ML20213F649
| ML20213F649 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8611140364 | |
| Download: ML20213F649 (113) | |
Text
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ORIGINAL
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION W
In the matter of:
COMMISSION MEETING Briefing on Status of Performance Indicator Program 2
(Public Meeting)
Docket No.
Location:
Washington, D.
C.
Date:
Friday, November 7, 1986 Pages:
1 _ ng 8611140364 861107 PDR 10CFR PT9.7 PDR ANN RILEY & ASSOCIATES Court Reporters 1625 I St., N.W.
Suite 921 Washington, D.C. 20006 (202) 293-3950
4 1
D I SC LA I M ER 2
3 4
5 6
This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on S
11/07/86..
In the Commission's office at 1717 H Street, 9
'N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain
?
12 inaccuracies.
18 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.10S, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may
)
21 authorize.
i 22 23 24 25
t 1
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 (BRIEFING ON STATUS OF PERFORMANCE INDICATOR PROGRAM]
5 6
(PUBLIC MEETING]
7 8
Nuclear Regulatory Commission 9
Room 1130 10 1717 H Street, Northwest 11 Washington, D.C.
12 13 Friday, November 7, 1986 14 15 The Commission met in open session, pursuant to 16 notice, at 10:05 a.m., the Honorable LANDO W.
ZECH, JR.,
17 Chairman of the Commission, presiding.
18 COMMISSIONERS PRESENT:
19 LANDO W.
ZECH, JR.,
Chairman of the Commission 20 THOMAS M. ROBERTS, Member of the Commission 21 JAMES K. ASSELSTINE, Member of the Commission 22 FREDERICK M.
BERNTHAL, Member of the Commission 23 KENNETH M.
CARR, Member of the Commission 24 25
g 2
1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
2 JOHN HOYLE 3
SAMUEL J.
CHILK 4
WILLIAM C.
PARLER 5
JAMES TAYLOR 6
VICTOR STELLO 7
EDWARD JORDAN 8
AUDIENCE SPEAKERS:
9 TOM MURLEY 10 GARY HOLAHAN 11 JACK HELTEMES 12 13 4
14 15 16 17 18 19 20 21 22 23 24 25
O t
3 1
PROCEEDINGS 2
CHAIRMAN ZECH:
Good morning, ladies and gentleman.
3 What we're trying to get, as you can see, is all of 4
the regions to participate this morning on a two-way 5
conversation.
So if we get interrupted, you'll know what's 6
going on.
7 The purpose of the meeting this morning is to 8
receive a presentation from the Staff on the subject of 9
performance indicators and their current status of 10 development.
I do not intend to ask for a vote today.
I 11 would, though, ask my fellow commissioners to be in a position l
12 to perhaps vote by notation next week, or as soon as they feel 13 they can.
14 Among other things, this morning, I think it would 15 be important for the Staff to address the methodology they've 16 used to develop the performance indicators, the basis and 17 criteria used to select those that they have selected, and the 18 manner in which they anticipate these performance indicators 19 will be used and any experience, as far as the trial program 20 is concerned.
21 Prior to the Staff's presentation, I would just like 22 to give a few words on the performance indicators that I 23 believe might be useful, at least as I see them.
First of 24 all, they should be used as a tool.
And they should be used 25 and combined with other information, inspections, and other
+
6 4
1 analyses and evaluations.
And if they're used that way, as a 2
tool, and combined with other technologies, other methods, 3
other analyses, I believe that they can be used to give us a 4
signal that something perhaps should be analyzed further.
5 The program is evolving.
It's still in the 6
development process, as I understand it.
And it needs 7
continual modification.
My experience has been that you learn 8
as you use this program and it does require modification as 9
you go along in order to make it more effective.
It's my 10 understanding that the pilot program developed has been a good 11 start and I think the Staff will provide us their views on 12 that this morning.
13 I understand that there are slides available in the 14 back of the room for anyone who hasn't seen them yet.
15 Before we go on, let me just see if we have all the 16 regions represented.
Region I, are you there?
17 (No response.]
18 CHAIRMAN ZECH:
Region II, are you there?
19 MR. NELSON:
Region II here.
20 CHAIRMAN ZECH:- III?
21 MR. KEPPLER:
III is here.
l l
22 CHAIRMAN ZECH:
IV?
23 MR. R. MARTIN:
IV is here.
24 CHAIRMAN ZECH:
V?
25 MR. J. MARTIN:
Here.
s 5
1 CHAIRMAN ZECH:
I see Region I in the room, so --
2
[ Laughter.]
3 MR. MURLEY:
My staff is supposed to be on there.
4 CHAIRMAN ZECH:
I recognize that, but we're not 5
going to wait for them if you're here.
6
[ Laughter.]
7 CHAIRMAN ZECH:
All right.
We'll go ahead unless my 8
fellow commissioners have any opening remarks?
9 COMMISSIONER BERNTHAL:
This is what happens when 10 you leave town, Tom.
11
[ Laughter.]
12 CHAIRMAN ZECH:
Anybody else have anything?
13
[No response.]
14 CHAIRMAN ZECH:
Then Mr. Stello, will you proceed?
15 MR. STELLO:
Yes, Mr. Chairman.
16 While I recognize that you're not asking for or 17 taking a vote today, I wanted to at least suggest what it is 18 that the Staff is here before the Commission asking is 19 essentially continue the development of performance indicators 20 and to devote the resources for that purpose.
21 We do recognize the limitations.
We do, however, 22 believe there is a very, very important benefit from doing 23 this as a tool to assist us in doing our safety job and to use 24 it only as a tool.
And I don't think we can say that enough 25 times, because I think there is a suggestion --
6 1
COMMISSIONER ROBERTS:
No, you can't.
2 MR. STELLO:
There's a suggestion that we might do 3
more than that.
That is not our intent.
That is not our 4
purpose.
I think it would be a risk of making bad judgments 5
to do more than to use it as a tool simply to raise questions 6
in your mind and to look further.
To use it as a basis to 7
take regulatory action, solely on the basis of indicators, 8
clearly is not our intent.
9 So what we're really looking for is an agreement by 10 the Commission just to move forward.
I recognize you're not 11 prepared to do that today, but that's the thrust of what we l
12 want to do.
13 There's a long history of performance indicators and 14 it now spans over several years.
We're not going to try to go l
15 through a great deal of that.
We're going to tell you exactly 16 what we did.
It's presented in the paper that you have.
17 Mr. Taylor has a few comments and then I'll let 18 Mr. Jordan take you through a presentation of how we got where I
19 we are and where we'd like to go in the future.
20 Jim.
21 COMMISSIONER ASSELSTINE:
Vic, at some point are you 22 going to address the INPO letter, as part of the presentation?
23 MR. STELLO:
I hope to address the INPO letter at 24 the end, yes.
25 COMMISSIONER ASSELSTINE:
Fine, okay.
n,
,,,,....n
7 1
MR. TAYLOR:
I would like to stress that this 2
program has been a combined effort of the regions and the 3
major headquarter's offices, research, AEOD, NRR, to develop 4
this program. And again, I will -- I know Commissioner Roberts 5
said he couldn't hear it enough.
We intend to use this as a 6
tool.
It is not a decision making process because, like statistical and other data, you have to go far beyond the data 7
8 itself to make a decision.
9 So it is intended in that vein and that's the way 10 cur staffs will be instructed to use it.
11 Ed Jordan, now will make the major presentation.
12 MR. JORDAN:
If I could have the first slide, 13 entitled " Task Group Charter."
14
[ Slide.]
15 MR. JORDAN:
I'd like first to define what we mean 16 by performance indicators for this purpose.
For the NRC 17 purposes, we've said that the performance indicators reflect a 18 set of data that should have a correlation with individual 19 plant safety performance.
20 The charter that we established for the task group 21 was to develop a minimum set of performance indicators and 22 then to recommend methods for using this information in order 23 to make timely decisions about performance.
24 The first assumption was that SALP is the basis for 25 evaluating licensee performance and performance indicators D
8 1
don't replace that, in terms of making overall decisions about 2
licensee performance.
And SALP, as you know, is done on about 3
an 18 month cycle.
The performance indicators are then, for 4
the purpose of trending plant performance in between SALPs and 5
then to provide a basis for decision making when declining 6
performance is recognized.
7 There are other performance indicator purposes in 8
the Agency for individual areas, such as the maintenance 9
area.
And this particular effort does not overcome the 10 individual areas, such as the maintenance area.
11 Next slide, please?
12
[ Slide.)
13 COMMISSIONER ROBERTS:
Now, I want to understand i
14 something and make it clear.
This is to -- the intent is to i
15 detect changes in a specific licensee's performance?
This is 16 not a comparison of one plant to another?
17 MR. JORDAN:
That's correct, sir.
It is to trend an 18 individual plant.
19 COMMISSIONER ROBERTS:
A specific plant?
i l
20 MR. JORDAN:
Yes.
21 COMMISSIONER ROBERTS:
Thank you.
22 COMMISSIONER ASSELSTINE:
I thought you were going 23 to be tracking both factors, though?
No?
24 MR. JORDAN:
The intent is not to rank plants.
25 COMMISSIONER ASSELSTINE:
Right.
l
____.,_____,__,.__,..._m..
f
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9 1
MR. JORDAN:
But clearly to understand a poor 2
performing plant with respect to itself and with respect to an 3
industry average.
4 COMMISSIONER ASSELS' TINE:
So you are going to'be 5
comparing these to industry aver [ge performance?
6 COMMISSIONER ROBERTS:
You're racking them up.
7 MR. STELLO:
The' figure charts that you have show 8
the performance of the plant and how it changes by its'own 9
history and how it changes overall, average and with the 10 history of the industry.
You have both pieces of information 11 as presented to you.
I think that was the question.
Maybe it
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12 was both questions.
13 The intent is to do this on a plant by plant basis 14 and not to have any way in which to say you could look at 15 these performance indicators and these say plant A is clearly 16 number one and plant Y is number N.
You can't do that and 17 there is just no way you can take this-information and even 18 attempt to do it.
19 MR. JORDAN:
The indicators are not that. strong.
