 10 CFR 50.36; and

/ l

(d) appropriate utilization of risk-based methodology for performing and documenting analyses to improve the

', content of and bases for Technical Specifications.

l Proposed recomendations for broad changes in Technical Specifications are scheduled to be completed in draft form by September 1, 1985.

) Areas of Interaction

• Identification of the role and the scope of maintenance as an element of the Technical Specifications

• Identification of maintenance errors and reportable l occurrences related to Technical Specifications requirements from Phase II of the Maintenance Program.

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• Recommended short-term Technical Specifications improvements which may impact maintenance performance effectiveness to be evaluated during Phase II of the j Maintenance Program.

3.3.4 Technical Specifications Research In August 1983, the Executive Director for Operations (EDO) requested the Deputy Executive Director for Regional Operations and Generic Requirements (DEDR0GR) to establish a Task Group to identify the scope and nature of problems with

, surveillance testing in current Technical Specifications and

! to develop alternative approaches to provide better

• l assurance that surveillance testing does not adversely

impact plant safety. The Task Group found (NUREG-1024) that ,

l because of the interdependence between surveillance testing, limiting conditions for operation (LCOs) and their bases, it.

i was necessary to broaden the scope of the review. The EDO i

endorsed the thrust of the recosuendations and the

. implementation methodology outlined in the Task Group report.

A Noveder 14, 1983 EDO directive also indicated that the Office of Research (RES) would provide the research and

analytical support needed for the NRR program. As a result of this action, the Division of Risk Analysis and Operations (DRAO) initiated a broad-based program, Procedure for l Evaluating Technical Specifications (PETS), designed to

! examine approaches for developing a quantitative basis to

support engineering judgments in evaluating Technical  ;

Specifications, and to demonstrate and fully document the j methodology. j

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i In a related (DST) activity, Reliability the Division and Risk of Safety Assessment Branch(Technology, RRAB),has the lead responsibility for the resolution of Generic Issue B-61 to optimize ECCS allowable outage periods ar.d test / maintenance intervals to reduce system unavailability.

Presently, the maintenance unavailability of a component depends not only on the average length of time that.a component is out for maintenance, but also on the frequency with which the maintenance is performed. Present Technical -

l Specifications do not control the frequency of such

' unavailability, but a cumulative outage limit may be effective in doing so.

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l Since analytically based criteria are needed as a basis for determining surveillance and test intervals in technical

< specifications for emergency core cooling systems (ECCS),

NRR/ DST has requested that RES incorporate into the PETS program the need to identify and evaluate possible means of implementing limits on cumulative outage times. The RES methodology for analytically deriving cumulative outage *

limits for ECCS will be te:;ted by DST and a licansing position developed.

l i

- The PETS program is expected to provide support for setting limits on reliability levels for diesel generators. The

Division of Systems Integration (DSI), Power Systems Branch (PSB), has the lead responsibility for the resolution of Generic Issue B-56 on diesel reliability. Issue B-56 has a

, high priority ranking due to its impact on plant safety

{ concerning successful accident mitigation. The PETS program will investigate several criteria, which will be essential l - to the development of a methodology to relate cumulative

! outage time with diesel reliability level, diesel configuration, and surveillance frequency.

! Phase I of the PETS program is scheduled for FY 1985 as a concerted effort to urgently resolve some generic questions surrounding the risk importance of both corrective and ,

preventive maintenance procedures, as well as to provide timely support for Generic Issues B-61 and B-56.

Areas of Interaction The MSPP is designed to examine the surveillance requirements in the technical specifications in view of the preventive maintenance program. The PETS methodology I will be reviewed to determine how to utilize it in analyzing the hypothesis that an effective maintenance program may compensate for some of the surveillance l

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requirements in existing Technical Specifications. DHFS will prepare the user need as appropriate for continuation of the PETS program to analyze the hypothesis. ,

! l The PETS program will complete the technical analysis

during Phase II

(1) to determine the requirements for changing the surveillance requirements in relation to the  ;

preventive maintenance programs and (2) to establish surveillance requirements on the basis of system reliability. .

i The ECCS outage research will provide input to Phase II of the Maintenance and Surveillance Program. The .

risk-based methodology for deriving Technical  ?