20 They are merely indicators.
21 COMMISSIONER ASSELSTINE:
But what you will do is, 22 in a particular area,'you will say.what is the average 23 performance industry-wide in this p' rticular category and then a
24 how does this plant compare with that in'dustry average?
25 MR. JORDAN:
Yes, as being either better than or i
10 1
poorer than, m
2 COMMISSIONER ASSELSTINE:
Or in the middle?
3 MR. JORDAN:
Yes.
4 I couldn't stress, in terms of the development 5
process -- Jim Taylor mentioned the involvement of the 6
offices.
This was a highly cooperative effort.
We assembled 7
a task group of senior NRC managers and we argued a lot, but 8
we resolved a great deal.
And this chart is one that was very 9
important to us in developing the process.
10 We laid out a system to go through.
We first 11 reviewed past and ongoing work related to performance 12 indicators, so we didn't redo any of that work, but we took 13 advantage of it.
And from that we selected a group of PIs for 1
14 the trial program.
The group that we worked from was a set of 15 about 27 indicators that had been used, were being used, and 16 were brainstormed.
And then we narrowed this.
I'll describe 17 it a little later.
18 We selected a set of plants for the trial program.
19 And then went through a data collection and review.
We've 20 conducted coordination meetings with industry.
We've gone 21 through a fairly extensive validation and confirmation of the 22 performance indicators.
And we have selected the slides, as a 23 minimum set.
We believe we've selected, for the indicators 24 that we were using and for the method of collection, what 25 amounts to more like an optimum set.
s 3
6 s
12, 1
And we have described methods of analysis and 2
monitoring thissinformation.
Of course, we're here to provide 3
you our recommendations.
[t.
.)
Next slide, please.
4 5
3
[ Slide.]
6 COMMISSIONER ASSELSTINE:
Ed, when you go through 7
the indicators, are you going to describe how you made the 8
decisions to' weed out -- go from the 27 down to the 8?
x 9
' MIO. JORDAN:
Yes.
10 COMMISSIONER ASSELSTINE:
And why you made some of 11 thos decisions?
12 (Commissioner Bernthal left the room.]
(-
13 MR. JORDAN:
Yes.
And in fact, this slide uses the s
14 criteria.
This is another -- it's a very simple list, but,we i
s 15 worked through a number of criteria.trying to find a s
16 methodology that would lead us towards the ideal set.
17 So these attributes -- first of all, and we put it 1E first because that's really our goal -- the performance s
19 indicators has to be related to nuclear safety and regulatory 20
., performance.
To make it useful to us, the data has to be 21 available to the NRC readily and in a timely fashion.
The 4
22 data cannot be susceptible to manipulation.
That is, if it's 23
. easy for a licensee to change his bookkeeping system or make 24 minor adjustments to change the values, then that's not a 25 useful item.
i l
C 12 1
The data ought to be comparable between utilities 2
and Commissioner Roberts, perhaps that's one that we'll have 3
to talk with you more about.
The performance indicators must 4
be a worthy goal for the utility.
We wouldn't want to cause 5
the utility to strive towards a goal that's not in the 6
interest of safety.
7 We're looking to reflect a range of performance.
8 And some of our indicators are weak on range, in that they're 9
counting very low numbers, ones and twos, for a period of a 10 quarter.
So we've compromised there, in some cases.
11 We were looking for indicators that were independent 12 of one another.
And certainly, we are seeking a predictive or 13 leading indicator for future performance.
And in many cases,
(
14 we're getting predictions by looking at history.
And if the 15 history is consistently poor, then one can expect the history 16 will continue unless changes are made.
17 And we wanted performance indicators that would 18 correlate with SALP, that were broad enough to have some 19 correlation with SALP, which is our basis.
20 Next slide, please.
21
[ Slide.]
22 MR. JORDAN:
I won't dwell on this.
23 The selection of plants was pretty much based on 24 considerations for validating the data.
We wanted to have the 25 right combination, all reactor types, ranges of performance,
13 1
and arrangements of sites.
For instance, a multi-unit site 2
with common management was of particular interest to us 1
3 because if we had data for a three unit site, where the three 4
units have essentially a common management and the indications 5
are that the three plants are performing quite differently, 6
then I don't believe the indicator.
So that was a way of us 7
testing or attempting to validate the indications.
8 Next slide.
9
[ Slide.]
10 COMMISSIONER CARR:
Why would you say that?
11 MR. JORDAN:
That a utility that is managing a plant 12 well -- a whole site -- you would expect the performance of 13 three units or two units to be comparable at that site.
I 14 would not expect to see one unit substantially different than 15 another.
16 (Commissioner Bernthal entered the room.]
17 MR. JORDAN:
And if they are, then I would say that 18 would be in the noise of the system and we're not measuring 19 accurately.
20 COMMISSIONER CARR:
As long as they were the same 21 type plants?
22 MR. JORDAN:
Yes.
And in fact, we also had 1
23 different type plants at the same site, that had reasonably 24 comparable performance.
25 CHAIRMAN ZECH:
I would, frankly, challenge that,
..,. -.. -. ~
14 1
also.
There may be something important that it tells you in 2
there.
Again, if we really believe this is only a tool, which 3
I certainly do, then if you had different performances from 1
4 three plants of the site under the same management, it 5
certainly merits looking into and asking yourself why, it 6
seems to me.
7 MR. JORDAN:
Yes, sir.
8 CHAIRMAN ZECH:
That's what the system is for.
9 MR. JORDAN:
Yes.
And understand --
10 CHAIRMAN ZECH:
So there could be some use to it and 11 it should not be considered invalid.
It could be very 12 indicative of problems.
It may not be, but it certainly --
i 13 that's all it is.
It's a tool.
We say why, why, why.
That's f
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14 what it's for.
15 MR. JORDAN:
Yes, but in establishing the program 16 and trying to decide whether we have a useful set of 17 indicators, we don't want white noise so that you get a 18 different picture from every plant that you look at.
So by 19 looking at multi-unit plants, we thought if there is coherence 20
-- reasonable coherence -- between them, and they're not 21 identical at all.
With reasonable coherence, then we felt 22 that we were on the right track in that subjective matter.
23 So it was only one of the methods of validating.
24 Now we're getting down to the business.
This is a 25 list of the 17 indicators that we used during the trial
15 1
program.
And the emphasis on this particular chart is on the 2
range of the indicators and the various data sources.
The 3
data sources, for many of the indicators, are existing 5073 4
data file that AEOD maintains; the 5072 file; the reviews by 5
the Staff, NRR, and I&E; the reports that are made to the 6
grade book, in terms of operations.
7 And an additional set were derived by direct 8
inspection.
And I'll give you an example, trying to collect 9
turnover rate in vacancies.
Let me pick an example that's on i
10 this sheet, significant event frequency is one that we did 11 within the staff rather than collect from the regions.
12 And it was an evaluation against criteria to 13 identify the most significant events within a given f
(
14 timeframe.
15 The last one, number nine, is one that we collected 16 from the regions, LCO action statements.
Our present 17 reporting requirements do not require identification of when a 18 plant enters an LCO action statement.
The limiting conditions 19 for operation indicate when a train is unavailable.
So having 20 that. kind of data would be, perhaps, useful to us in 21 understanding how much time, how often trains are unavailable.
22 So we did a data collection, found it extremely 23 difficult, very time-consuming in a plant basis, and that was 24 one of our bases for determining which indicators to select.
25 Next slide, please.
16 1
[ Slide.]
2 MR. JORDAN:
Fraction of control room alarms is 3
another one that was different -- difficult, rather, and 4
ambiguous.
Different plants have different alarm 5
arrangements.
Some plants are designed to run with dark 6
panels and some are designed to operate at power with 7
significant numbers of lamps illuminated.
8 So the interest that the NRC would have in this 9
particular alarm, this particular performance indicator could 10 cause licensees to change their system, which might not be in 11 the best interest of plant safety.
So in evaluating that one, 12 we decided that the adverse feedback would cause it to be an f
13 indicator we did not select.
(
14 And I'm not going over each one in detail, I'll just 15 pick out highlights.
The turnover rate and vacancies was one 16 we felt quite interested in.
And the object would be, that 17 could be a leading indicator if morale is bad at a particular 18 plant, if there's a problem with staffing, then perhaps there 19 can be an adverse effect on operations.
20 That also is a difficult one to collect, and the 21 correlation with that information was not good in our 22 analysis.
So that one we didn't select.
23 And I'll go through the indicators in a little more 24 detail in a few minutes.
Could I have the next slide?
25
[ Slide.]
.e 17 1
COMMISSIONER ASSELSTINE:
Before you leave that, 2
when I looked through the original list of 27 -- you've 3
mentioned a couple of these -- but it struck me that there 4
were several of them that are fairly important indicators of 5
how effective the company's management is in operating the 6
nuclear program.
You've touched on a couple of them, and I 7
grant you that there may be some difficulties in trying to 8
collect and assess the information.
But I guess I wonder 9
whether that ought to foreclose efforts to pursue some of 10 these.
And let me mention a couple of them.
11 LCO action statements entered, for example.
We know 12 when we've looked at some of the problem plants that we've got 13 a couple of problem plants that are almost always in an action 14 statement.
I mean, there are four or five of those a day, day 15 in and day out.
That poses tremendous challanges to the 16 operators, to the operating staff of the plant.
They're 17 always running around trying to fix something to keep the 18 plant on-line.
19 That ought to be a good indicator that sooner or 20 later, if the licensee doesn't address that problem and they 21 don't start making real progress in reducing those, that's 22 something is going to happen.
I mean, it's just common sense 23 that if you're always trying to fight fires and keep your head 24 above water, sooner or later something is going to catch up 25 with you.
And it's an indicator that the company isn't
ss 18 1
bringing to bear sufficient management attention and perhaps 2
the necessary resources to get the plant in a more stable 3
level of operation.
4 Number of items out of service.
Again, I was just 5
at a plant that had 130 pieces of equipment in the control 6
room out of service.
And out of those 130, the company 7
acknowledged that half of them were fairly significant.
8 That's an indicator that somebody is not paying attention to 9
maintaining the condition of the plant, that there's a 10 potential for operators not to be able to rely upon the 11 information that they're being given in the control room, and 12 increased obstacles to their being able to operate the plant 7
13 safely.
14 It's an indicator that there's a potential problem, 15 and it's indicator that the management isn't focusing on 16 maintaining the quality of the plant.
That's another one that 17 I think can be very useful and very helpful.
18 Conversely, if you've got a plant where everything 19 is running and where they really keep after those things, 20 that's a good indicator that you've got people paying 21 attention to what needs to be done.
22 Operator licensing examination results.
We've seen 23 some of these plants -- and interestingly enough, it tends to 24 correlate with some of the plants that we've categorized as 25 problem plants, that have very high failure rates on operators i
l 1
.s 19 1
when the NRC gives requalification exams.
It strikes me that 2
that's also an indicator.
3 First, of the capability and preparedness of the 4
operators to do their job.
And recond, the adequacy of the 5
company's training program.
And third, the commitment of the 6
company's management to make sure that their people are kept 7
qualified and able to carry out their responsibilities.
8 Personnel vacancies, turnover rate and overtime.
9 Again, when we looked at Pilgrim, one of the things we found 10 out is they got so short on operators that everybody was 11 working unacceptable -- or that the SROs were working 12 unacceptable levels of overtime, and the Ros.
That's another 13 good indicator.
The company's not paying attention to it's
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14 most basic needs.
That is, having an adequate number of 15 qualified people to do their job.
16 The same thing for senior management positions at 17 the plant.
If a company has a vacancy for a long period of 18 time in key jobs, like maintenance superintendent, I&C 19 superintendent, operations manager, those kinds of things; if 20 they're not building a reservoir of qualified people to move 21 up into those jobs as time goes on, that seems to me to be a 22 sure-fire indicator of a lack of management attention to 23 what's going on.
24 Contractor support is another one.
If you're 25 relying very heavily year in and year out on contractors,
20 1
that's also a warning sign about what's going on at the 2
plant.
It strikes me that you sort of passed up on a number 3
that experience has shown us are very significant factors.
4 Admittedly, some of those may be difficult to collect, but I 5
guess my concern is, have you weeded out too much in trying to 6
get down to a very small nur.ber of indicators, such that 7
you're giving up some -- what appear to be fairly important 8
determinants of performance?
9 MR. STELLO:
Yes.
10 COMMISSIONER ASSELSTINE:
Okay.
That's what I 11 thought.
12 MR. STELLO:
We want to revisit the issue again.
13 I'm not sure I know when.
I agree with some of the things you 14 said.
Others I don't know that they're good ideas.
Others I 15 think we've already captured by other performance indicators.
16 But we're not finished.
We need to do more.
17 CHAIRMAN ZECH:
Frankly, I agree pretty much with 18 what Commissioner Asselstine has said.
Those are the hard 19 ones.
I've reviewed the program, too, and I think you've
.20 frankly come up with those that are pretty obvious at first.
21 But I do think now the hard ones are the most 22 useful.
Those are the ones that Commissioner Asselstine has 23 alluded to -- and others, too.
And my suggestion would be 24 also -- and perhaps the hardest one of all might be to look 25 back at the significant events we've had over the past year or
1 21 j
1 so or longer and look at the investigations that we've done ah 2
and the conclusions and recommendations we've come up with and 3
see, how could we possible have -- what kind of a performance 4
indicator could we have derived that would have shown us this 5
kind of an event coming.
That's a very difficult one to do, 6
but it's worthwhile.
7 And it does get to be subjective.
But you see, we 8
really are talking about tools.
And if we remind ourselves 9
that's what we're talking about, then okay, so in some cases 10 the exam rate is not very indicative.
In maybe one case it 11 really would be.
In some cases the management organization 12 and filling positions, you know, they're not many that don't 13
,7 do a pretty good job, but maybe there's one or two that would 14 stand out.
That's what we're -- you know, those are useful 15 pieces of informauion.
It's just tools we're talking about, so I think some 16 17 of the very subjective ones, the difficult ones are perhaps 18 the most useful.
I recognize you're just getting started and 19 I think that's important.
But that's why I emphasized 20 earlier, in my experience a program evolves, develops and you 21 do get those harder ones.
But my experience has been that 22 those are the ones that are the most difficalt to come up with 23 but the most useful.
And that's what they are, they're 24 useful tools.
25 So I submit that some of those ones that have been
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22 1
mentioned are truly the ones that we need to spend more time 1
2 on.
But I think you made a good start.
It's just that 3
simply, we've got to recognize it's an ongoing program and 4
you'll continue to develop the data you need and to look real 5
hard and to come up with the more difficult indicators.
Is 6
that the approach that you're going to take?
7 MR. STELLO:
If the Commission let's us do that, 8
yes.
9 CHAIRMAN ZECH:
All right.
10 MR. STELLO:
That's what we're here to ask agreement 11 on.
12 COMMISSIONER ASSELSTINE:
Okay, but it does strike I
13 me that a lot of those really go to the heart of the question 14 of management effectivenss.
If you use them as tools, there 15 may be perfectly legitimate explanations for why some of those 16 appear to be anomalies in an individual case.
(
17 MR. STELLO:
That's right.
You know, you could get i
l 18 a list, you could add about 50 more indicators and say they l
i 19 sound good.
You've got to be careful, the toolbox gets so 20 heavy you can't lift it.
You know, you want to try to hold 21 them down to where you could do it quickly and efficiently, 22 too, when you're making these judgments.
And every time you 23 look you ask, if this plant a problem, are there questions.
24 When you go in and review the plant you ask all those 25 questions; what was the overtime rate; what was the pass / fail
23
.1 rate.
All of those kinds of things you're going to get.-
2 All you need is, do you get enough information from 3
these to ask the questions.
Once the question is asked, 4
you're going to be asking now, literally hundreds more 5
questions about what's going on in the plant to make the i
6 judgment.
So you don't stop here.
You've got to be very, 7
very careful.
This is the just the beginning to ask why, how 8
what.
9 CHAIRMAN ZECH:
But you clearly need more than you 10 have now.
11 MR. STELLO:
We need more, I agree.
12 COMMISSIONER ASSELSTINE:
Yes.
.,[
13 MR. STELLO:
I'm not debating it.
I just want to 14 also put a caution that you don't want to let this get so big 15 that it gets to be cumbersome to use, too.
16 COMMISSIONER BERNTHAL:
Vic, one of the things that I
17 I -- it may be in the package of stuff that I have here -- but 18 I have not seen yet in a list of bullets or whatever is the 19 INPO program.
They have a rather similar program, as I
\\
l 20 understand it, which they have undertaken.
21 How did their performance indicator criteria, their 22 list of criteria, how does that list compare with the list of 23 criteria that you've selected for this program?
24 MR. JORDAN:
I have a slide that will compare those 25 directly.
24 1
COMMISSIONER BERNTHAL:
You do have that?
/
2 MR. JORDAN:
Yes, sir.
3 COMMISSIONER BERNTHAL:
Okay, all right.
4 MR. JORDAN:
And I would like to say that the Staff 5
is not at all defensive with regards to other performance 6
indicators.
The task group struggled very hard with those 7
very indicators that you've identified.
8 One of our favorites really is the limiting 9
condition for operation, the train availability is the heart, 10 and I'll explain why in a moment.
We were trying to come up 11 with a set that we could embark on while we then developed and 12 improved on the overall program.
[
13 COMMISSIONER BERNTHAL:
We certainly shouldn't be 14 defensive.
In fact, decidedly to the contrary, I think we 15 should welcome the utilities and INPO itself picking up on 16 this kind of program.
17 One concern that I have had in looking at where we 18 are now on this matter is that we may be, in fact, coming in a 19 rather poor second fiddle to what INPO is doing.
It's not 20 clear to me we should be doing the same things that INPO is 21 doing at all.
We should be doing the things that suit our 22 purposes uniquely, and INPO similarly should do things that 23 suit their purposes.
But if you've got a slide, we'll defer 24 the discussion on that for the moment.
i 25 MR. JORDAN:
All right.
Very briefly, we did l
25 1
several things in the confirmation.
I've mentioned already 2
the review of the multiple unit, same unit type data.
We also i
3 did a validity check through a logic model, and we did some 4
statistical analysis of the data to compare the performance 4
5 indicators against the operational SALP areas of maintenance, 6
surveillance, operations and quality assurance.
And then we 7
compared the performance indicators internally among I
8 themselves as far as their coherence.
9 Could I have the next slide, please?
10 (Slide.]
11 j
COMMISSIONER ASSELSTINE:
Are you going to talk I
12 about the results of that comparison?
j(
13 MR. JORDAN:
Yes.
14 COMMISSIONER ASSELSTINE:
Okay.
15 MR. JORDAN:
This we're rather proud of.
This was 4
16 derived from the research reliability program, and we feel 17 that's really the basis for the determinations that we've 18 made.
At the top clearly is plant safety, and this is related
]
19 to risk -- severe accident type safety.
And the legs that 20 support it are the arrival rate of transients, the i
j 21 availability of safety systems, and then the design features i
22 and potential for cognitive errors.
23 That latter box, we don't have measurements in the l
24 performance indicator program.
We recognize it's a 25 contributor to overall risk, but we're not advertising that t
26 1
we're trying to solve that problem.
The cognitive error side 2
of it would come out of operator performance, but not 3
directly.
4 COMMISSIONER ASSELSTINE:
Are there other indicators 5
that at least give you some indirect information on both of 6
those, including inherent design features?
I mean, it strikes 7
me that --
8 MR. JORDAN:
Yes, we find through events design 9
problems.
But in terms of the overall design, two versus 10 three diesel generators, that kind of thing, that's 11 established.
12 COMMISSIONER ASSELSTINE:
All right.
But it strikes
(
13 me that things like frequent unplanned outages, frequent 14 failure of the same safety system over and over again, LCO 15 statements, where you're always in an LCO statement, tells you 16 something.
17 MR. JORDAN:
Yes.