Specification outage limits will be evaluated as a means of determining maintenance needs and the results of trial Technical Specifications evaluations will be used to determine the nature and extent of maintenance problems at operating plants.

The results of the trial applications of methods for deriving ECCS outage limits will be assessed for Phase II to determine the impact on safety.

The need for limits governing maintenance and i surveillance outages will be determined so that i recommendations from the Maintenance and Surveillance l Program may be used for development of a licensing position by DST for ECCS out:ge limits as app % ptiate.

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3.3.5 Nuclear Plant Aging Research

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! The Nuclear Plant Aging Research (NPAR) program sponsored by the Office of Research, Division of Engineering Technology

! (DET), is intended to identify and characterize aging and service wear effects associated with electrical and mechanical components, interfaces, and systems likely to impair plant safety. The research will identify and recomend methods of inspection, surveillance and condition monitoring of electrical and mechanical components and

! systems which will be effective in detecting significant aging effects prior to loss of safety function so that timely maintenance and repair or replacement can be i implemented. Aging research will also identify and recommend acceptab.e maintenance practices to mitigate the effects of aging and service wear.

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The important products which will be input to the  ;

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Maintenance and Surveillance Program Phase I Survey and

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Evaluation will be a survey of current maintenance practices for selected components including motor

operated valves, q Anticipated results from the NPAR which will be useful for Phase II Identification of Problems and Impacts will ,

be an evaluation of the relative benefits of preventive l and corrective maintenance and identification of potential mechanisms causing equipment degradation j~

through improper maintenance for selected components.

Reconenendations for preferred maintenance practices for selected components provided from the NPAR will be used

in the maintenance program.

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• The NPAR will provide an evaluation of the role of maintenance in counteracting aging effects.

!I Phases I and II of the Maintenance Program will provide

! information regarding plant maintenance indicators and current industry practices to the NPAR. [

C Recomunendations for inspection surveillance and 0

) monitoring methods, including means of mitigating the  !

. effects of aging and service wear of selected components 1 as appropriate, will be provided for Phase II of the  !

j Maintenance Program from RES. p t

3.3.6 Effectiveness of Industry ALARA Programs The Division of Systems Integration (DSI), Radiological Assessment Branch, is concerned with the high proportion of p

! occupational radiation exposure which is attributed to maintenance activities. RAB is funding a project intended to identify the issues and perform cost-benefit analysis on new dose-reduction techniques and industry-developed i equ,ipment. A related research project is a comparative review of occupational dose experience at U.S. and foreign

nuclear power plants. The scope of this research includes

• an identification and evaluation of high-dose maintenance tasks as well as new industry incentives for dose reduction.

One aspect of the RAB program is to evaluate the effectiveness of industry (e.g., INPO) programs to reduce  !

occupational exposure and determine the need for further  !

regulatory guidance.

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i Areas of Interaction

• The results of the research and assessment of industry i programs will be used in developing measures of maintenance practices and problems during Phase I of the l.

Maintenance and Surveillance Program. Occupational  ;

exposure data will be reviewed as a possible indicator j

!- variable for assessing licensee maintenance effectiveness, l

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• High-dose maintenance tasks that are identified from the

RAB programs will be used in evaluating the safety impact

. of maintenance problems during Phase II of the

. Maintenance and Surveillance Program. -

!

• Dose-reduction techniques identified will be evaluated '

j . for their impact on maintenance effectiveness.

• The survey of industry maintenance practices and problems i from Phase I of the Maintenance Program will provide l-

information on maintenance practices that impact ALARA .

j programs.

• The above information, as well as information about the

, relationship between occupational exposure data and l maintenance effectiveness as safety indicators, will be "

arovided from Phase I and Phase II of the Maintenance Yogram to RAB/DSI for input to their determination about the need for regulatory guidance. t l 3.3.7 Equipment Qualification .

The Division of Engineering (DE), Equipment Qualification I Branch (EQB), pursues quality control of nuclear power plant

! equipment to ensure performance in accordance with design specifications. The equipment qualifications program j requires information regarding age-related performance -

degradation of equipment and components and maintenance and surveillance activities which affect equipment integrity, i Results of the Nuclear Plant Aging Research will provide implications for the environmer.tal integrity of electrical and mechanical components and equipment qualifications. l Information and methods by which licensees may identify and perform necessary maintenance effectively is needed to evaluate equipment qualification impacts. While initial IE inspections of EQ programs will focus on the technical adequacy of the initial qualification process, maintenance activities necessary to maintain qualification will need to be built into the inspection program.