18 COMMISSIONER ASSELSTINE:
It may be the maintenance 19 program, but it may also be you've got a basic design weakness 20 in a system.
Turkey Point is a good example.
You've got a 21 couple of systems down there that are shared systems that are 22 very difficult to maintain and operate.
23 MR. JORDAN:
Right.
But in terms of containment 24 volume or pressure capability or vessel that sort of thing 25 we're not putting into the equation.
And we'll never have a i
,,.____.__.r,
27 1
numerical value out of the top of this, but we think we have 2
some proportionality.
So we try to then align the performance 3
indicators under those legs, and from the trial program we 4
feel that the scrams, the ESF actuations, and safety system 5
actuations, significant event frequency and unplanned 6
shutdowns, for instance, all line up under low frequency of 7
Some of these have connections to other logic 8
legs, but those are the principal line-ups.
9 The high train availability.
You recognize that one 10 as one if we had the LCO action statement information that 11 would support that one almost uniquely.
And instead, we have 12 forced outage safety system failures that we've maintained.
(
13 Under the potential for common cause failures, we 14 have cause codes that we didn't select.
I'll go down to one 15 we did, enforcement action index.
That one reaches across all 16 of the management areas and goes beyond the normal operational 17 areas that the rest of the performance indicators are 18 interested in.
So for instance --
19 COMMISSIONER CARR:
But that one doesn't mean your 20 truly independent criteria.
21 MR. JORDAN:
Does not.
It becomes an emphasis on 22 generally some other event.
But for instance, where there's 23 security violation or emergency preparedness or other 24 functional areas that relate then to the maintenance at a 25 facility, it does show up there and does give us some
28 1
support.
And the overall maintenance indicator is one that 2
supports that particular area.
3 COMMISSIONER ASSELSTINE:
On your point earlier 4
about enunciators, you're right that plants vary in terms of 5
how many enunciators that have lit during normal operation or 6
that are supposed to be lit during normal operation.
But it 7
also can be a good indicator of the attitude that the company 8
has in terms of the way it operates its plants.
9 MR. JORDAN:
Yes.
10 COMMISSIONER ASSELSTINE:
If you've got a plant 11 where you've got a lot of these things that are lit all the 12 time, nuisance alarms, and there's just no effort to clear
[
them out or close them out, that's tell you something about 13 14 the operating philosophy of the company.
15 conversely, you go into some of the few plants in 16 the country that really make an effort in this area to go for 17 a blackboard or get it down to the anunciators that are 18 supposed to be lit during normal operation, and that evidences 19 a different kind of pb'losphy.
20 MR. JORDAN:
It does.
In this trial by looking at 21 that one, we got feedback from the resident inspectors that 22 collected that information, that that's a part of their 23 routine inspection.
They're in the control room daily and 24 they do the sweep of the boards.
25 MR. TAYLOR:
They do ask why.
29 1
MR. JORDAN:
And then press the licensee.
So it's, 2
in some cases, redundant to try to keep book on that 3
particular item as a numerical item.
4 COMMISSIONER ASSELSTINE:
Okay.
5 CHAIRMAN ZECH:
Then on the other hand, some of 6
them have considerably more alarm lights on and it's just been 7
that way for a long time.
Perhaps it's all right and perhaps 8
it isn't.
But what we're trying to determine is, is this good 9
or not.
i 10 Now I submit that perhaps some of them could perhaps 11 clear some of those lights off with a more aggressive program.
12 MR. JORDAN:
Sure.
(
13 CHAIRMAN ZECH:
It might contribute to safety.
So 14 looking at this again is, I think, worthwhile.
At least, I 15 recognize the inspectors do it.
We all do it, too, when we 16 look at the plants.
17 On the other hand, perhaps it's something worth 18 looking into.
It certainly deserves serious consideration.
19 If it can give us a clue as to whether or not the policy of 20 the organization is to maintain and improve their operational i
21 program, it's something that is, I think, worth looking at 22 very carefully.
23 COMMISSIONER ASSELSTINE:
And also, in some 24 instances just having a resident inspector try to raise the 25 issue often doesn't get the kind of results that we want to
=
~
30 1
see.
There have been some instances where it's taken regional 2
administrators or Commission visits to sort of --
3 CHAIRMAN ZECH:
And we're trying to help the 4
resident inspectors and we're trying to support him.
5 MR. JORDAN:
Next slide, please.
6
[ Slide.]
7 MR. JORDAN:
I apologize for the cluttered 8
appearance for that slide, but we simply kept adding things j
9 onto it.
This is the comparison with INPO, and also with the 10 IAEA indicators.
And so I'll walk through this in some 11 detail.
12 COMMISSIONER ASSELSTINE:
Just in terms of the IAEA i(
13 indicators, have we -- as part of the efforts to develop those 14 kinds of things -- made any commitments about IAEA about what 15 we would do with them in this country?
16 MR. JORDAN:
We have' participated with them, in a 17 session in June.
And this was to contribute our part.
INPO a
18 was also a participant and the object is to try to have as 19 consistent and reasonable a set internationally, as well.
And 20 so we're continuing to participate and review the material 21 with them.
22 COMMISSIONER ASSELSTINE:
But it's basically up to i
23 individual countries to decide whether they're going --
24 MR. JORDAN:
It would be up to the individual i
1 25 countries to adopt.
And as you know, it's very hard to get a
.-.--,_._____.-,__._.._,_-_.._-____.___,_,_......-_,,m.,___
- -. _ - ~.... _.,. _ _ -, _. -. _ _. _ _ _ _., - _ _. _ _ _ _,, -.. _ _ - _ _ _. _ _ _.. _ _ _ _ _
s e
31 1
consensus in the U.S.,
across the IAEA, it's even harder.
And
/
2 for instance, scrams as an indicator right now in Japan is not 3
a very useful indicators, because that's ones and zeros.
4 COMMISSIONER ASSELSTINE:
It's an indicator, all 5
right.
i 6
MR. JORDAN:
I hope it becomes that kind of an 7
indicator in the U.S.
8 COMMISSIONER ASSELSTINE:
That's right.
9 MR. JORDAN:
The NRC scram definition is the same as 10 the INPO definition.
That is a performance indicator that we i
11 have selected through the process.
We believe that's a very 12 important measure of transients.
And these are automatic
(
13 scrams while critical.
It does not include manual scrams.
We 14 maintain data on scrams above and below 15 percent power for 15 information, but that's not the indicator.
The indicator is 16 the unplanned, automatic scrams while critical.
i 17 COMMISSIONER CARR:
Why wouldn't you make that 18 unplanned, rather than unplanned automatic?
If the operator 19 sees he's about to get scrammed, then he goes up and scrams 20 it, the same problem has occurred.
l 21 MR. JORDAN:
The same problem has incurred.
There 22 was a concern that there was a disincentive for the operator 23 to manually trip it if we counted that one against the 24 licensee.
And so that was a --
25 COMMISSIONER CARR:
I don't know many operators that I
1 I
l s
32 1
would be disincentivized to be funny on a scram.
2 MR. JORDAN:
I personally agree with you.
It's an 3
industry-type concern that this would be a negative --
4 COMMISSIONER CARR:
I think you've incentivized them 5
to trip it.
6 MR. JORDAN:
We --
7 COMMISSIONER CARR:
Because then they don't have to 8
worry about it.
9 MR. JORDAN:
We had that argument in the task group 10 and it's a wash.
It's very hard.
The way that I can say we 11 collected information, though, is through other events.
If 12 the operator manually scrams it and there is a complicated 13 event, then we're going to pick it up as an indicator through 14 the significant event frequency.
This would be a scram with 15 complication.
So we will score it.
16 COMMISSIONER CARR:
I hear you, but I'm not 17 persuaded.
18 MR. TAYLOR:
We'd certainly know about that, too, l
19 because it gets reported.
You know, it's noted.
20 MR. JORDAN:
Yes, it is reported to the operations 21 center and we have the data for the purposes of the tally.
22 And in our relationship with INPO, we've worked very hard to l
l 23 come up with the same definitions, to accommodate where the 24 industry already has a number.
And the concern is, of course, 25 reporting different values nationally, for instance, is a l
l
n 33 1
strong concern of INPO's.
/
2-COMMISSIONER ASSELSTINE:
The industry has been 3
emphasizing decreasing automatic scrams for what -- a couple 4
of years now.
5 MR. JORDAN:
Yes.
6 COMMISSIONER ASSELSTINE:
Have you seen any 7
correlating increase in manual scrams?
8 MR. JORDAN:
I have not looked, personally, so I l
9 don't -- I don't believe so.
The manual scrams are very low 10 numbers.
11 MR. HOLLAHAN:
Gary Hollahan from NRR.
I believe 12 the number's been about consistent.
Manual scrams run about
(-
13 10 percent.
Total scrams are down about 10 percent this year, 14 but the percentage that are manual is about the same.
15 CHAIRMAN ZECH:
The point is, we don't want to 16 discourage an operator from scramming the plant if he has any 17 concern about safety.
That's basic.
18 MR. STELLO:
There's one, I think, important point 19 which I'm raising as part of what I wanted to get to later, in 20 the INPO letter.
To the extent that it's at all possible to 21 be able to rely, to the extent we can -- to be completely 22 consistent with the INPO indicators that we are going to use, 23.
since we can in fact use it and maybe it will save us time, 24 effort and energy.
25 That's another reason for keeping it the way we have
34 1
it.
It is identical.
2 COMMISSIONER CARR:
I just don't agree with them 3
either.
4 (Laughter.]
5 COMMISSIONER ROBERTS:
How are you going to deal 6
with scrams per 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />?
I'm looking at a printout here 7
and you've got over 100 plants.
And if you just look at the 8
numbers -- and I'm not going to identify anybody -- here's 9
some plant with 42 scrams per 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, but they only 10 operated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
11 Now this thing is going to be computerized.
You're 12 going to kick out a lot of numbers.
Who and how is some 2 /
13 intelligent judgment going to be applied to something like 42 14 scrams per 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, which looks horrible on the face of 15 it, but in fact is not.