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i Area of Interaction The need for guidance to ensure equipment qualification will be identified as the safety impact and nature of maintenance problems are investigated during Phase II of ,

i the Maintenance Program and provided to DE/EQB.

3.3.8 Reliability Program The Division of Risk Analysis and Operations (DRAO) of the Office of Research sponsors the reliability research program with objectives to design and build reliability into systems that are important to safety and prevent degradation of this reliability during operation. The tasks to be performed under the reliability research program include a screening evaluation to survey available reliability techniques

applicable to LWRs. Elements that appear most promising for i applicability to nuclear plant reliability will be developed *

]; for trial application.

4 Areas of Interaction The reliability research program is expected to produce

, methods and recommendations for detemining priorities for maintenance (e.g., frequency, preventive or

. corrective type) and would help to prioritize equipment

for maintenance action.

The results of the trial applications will be important i for evaluation of the safety 1spect of maintenance  !

problems during Phase II of the Maintenance Program. i L

• Reconnendations for reliability-centered maintenance F l

l strategies from the reliability program will be ,

considered in the Maintenance Program.  !

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Information from Phase I surveys of current maintenance practices will be provided to DRA0/RES to identify

. current reliability practices and implementation constraints at operating plants.

Related projects being sponsored by EPRI are being monitored for use in the Maintenance Program through the RES Reliability Program. These EPRI projects include efforts to evaluate Technical Specifications requirements affecting i safety system reliability as well as a trial application of reliability centered maintenance methods at a sample of plants.

Il l

l 3.3.9 Training and Qualifications of Personnel The Comission has approved a Policy Statement (SECY-85-01) whereby the industry would be allowed to proceed for two years under the INPO accreditation program. The NRC endorses INPO accreditation as a means of achieving impicmentation of a systems approach to training (SAT) in the nuclear industry. The accreditation of industry training programs, including training for maintenance and I&C personnel, will be monitored by the NRC and reevaluated at the end of the two year period.

The NRC will continue to review training and qualifications as part of the license application and safety evaluation process. The NRC will exercise some discretion in enforcement matters related to training and qualifications for a minimum of two years. The NRC will continue to inspect training and qualifications programs on a routine basis in order to ensure effectiveness of industry improvement efforts.

The NRC will inspect and evaluate licensee training programs, including maintenance training, using criteria based on the systems approach to training.

A as of Interaction The need for further regulation of maintenance personnel  !

qualifications and training will be evaluated based on the NRC review of industry implementation of performance-based training. ,

The results of NRC maintenance training reviews will be I utilized during Phase II of the Maintenance Program to

.; assess the effectiveness of industry maintenance  ;

i personnel training programs.

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The evaluation of the safety ispact of maintenance '

personnel qualifications and training, as determined from

! Phase II activities of the Maintenance Program will be i part of the NRC assessment of the effectiveness of j industry maintenance personnel training.

The training and qualifications of maintenance personnel will be reviewed as part of Phase I activities to identify current industry practices.

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l 3.4 INTERACTIONS WITH OUTSIDE ORGANIZATIONS Interactions with outside organizations will be conducted in order to assess the acceptability of industry initiatives and activities to achieve the objectives of the maintenance program. A number of l outside organizations have expressed interest in nuclear power plant maintenance and are concerned in various aspects of maintenance operations. Tht Program Phn is designed to assess the significance of the contribution of these organizations and to utilize their activities to complement the NRC efforts. The

! primary coordination point is currently with NUMARC. Through NUMARC and direct NRC contacts, the following organizations are expected to play major roles in a national program for improving I maintenance in the nuclear industry.

1. Nuclear Utility Management and Human Resources Comitte*

i l (MUMARC)

The NUMARC Maintenance Working Group is taking or considering ,

l several actions in its efforts to assess the status of maintenance in the industry and to determine possible alternatives to ongoing industry programs for improvement.