16 MR. JORDAN:
I'll restate and say the performance 17 indicator is only the unplanned scrams at power, not per 1,000 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
The per 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> data is to help people reconcile 19 operation and looking at low power operation, as well.
You're 20 looking at above and below 15 percent, to see if you can 21 understand a problem at a particular plant.
22 If it has a high overall scram rate, then look at 23 the other, finer, structure of it.
But that finer structure 24 is not an indicator.
It's just added information, easily 25 maintained and does have useful.
r
,-_m.
--.--.._-_,_--,-,m,
35 1
COMMISSIONER BERNTHAL:
Statistics are small 2
numbers.
3 COMMISSIONER ROBERTS:
And can be very mischievous.
1 4
COMMISSIONER BERNTHAL:
One other observation that 5
I'm sure you've thought about is that something like a scram, 6
an automatic scram perhaps in particular -- I'm sure certain 7
of these things like scrams show up in two or three of your 8
performance indicators.
I don't know that there's anything 9
wrong with that, but for example, for certain scrams they will 10 be unplanned shutdowns as well and they may occur because of 11 a safety system failure.
12 You see what I mean?
There's a snowball effect.
/
13 MR. JORDAN:
Yes.
We don't weight the performance 14 indicators.
They'self-weight in that very fashion.
15 COMMISSIONER BERNTHAL:
Yes, they do.
16 MR. JORDAN:
So that if there is a simple scram, 17 then it'll show up as that statistic only.
If it's a complex 18 scram, with other failures, then it will be multiplied and get 19 additional weight, even including enforcement action.
I 20 What I propose to do is,to go through the ones that 21 we've selected and then, if there are questions on ones we 22 didn't select, I can go into more detail on those, without 3
i 23 taking the Commission's time.
24 CHAIRMAN ZECH:
Fine.
Go right ahead.
25 MR. JORDAN:
The next one that was selected was 1
d 36 1
safety system actuations.
And there, this is identical to the 2
indicator unplanned safety system actions used by INPO and it 3
includes the actuations of the ECCS, both actual and 4
inadvertant, and emergency EC system actual.
So this is a 5
fairly limited set.
We, in the trial program, used a wider 6
set and it looked at the more limited set and does not affect 7
our information badly.
8 So we're going to accommodate the INPO definition 9
specifically.
10 The next one is the significant event frequency.
11 I've given you some information about that one already.
This 12 came out of the screening that NRR and I&E do on a daily
{
13 basis.
Each morning, upon going through the events, there's a 14 conference call and a review of events.
Now there are 15 criteria that are applied to events to screen out, to identify 16 significant events and to maintain a listing of that set.
17 COMMISSIONER ROBERTS:
Now, is this what is 18 discussed in the weekly monthly Monday afternoon meeting?
19 MR. JORDAN:
They are not an exactly congruent set, 20-but a significant event would generally be discussed, but 21 there are also some other events that are not classed as 22 significant events that are also discussed in that Monday 23 meeting.
24 COMMISSIONER ROBERTS:
All right.
On July the 28th, 25 the items under discussion, which would become -- as I am told
e 37 1
-- significant events, there was some minor earthquake that 2
related possibly to Rancho Seco and Diablo Canyon.
But it was 3
later determined there was absolutely no significance.
- Now, 4
is that going to be racked up as a significant event for 5
Rancho Seco and Diablo Canyon?
1 6
MR. JORDAN:
No, sir.
That's what I explained, that 7
it's not a congruent set, that a significant event is 8
generally discussed at the meeting, but there are many events 9
that are not significant by this definition, that are 10 discussed at that meeting.
11 COMMISSIONER ASSELSTINE:
Ed, let me ask you another 12 one, though, along those lines.
When I looked at the SECY
(
13 paper, you say under significant events, things like discovery 14 of a major condition not considered in the plant safety 15 analysis, degradation of fuel integrity, primary coolant 16 pressure boundary, or important associated structures.
Let me 17 give you an example.
18 Duke found this problem with the auxiliary feedwater 19 suction at Oconee.
Would that be the kind of thing that would 20 fall under this?
21 MR. JORDAN:
Yes, sir.
Definitely.
22 COMMISSIONER ASSELSTINE:
And is there a way -- I 23 mean, it strikes me that it's sort of a plus that Duke found 24 that problem and brought it to our attention and dealt with j
25 it, not a minus.
38 1
MR. JORDAN:
They should have found it sooner.
2 COMMISSIONER ASSELSTINE:
Okay.
3
[ Laughter.]
4 COMMISSIONER ASSELSTINE:
All right.
That's true, 5
but how about things like BWR pipe replacement, steam 6
generator tube integrity?
I take it, if you're talking about 7
degraded condition, it would be an event that resulted from 8
that or just would the degraded condition itself be picked up 9
under these?
l 10 MR. JORDAN:
I think it's possible, but it would 11 require looking at each case.
For instance, the BWR pipe 12 replacements, normally those would not be tallied in here as 13 significant events.
That's an industry problem.
If a plant
[
14 had a pipe failure, if a crack developed and a significant 1
15 leak, then it would require this.
16 COMMISSIONER ASSELSTINE:
Then it would trigger 17 this?
18 MR. JORDAN:
Yes, sir.
19 COMMISSIONER ASSELSTINE:
All right.
20 COMMISSIONER BERNTHAL:
Why does your asterisk list 21 there -- I see seven -- not correlate with what I'm reading in 22 the SECY paper?
For example --
23 COMMISSIONER ROBERTS:
Well, they don't, Fred, and I 4
24 can't give you an answer.
But they don't correlate.
25 COMMISSIONER BERNTHAL:
For example, I don't know i
I 39 1
what an overall maintenance indicator is in the SECY paper, 2
and it doesn't appear in this -- sorry, in this list.
It 3
doesn'tappearpntheSECYpaper.
4 MR. JORDAN:
I'll get to that.
5 3
COMMISSIONER BERNTHAL:
You'll clarify that?
1 4
6 MR. JORDAN:
Yes, sir, I will.
7 COMMISSIONER ASSELSTINE:
I gather, because you're s
8 working off the original 17 that have now been sort of 9
modified and pared down to the 8?
10 MR. JORDAN:
That's right.
We have continually 11 modified:-- the system is continually in a state of flex.
12 CHAIRMAN ZECH:
It will be that way.
It will
/
13 continue to be that way, if you use it properly.
You'll find 14 some of the indicators that you've recommended aren't as 15 useful as others, and you'll find some other ones.
If you 16 apply yourself and work at it hard, and do work on the hard 17 ones that ss've suggested, you'll have new indicators.
18 It's a system that my experience has shown improves 19 in time.
There's no way to do it except to work it through, 20 try the system out.
You'll find some indicators that are not 21 too~useful.
And then you'll find another indicator't' hat's s
22 very.useful.
23 So in time, the system gradually improves, it's been 24 my experience.
And again, you have to question everything.
25 You'll get some false alarms, and that's why we say it's a I
1
,_...._.-_,,,,_._______-_.m_
,___,_,__._...,,_.,,~.,,,~-_-.____m.
m 40 1
tool.
You'll have good reason for some perturbation to the 2
system.
You'll say why and you'll look into it in depth and 3
you'll find out there is a good reason or there isn't a good 4
reason.
i 5
But all it is is a device for signalling attention 6
and management focus on our part.
And I think that's the 7
thing.
So it has to be, if we design it properly, it will 8
certainly change and should change.
If it doesn't change, we 9
don't have the right system.
The system needs constant 10 monitoring, constant checking, constant challenging.
And if 11 we do that, we'll find that it will give us continually 12 valuable information, as a tool, to wave our attention to
[
13 something we should look into.
14 It'll need changes.
And certainly this will.
15 MR. JORDAN:
The next one is safety system 16 failures.
This is a case where INPO is developing one called 17 safety system unavailability.
It's not fully developed at 18 this time, and we feel this is a very important one, and we 19 will contin.vt with it.
And when INPO develops, we will 20 consider the comparison.
21 COMMISSIONER ASSELSTINE:
How did you pick your 22 safety systems?
23 MR. JORDAN:
These were the -- what the Staff viewed 24 were the most sensitive to safety, a generic list across all 25 the plant types.
And so then it would be key word retrieved
41 1
in that fashion.
2 COMMISSIONER ASSELSTINE:
Is instrument error on the 3
list?
4 MR. JORDAN:
No, it's not.
5 COMMISSIONER ROBERTS:
How do you reconcile the 6
redundancy and safety system failures and forced outage rate?
7 As I read this, you've got forced outages that can be 8
attributable to operator error or equipment failure.
Isn't 9
equipment failure under safety system failures?
10 MR. JORDAN:
That's possible, but this is a fairly 11 hard set.
These are low numbers.
This is when the entire 12 system -- and pick the diesel generator -- the emergency
('
13 electrical power system is unavailable.
Not one train, but 14 both systems.
15 And so -- and both units, I'm sorry.
So this is a 16 case where that entire system was not available.
There are 17 some ambiguities because, for instance, for BWRs the high 18 pressure coolant injection system has a backup in the 19 autodepressurization system.
But since it's called a system, 20 whenever the high pressure injection system is out of whack, 21 and it becomes a safety system failure here.
22 We recognize those inconsistencies, but they're only 23 with respect to a given plant type.
24 The next one down is forced outage rate.
This is 25 one that has common definition with INPO.
It's from the gray
42 e
1 book information.
It's the number of forced outage hours 2
divided by the sum of forced outage and service hours.
So 3
that's a very simple one.
It's quite useful.
4 Could I have the next slide, please?
5 (Slide.]
6 COMMISSIONER ROBERTS:
What do you do in the 7
circumstance of somebody like Millstone, who shut down in 8
anticipation of Hurricane Gloria?
Is that a forced outage?
9 MR. JORDAN:
It probably would be, yes.
And 10 clearly, it's a numerical value that shows up, but it's not 11 one that's explained.
So when one looks at the data --
12 COMMISSIONER ROBERTS:
Did you say possibly it is
/
13 one that is explained?
14 MR. JORDAN:
It is one that is easily explained when 15 one looks, then, at that particular plant.
So when you have 16 data that you don't understand, then you look further at the 17 plant.
And I'll show you a little later, on the detailed 18 charts, how we look at the plant operating history during a 19 given cycle.
20 CHAIRMAN ZECH:
And you don't just put it on a 21 computer and crank out the results.
You have a forced outage 22 due to a hurricane, or whatever.
You say okay, why did you 23 have the forced outage?
You had a hurricane.
You did it.
24 You did it knowingly.
You did it for safety purposes.
It 25 makes sense.
43 1
So you've analyzed it. That's what you're doing.
2 And it would be explainable, and that's all you're asking, why 3
did you do it.
4 MR. JORDAN:
One indicator being outside of the j
5 norm, so to speak, or being trending high, is not really cause 6
for a second look.
It's normally several indicators that are 7
giving you the same kind of a message.
Then you go back and 8
look at more detail at that particular plant because there is 9
noise in the indicators.
Scrams are somewhat a statistical 10 process at plants.
11 And I note, from the operation center, we've gone 12 almost a week and a half with no scrams.
That's remarkable
{
13 with the scram rate across the country.
But that happened, it 14 was a statistical quirk.
15 CHAIRMAN ZECH:
Let's keep it that way.
16 MR. JORDAN:
Yes, I'd like for it not to be a 17 statistical quirk.
18 COMMISSIONER ASSELSTINE:
Ed, would planned 19 maintenance activities, that wouldn't be included under forced 20 outage, would it?
21 MR. JORDAN:
No, when a plant is planned to take an 22 outage, then it's not a forced outage.
23 COMMISSIONER ASSELSTINE:
So pipe replacement or 1
24 steam generator replacement, you wouldn't be penalized under 25 this?
i
_._m
44 1
MR. JORDAN:
No.
2 COMMISSIONER ASSELSTINE:
Okay.
3 MR. STELIO:
I hate to stop it, but I think there's 4
a connotation that if somebody has one of these indicators 5
that's above average it's a penalty.
It's a tool.
6 COMMISSIONER ASSELSTINE:
That's true.
7 MR. STELIO:
There is no intent to penalize 8
someone's performance because of the way they rack up, and you 9
compare it to the average and it looks worse than the 10 average.
It doesn't mean their performance is in fact bad.
11 COMMISSIONER ASSELSTINE:
That's true.
12 MR. STELLO:
It's just a tool.
There's no intent to 13 penalize.
There's no intent to do anything more than to try 14 to help us do our safety job better.
15 COMMISSIONER ASSELSTINE:
It may be a basis for 16 questioning further.
17 MR. STELLO:
That's the whole purpose.
18 COMMISSIONER ROBERTS:
Vic, you're saying all the 19 right words.
I'm just worried about the implementation.
20 MR. JORDAN:
And he has crammed those words into the 1
21 Staff.
22
[ Laughter.]
23 MR. JORDAN:
I've become a true believer.
24 COMMISSIONER ROBERTS:
Yes, but things change and 25 people come and go.
1
. -. - - -. ~.
,,.,, -. - -,.... -. -,. - ~ -. -,
45 1
CHAIRMAN ZECH:
No, it's worth challenging the 2
execution.
I agree with Commissioner Roberts, because the 3
system can be gimmicked if you're not careful, and you don't 4
want people to do things that are unsafe just to make 5
themselves look good.
It's a constant challenge.
This is a 6
system that does requires a recognition that it must be looked 7
at very carefully and you should keep away from anything that 8
might do the opposite.
That is, provide unsafe condition at 9
the plant.
10 So it's worth challenging and looking at, and we 11 don't want -- we want to make progress towards safety.
And so 12 the system does require a constant vigilance to make sure that 13 it's doing what we want it to do.
It's a constant thing to
(
14 have to watch, too, and I know that Mr. Stello is well aware 15 of that, and I trust the Staff is, too.
16 COMMISSIONER CARR:
I couldn't agree more.
You're 17 going to have to work hard to keep it being a tool and not a 18 score sheet.
4 19 CHAIRMAN ZECH:
That's right.
20 MR. JORDAN:
Could I back up to the previous slide 21 just a moment.
I'd like to go back to the maintenance 22 backlog.
That's one that we didn't select, and I need to 23 explain to you why, because it was on the list that the -task 24 group recommended.
25 The maintenance backlog was identical to the
46 1
indicator that was corrective maintenance backlog greater than 2
three months old that INPO uses.
And they don't use it as an 3
overall performance indicator however.
It's one of their 4
other, other than their 10 indicators.
And it's a fraction of 5
the overall -- of the corrective maintenance work requests, 6
and it's for those requests that don't require an outage and 7
are more than three months old.
8 It's very interesting information.
The interactions 9
that we had with industry, however, were that each utility has 10 a different scheme for maintaining their maintenance records.
11 Some of them include the sink in the control room kitchen 12 on their maintenance backlog list, and some include groups of
/
13 equipment like the entire low pressure coolant injection
\\
14 system.
Maybe that's an exaggeration.
15 But the point that the industry representatives made 16 was that that one was clearly not one that was comparable 17 between utilities.
And further, if the NRC pressed it, it's 18 one that the utilities might change their scheme to look 19 better in the record.
And so, industry didn't want that as a j
20 possibility.
They felt that each utility should have its own 21 system and maintain it in the fashion that they have in the 22 past.
i 23 So it's one that INPO is looking at, and continues 24 to as an item of interest.
But industry urged us not to use l
25 that one as one that we would trend.
And the Staff then
- - - - - - - - - ~, - - - - - - -. - - - -
47 1
agreed.
It was a concern we had in the task group.
The task 2
group, however, recommended it and we rescinded it and the 3
task group does now allow.
4 COMMISSIONER ASSELSTINE:
Ed, are there ways, even i
5 if those arguments are legitimate and the idea of cooking the 6
numbers or keeping track of the information in a particular 7
way to make the plants look on the positive side troubles me a 8
little bit.
But even if that's a valid argument, maintenance 9
is terribly important.
10 Is there a way to develop some surrogates that will 11 provide you an cbjective indicator ofthow the plant is doing?
12 (Commissioner Roberts left the room.]
z' 13 COMMISSIONER ASSELSTINE:
For example, numbers of or 14 items of equipment out of service and for how long.
Maybe 15 further breaking down your safety system failures.
How often 16 do trains go out?
It's not just a question of whether you've 17 got HPCI or ADS, it's a question of how often those things are 18 out of service.
19 So are there some surrogates that can give you some indicators of maintenance performance that gets around this 20 21 question of the differences in the way the utilities track the 22 backlog?
23 MR. JORDAN:
Yes, sir.
We do have one that's 24 equipment forced outages per 1,000 critical hours that I'll
\\
25 describe.
48 1
COMMISSIONER ASSELSTINE:
Yes.
2 MR. JORDAN:
And the Staff also has a very strong 3
urge towards development of cause codos across the other 4
indicators, with maintenance being one of the ca.use codes we 5.
want to pull out.
6 So that, for instance for scrams, if it's a scram 7
due to a maintenance error or problem, then we'd like to be 8
able to have that level of detail.
Not as an indicator, but 9
as an added level of detail so that one can look across a 10 particular plant and decide that maintenance is a problem or 11 personnel error is a problem or some other feature.
12 COMMISSIONER ASSELSTINE:
Okay.
{
13 MR. MURLEY:
My name is Tom Murley, regional 14 administrator. Commissioner, I just have to say that this is 15 not going to replace the inspection program.
16 COMMISSIONER ASSELSTINE:
Yes.
17 MR. MURLEY:
So we are still going to be looking at 18 some of the things like maintenance very carefully.
I think 19 it will help us where to look.
20 COMMISSIONER ASSELSTINE:
Fair enough.
i 21 COMMISSIONER CARR:
But this is the biggest hole in 22 your indicators.
I don't know how you're going to plug it, 23 but you've got to find a way to plug it and you've got to put 24 it in there.
25 COMMISSIONER ASSELSTINE:
That's right.
49 1
COMMISSIONER CARR:
Why don't you use something like 2
mean time between repair?
I mean, that doesn't vary.
3 MR. JORDAN:
Let's go to the next slide.
4 (Slide.]
5 COMMISSIONER CARR:
But just as important to me, if 6
that guy didn't fix his john as it is if he didn't fix his 7
reactor.
It's an attitude of management.
8 COMMISSIONER BERNTHAL:
I have to tell you in that 9
regard a quick story here from when I visited --
10 (Laughter.]
11 COMMISSIONER BERNTHAL:
It's not quite exactly what 12 you were talking about.
/
13 (Laughter.]
14
[ Commissioner Roberts returned to the room.]
15 COMMISSIONER BERNTHAL:
When I visited the Finland 16 plant at Lavisa, those are the Russian nuclear steam supply 17 systems, a year and-a-half ago or whenever it was, the young, 18 aggressive, dynamic, I must say, Ph.D. nuclear engineer who 19 was responsible for the original operation and staffing of 20 that plant accompanied us.
And we walked in the front door of 21 the plant with him, and the first thing -- or one of the first 22 things that struck your eye was a clock above the door which 23 had the wrong time.
24 And I have to say, I was somewhat shocked at the 25 length to which t'at manager went in chewing out the plant
50 manager who was standing in front of us because their clock 1
2 didn't have the right time on it.
And it was as though I 3
wasn't even there.
I don't think this was a show for me.
And 4
he was adamant about the fact that he didn't want people 5
thinking that they didn't know how to tell time.
6 So it's exactly the point you mentioned that --
7 COMMISSIONER CARR:
We want to encourage the fix it 8
now concept all over the plant.
9 COMMISSIONER BERNTHAL:
That's the point.
10 COMMISSIONER CARR:
So I don't know how you're going 11 to -- you've got to come up with something.
12 MR. JORDAN:
We do have one, and on your chart it's 13 overall maintenance indicator.
And that was based on the NRR 14 division of human factors overall maintenance program.
15 They've had a program of performance indicators that they've 16 been working on for quite some time.
So this was an input 17 into this system.
So that's a composite indicator.