Near-tem industry plans include:

a. Initiate monitoring and trending of industry-wide

. maintenance performance indicators; ,

i l b. Evaluate maintenance performance trends,

! c. Continue to improve maintenance training programs to achieve accreditation by INP0; I

I d. Conduct maintenance-related workshops;

e. Participate in maintenance standards activities including l

INPO Good Practice and Guideline development and other technical standards development and improvements.

l f. Evaluate the state of maintenance in the indsutry as l

reflected in INPO incorporation evaluation of other reports inspection (also,inconsidering results this effort ).

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Progress and generic results are being shared with the NRC.

An MRC Task Force will work with a NUMARC Working Group to exchange data and information on maintenance indicators.

The success of this effort depends on mutual cooperation.

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2. Standards Organizations The ASME Comittee on 0)erations and Maintenance, the ANS Operations Comittee, t1e ASQC QA for Operating Plants.

Preventive Maintenance Programs Subcomittee and the IEEE Nuclear Power Engineering Comittee have been conducting a dialogue within the last few years on the need for a national standard on maintenance for nuclear power plants. A working relationship will be conducted with these organizations by NRC representatives on the comittees and by perd odic presentations on NRC activities to the comittee meetings. If a national standard on maintenance becomes available within a reasonable period of time, it will be considered for endorsement by the NRC.

3. Institute of Nuclear Power Operations The Institute of Nuclear Power Operations (INPO) is involved in a number of activities that are closely related to the subject of the Maintenance Program Plan. The following INPO programs" are considered: (a) INPO's periodic plant evaluations address issues in maintenance. The Program Plan will assess the effectiveness of the plant evaluations and will consider it as one means of industry self-monitoring; (b) INPO has developed qualification guidelines for mechanics, electricians and instrumentation / control technicians. The implementation of these guidelines will be followed; (c) INPO has conducted a number of workshops for maintenance superintendents. NRC participation and observation of the workshops will be continued; (d) IMPO~1s in the process of documenting and disseminating information on good industry practices. IhPO good practice activities on maintenance will be followed in the Plan; (e) INP0's Accreditation Program for Training includes maintenance personnel. Training accreditation is being evaluated by NRR; the results will be monitored as part of the planned maintenance activities.

4. Department of Energy The Department of Energy (DOE) has developed a method to assess the performance of maintenance for nuclear reactors within the Management Oversight and Risk Tree (MORT) program. The method has been used'for DOE reactors, and is in the process of being validated with a number of Scandinavian nuclear power plants.

The applicability of the DOE assessment method for NRC use will be evaluated within this program.

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5. Electric Power Research Institute l

! The Electric Power Research Institute (EPRI) has been conducting a large number of research studies related to  !

. maintenance. Some of the EPRI programs, such as the  !

development of a preventive maintenance guide (EFRI  ;

. Report NP-3416) or the maintainability guidelines (EPRI I Report NP-2360) are directly related to some elements of the '

Program Plan. The results of EPRI research studies, some of which are being monitored by the Office of Research, will be utilized in the program. NRC personnel will participate in and contribute to EPRI maintenance workshops. [

6. Vendor Maintenance Programs  !

The maintenance guidelines, maintenance program j

recosuendations, and maintenance services available from the '

! vendors of nuclear power plants will be evaluated and utilized in the program.

7. Maintenance Activities Outside the Nuclear Industry l~

The U.S. military, NASA and the Federal Aviation Administration

(FAA) have well-established and sui:cessful maintenance

! programs. The technical, organizational and regulatory aspects

of these maintenance activities will be included in the program ,

l by direct exchange of information, documentation, and data between the above organizations and the NRC staff.

8. Foreign Countries Maintenance Programs .

The staff plans to continue its exchange of maintenance program l information with the Japanese and to initiate information i l exchange with the French, Geman, Swedish, United Kingdom and I Canadian Governments.  ;

9. Edison Electric Institute (EEI)

Edison Electric Institute has been developing examinations for selection of nuclear power plant personnel. Ability and aptitude screening as selection practices for maintenance personnel should be pursued for possible incorporation in standards and guidance for personnel qualifications. The staff will exchange information with EEI regarding personnel selection and screening practices in the industry.

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