18 However, we found in looking back that that 19 composite was composed of some of the other indicators that we 20 had selected.
So we have pared down that composite to be what 21 amounts to the mean time between forced outages caused by 22 equipment failures due to maintenance.
So that's the 23 indicator that you were talking about, Commissioner Carr.
And 24 for statistical purposes we have it listed now in the document i
25 as equipment forced outages per 1,000 critical hours.
That's
51 1
one that -- that's just the inverse of the mean time between 2
forced outages and works better in our statistical --
3 COMMISSIONER CARR:
That tells me how many times it 4
fails.
It doesn't tell me how long it takes them to fix it.
5 COMMISSIONER ASSELSTINE:
Yes.
6 MR. JORDAN:
That's true, it's the repetition rate 7
and how many times it fails.
8 COMMISSIONER CARR:
And I'm worried about their
+
9 approach to fixing something.
10 MR. JORDAN:
And we're not satisfied with the 11 maintenance.
We gave up the maintenance backlog with some 12 trepidation.
So that's one that is also extremely high on our f
13 list.
14 COMMISSIONER CARR:
Well, I'll agree that will tell 15 me that.
If you'll now tell me the mean time to repair it 16 then I'll be all right.
I can get where I want to go.
17 COMMISSIONER ASSELSTINE:
In fact, the mean time to 18 repair, I think, has a direct relationship to the enthusiasm 19 with which people identify problems.
If they don't get fixed 20 they quit reporting them.
21 CHAIRMAN ZECH:
And fixing them, too.
22 COMMISSIONER ASSELSTINE:
That's right.
23 COMMISSIONER BERNTHAL:
Let's see, make sure I 24 understand here.
You've dropped overall maintenance indicator 25 and you've picked up maintenance backlog, or is it the other 1
52 1
way around?
2 MR. JORDAN:
No, no.
3 COMMISSIONER BERNTHAL:
What are we doing here?
4 MR. JORDAN:
Okay, I'll restate.
The overall 5
maintenance indicator was from the human factors maintenance 6
program, and they have a set of performance indicators that 7
they applied to come up with that value.
8 COMMISSIONER BERNTHAL:
And that's the one you're 9
going to use?
10 MR. JORDAN:
And that's the one that we tested in 11 the trial, and then determined that the indicators that we had 12 selected, for instance, were composed of many of the things
/
13 that are already in this overall maintenance indicator; the i
14 automatic scrams and so on.
So that indicator was to some 15 extent an overall plant indicator.
16 COMMISSIONER BERNTHAL:
Okay.
17 COMMISSIONER ASSELSTINE:
So they're not going to do 18 that.
19 MR. JORDAN:
So one that was not in it was this mean 20 time between forced outages.
So then we boiled it down to 21 that being the indicator that we would use out of the human 22 factors program as the maintenance --
23 COMMISSIONER BERNTHAL:
Where's maintenance backlog 24 then?
25 COMMISSIONER ASSELSTINE:
It's out.
53 1
COMMISSIONER BERNTHAL:
That appears in the SECY 2
paper.
That's out now?
3 COMMISSIONER CARR:
It's not in there.
4 COMMISSIONER BERNTHAL:
What is your maintenance 5
indicator then remaining?
6 MR. JORDAN:
Equipment forced outages per 1,000 7
critical hours.
8 COMMISSIONER BERNTHAL:
I don't agree with --
9 COMMISSIONER CARR:
That isn't a maintenance 10 indicator, that's a failure indicator.
11 COMMISSIONER BERNTHAL:
I have to agree with the 12 acmiral on the other end of the table.
I think you've dropped 13 out an effective maintenance indicator.
{
14 COMMISSIONER ASSELSTINE:
I agree as well.
15 MR. STELLO:
That, as well as several others, it 16 needs further week, I agree.
We're not here to tell you these 17 are the correct, the right indicators.
18 COMMISSIONER CARR:
The only message I want to get 19 across, this one is critical.
20 MR. JORDAN:
Yes, sir, we agree.
21 MR. STELLO:
If the Commission allows us to go 22 forward we certainly will jet back to working on them.
But 23 it's the concept we're talking about.
24 CHAIRMAN ZECH:
I agree with Commissioner Carr.
i' 25 Maintenance is probably the most difficult one to come up but
54 1
also extremely important.
We've got to figure out a way to 2
get maintenance in this program.
3 MR. STELLO:
And we will try.
You do recognize --
4 CHAIRMAN ZECH:
But it's very difficult to do that.
5 MR. STELLO:
-- that INPO is collecting a lot of 6
information on maintenance as part of what they're doing.
7 They have offered in a letter we received yesterday to 8
cooperate freely with us, and in fact they have.
9 COMMISSIONER CARR:
We'll take all the help we can 10 get.
11 MR. STELLO:
And we'll look at everything that we 12 cun.
And if maybe there's a way to look at what they're
{
already collected that will give us those kinds of insights 13 14 we'll certainly want to do that.
But we need to do more 15 work.
We're not finished.
16 CHAIRMAN ZECH:
All right, let's go.
17 COMMISSIONER ASSELSTINE:
It sounds like the message 18 though from this side of the table is, your top priority on 19 your next indicators ought to be on maintenance.
20 CHAIRMAN ZECH:
I don't know if it's the top 21 priority, but it's one that has to be in there.
But we also 22 recognize, I think, on this side of the table how difficult it 23 is.
And I certainly recognize it can be gimmicked, and I can 24 understand industry's concern because we don't want to -- what 25 we want to do is have a maintenance program that fixes things
,e 55 1
when they need fixing and fixes them quickly.
But we want an 2
indicator on maintenance that will be something that will be 3
positive and constructive and, hopefully, can't be gimmicked.
4 We recognize it's difficult, but I think we're also 5
telling you we really need a maintenance indicator.
We think 6
it's so important and we ask you to do further work on it.
7 MR. JORDAN:
And we agree.
The last one --
8 COMMISSIONER ROBERTS:
I also agree that the list --
9 with dropping the maintenance backlog as purely a listing of X 10 number of items.
That is absolutely unworkable and would lend 11 itself to all sorts of mischief, both o-the part of the NRC 12 and the licensees.
It's more complex than a listing of number 13 of open maintenance items.
14 MR. JORDAN:
Yes, the Staff agrees.
15 CHAIRMAN ZECH:
But also the backlog, if it just 16 stays large and gets larger, that might tell us something, 17 too.
So I'm not so sure that we should throw it out 18 completely.
It's a challenge to you, that's what we're 19 telling you now and we ask you to work on it some more.
20 MR. JORDAN:
We feel challenged.
That one is tough.
21
[ Laughter.)
22 MR. JORDAN:
Enforcement action index.
This is one 23 also that industry said, please don't use it.
We don't like 24 it, we don't want it, and this is one --
25 COMMISSIONER CARR:
I think it's the least
56 1
independent one you've got.
2 COMMISSIONER ROBERTS:
The most subjective.
3 MR. JORDAN:
It's interesting.
4 COMMISSIONER CARR:
You would never take action if 5
you didn't already have a problem you've turned up-somewhere 6
else though.
7 MR. JORDAN:
It is a multiplier on some of the other 8
issues.
But I have to tell you that that particular one 9
correlated most strongly with SALP of all of the indicators.
10 COMMISSIONER CARR:
But you don't find them unless 11 you think they're bad.
12 MR. JORDAN:
It's perhaps a self-fulfilling 13 prophecy, and that's the position that the utilities raised.
14 MR. STELLO:
If you look at that particular 15 indicator and you look across the plants and you make 16 judgments of overall plant performance that you think has been 17 generally good, bad or indifferent, I think you find some 18 correlations with the enforcement index that don't think.
19 And that is that you have plants where the 20 performance is indeed good and the enforcement index is coming 21 out high.
And on the other hand, you have poor where the 22 enforcement index is going the other way.
23 COMMISSIONER BERNTHAL:
But Ken's point is that why 24 don't you have a performance indicator on here?
Just like an 25 enforcement action index.
57 1
COMMISSIONER CARR:
The problem there is that that's 2
not predictive.
3 MR. STELLO:
I want to finish making my point.
4 Maybe it's a useful idea, at least for the moment, to keep 5
this here to give us some understanding, is the way we're 6
going about enforcement the right way?
Are we getting the 7
results out of enforcement we think we're getting?
We think 8
enforcement is producing changes in performance.
If carrying 9
that index shows that maybe we're not, it isn't working that 10 way or there's something about it, perhaps we can learn about 11 one of the major programs of this agency -- enforcement -- and 12 how to do it better.
13 As I look through it, it's suggesting to me 14 something I'd like to see kick around for a while because I 15 think it at least offers the potential to help us decide, are 16 we really doing enforcement in a way that's helping or 17 hurting.
18 COMMISSIONER BERNTHAL:
But it is not a performance 19 indicator.
It is not.
It is an evaluation of an evaluation.
20 MR. STELLO:
I think you could make the argument 21 both ways, but I was trying to offer yet another reason for --
22 COMMISSIONER CARR:
Yes, if you want to use if for 23 that, I support it.
24 COMMISSIONER ASSELSTINE:
Yes, that's right.
25 CHAIRMAN ZECH:
And I think that's the right thing
58 1
to do, tco.
I think it is useful in a sense.
But again, it 2
does take a careful definition of what you're doing and an 3
understanding of what you're doing.
I think it's useful to 4
have there.
It's a tool, take a look at it.
5 COMMISSIONER BERNTHAL:
If you want to know the 6
truth, it's an indicator of our performance.
7 COMMISSIONER ASSELSTINE:
It's also an indicator of 8
responsiveness, I think.
9 CHAIRMAN ZECH:
Over a period of time, I agree.
10 MR. STELLO:
It does all those.
11 CHAIRMAN ZECH:
If it requires many, many 12 enforcement actions over time it's going to tell you 13 something.
{
14 COMMISSIONER ASSELSTINE:
That's right.
15 COMMISSIONER BERNTHAL:
I don't want to quibble over 16 it, but it does not fall within the definition as what we 17 normally make it.
18 CHAIRMAN ZECH:
Let's go on.
19 MR. JORDAN:
All right, sir.
I'll just define it as 20 an index.
It accumulates enforcement actions in a given 21 period of time and then weights them with the severity levels 22 that are in Part II.
So that for instance, the most stringent 23 severity Level I would have a times 20 weight, and the 24 weakest, the simplest, Category V would have a one weight, and 25 a gradient in between.
59 1
CHAIRMAN ZECH:
I think we've talked enough about 2
the specific ones.
Now we recognize you're still developing 3
them, but I think we ought to just move along.
4 MR. JORDAN:
That simply lists that INPO has an 5
additional series of indicators, and those are not overall 6
performance indicator as such.
7 Could I back up to the previous slide?
I want to 8
make one point.
9
[ Slide.]
10 MR. JORDAN:
If you'll look at the double asterisk i
11 INPO indicators there, there are five:
equipment availability 12 factor, thermal performance, fuel reliability, volume of low
(
13 level solid radwaste, and industrial safety lost-time accident l
14 rate.
Those are five of the total of 10 INPO overall 15 performance indicators.
Those are not indicators that the NRC 16 Staff recommended be adopted for safety purposes.
I just 17 wanted to make that point.
18 CHAIRMAN ZECH:
But my view is we should have an 19 indicator that in some way or another concerns itself with 20 exposure.
That's our business, safety, and it seems to me you l
21 need to do that.
22 MR. STELLO:
We have a separate special program 23 monitoring that as a measure of how well the.INPO program that 24 we agreed to let them implement is doing, and make a special 25 note of that.
4 e
s--,----~~
- - - - - + - -, - _. - -, - - - -,, - -.
--,------------,-,-re-----w-
+,,--e-
-;,m.,- - - - - - - - - - - - -, - - - - - - - - -. - -
--wae
60
.o 1
CHAIRMAN ZECH:
Yes, I think you should look into it 2
and try to figure out how to make it a performance indicator.
3 MR. STELLO:
We already have all of the data.
4 CHAIRMAN ZECH:
Exposure is important to us.
5 COMMISSIONER CARR:
As you leave the indicators, I 6
support Commissioner Asselstine on training.
If it's only the 7
simple, how many failures versus how many exams we give, 8
that's an indicator and training is very important and we 9
shouldn't overlook it.
10 COMMISSIONER ASSELSTINE:
Yes.
11 CHAIRMAN ZECH:
I agree with that, too.
12 MR. JORDAN:
I'd like to skip over the coordination
(
13 with industry and go to the sample report format briefly, 14 number 15.
15
[ Slide.]
16 COMMISSIONER CARR:
I might suggest you don't call 17 this a report.
You might call it a data gathering or 18 something.
19 MR. JORDAN:
All right, sir.
20 CHAIRMAN ZECH:
All right, let's move along.
21 MR. JORDAN:
I'd like to show you the large chart 22 just simply to identify the data that's in the file.
This 23 would be page 16A.
24 (Slide.]
25 MR. JORDAN:
We've circled one plant's listing.
The
.-r
l i
61 i
1 object is that the data file and the report would identify the 2
latest SALP scores, the date of the last report and then give, 3
for instance -- I'll pick safety system actuations -- the 4
four-quarter average ending for that quarter that ends as of 5
the time of the report, and then this particular quarter, the 6
last quarter's data for safety system actuations.
7 So that's the format that the data is maintained.
8 And one can derive all of the charts, all of the information 9
from this plus the grade book operating history.
So let's go 10 to the first finger chart, page 17.
11
[ Slide.]
12 MR. JORDAN:
This is for example purposes only to 13 identify how the data is displayed.
The top chart is a trend
- \\
14 chart, and we're comparing by standard deviations the previous 15 four-quarter mean with the present most recent quarter.
And I 16 have to say that during the review, it may be more useful to 17 compare it with two quarters and to back up and go six 18 quarters.
The data is noisy, so we may get better stability 19 by different timeframes.
But this was a very useful display 20 as it was.
21 So you can go down through each indicator -- and 22 I',ll pick scrams.
Now, Commissioner Roberts, you had a 23 concern about showing the various scrams.
We have them 24 depicted.
For instance, for this particular plant there was a i
25 decline.
That is, they had a higher overall scram rate during
I 62 l
1 this particular quarter compared to the previous four quarters i
2
-- substantially higher.
And the greater than 15 percent per 3
1,000 critical hours scrams were higher, as you would expect.
4 If you would switch to page 18?
5
[ Slide.]
6 MR. JORDAN:
The dashed line that dips and has jags 7
represents the critical hours.
So from this chart, if you're 8
concerned about whatever the scram data says, then you can see 9
that the plant during this most recent quarter was operating 10 most of the time -- 1846 hours0.0214 days <br />0.513 hours <br />0.00305 weeks <br />7.02403e-4 months <br /> out of the roughly 2200 per 11 quarter.
And so that data is good, and you would expect 12 agreement between the greater than 15 percent and the total.
13 And there were no trips below 15 percent power, so there's no 14 data at all.
15 This more detailed chart also allows you to see that 16 the scram rate per quarter over the past eight quarters has 17 varied, and how it's varied, and what the overall industry 18 average is.
This is a back-up that when one raises a question 19 from the trend data, then you can look at more detail, look at 20 the plant operating history, and look at the previous data 21 over a two-year period.
22 The bottom chart is the deviations from industry 23 means.
And this is based on a four-quarter average against 24 the industry four-quarter average for that same period.
So l
25 you can see that for this particular plant, all of their i
i
. _ _ _ _ _ _ ~ _. -. _ _. _ _ - _ _ -. _. _ _. _ _ _. -..., _ _ _ _ _. _ _. _ _ _. _ _. - _
63 1
performance indicators were better than the industry average.
2 So this plant has a quite consistent picture, both in its overall performance against the industry average, 3
and 4
in terms of its trends.
Curiously, its trends are down for 5
the most recent quarter, and its overall average performance 6
over the past four quarters including this one is above 7
average.
This is not a plant that we.would have a great 8
concern with.
9 COMMISSIONER BERNTHAL:
What's your provision here 10 or methodology?
It seems to me you ought to have some method 11 here of dealing with statistics of small numbers?
12 Commissioner Roberts pinpointed such an example earlier.
13 There's always a tendency in this agency, and in many other 14 places, to fail in the very important task of treating 15 uncertainties.
16 If you've got a tiny number here, it can show up as 17 a huge bar and be absolutely meaningless.
Are you going to 18 deal with that in some way?
19 MR. JORDAN:
Yes.
20 COMMISSIONER BERNTHAL:
That ought to be reflected 21 in your bar somehow.
I don't know.
22 MR. JORDAN:
The statisticians have worried about it 23 and are counseling us in ways that we can identify anomalies 24 in that fashion.
And that is an ongoing development.
25 COMMISSIONER BERNTHAL:
Maybe you need a different
_-,---.g
_ ~.
,,._wy,m.
64 1
level of shading or something to indicate the uncertainty 2
region there.
3 MR. JORDAN:
Yes, and averaging over a longer period 4
of time as the management group suggested, helps; reduces that 5
erratic nature of the small numbers.
6 COMMISSIONER CARR:
If the SALP goes from 18 or 19 7
months, it seems like you ought to average over that period of 8
time.
9 MR. JORDAN:
Yes, and the SALP period, of course, is 10 set where this would be a rolling average.
That is one of the 11 proposals.
12 COMMISSIONER CARR:
Then you can predict what the 13 next SALP ought to look like.
\\.
14 COMMISSIONER BERNTHAL:
No, but you can't average a 15 period that long or it will take two years figuring out who's 16 in trouble, and there's no point in doing it then.
17 COMMISSIONER CARR:
You don't, because you get a 18 data point --
19 COMMISSIONER ASSELSTINE:
Every quarter.
20 COMMISSIONER CARR:
Ought to get one earlier than 21 every quarter, won't we?
22 COMMISSIONER BERNTHAL:
That's differential.
That's 23 fine.
24 MR. JORDAN:
Could I have page 20?
25
[ Slide.]
i 4
65 1
MR. STELLO:
Our plan is once per quarter.
2 COMMISSIONER CARR:
Once per quarter.
3 COMMISCIONER ASSELSTINE:
Is that frequent enough?
4 MR. JORDAN:
The data at this point won't support 5
looking at it very hard over a shorter period of time.
The 6
regions then find issues that are happening more rapidly than 7
that.
This data, I don't think --
8 COMMISSIONER CARR:
I think quarterly ought to be 9
enough.
10 MR. STELLO:
I think we'll get a couple of quarters 11 under our belt.
12 CHAIRMAN ZECH:
I think quarterly is a good way to
[
13 start.
14 MR. STELLO:
It is a good way.
We're changing --
15 we'll change it to anything you want.
But I don't think the 16 data changes fast enough to warrant any much more --
17 COMMISSIONER ASSELSTINE:
That's true.
Yes, if a 18 plant has six scrams in two weeks we've got other ways to 19 focus on them.
20 COMMISSIONER CARR:
They get recognized --
21 MR. JORDAN:
That's right.
Okay, the 22 recommendations.
The continued development work, clearly we 23 have a number of areas.
You've mentioned a number of them 24 here this morning.
The personnel radiation exposure is one 25 that we're looking further at.
.O 66
,o 1
Predictive indicators, we're anxious there.
For 2
instance, the maintenance backlog that we gave up was a 3
predictive indicator.
We're very interested in the systems 4
and cause codes as a further detail that we can examine.
5 The LCO action statements we talked about we want to 6
develop further, and that's related to train unavailability.
7 And we want to go further with the direction of the 8
reliability risk base of the indicators to support real safety 9
issues, real risk.
10 And there were considerations that came out of the 4
11 October management meeting I've mentioned already.
I guess 12 one I didn't mention was grouping the plants a little 13 differently so that we grouped PWRs and BWRs separately and 14 separated out new plants.
That's very easy to do and we've 15 done it in another set of data and it is quite meaningful to 16 have the population you're looking at be a similar population.
17 I've finished my presentation.
18 CHAIRMAN ZECH:
Thank you very much.
19 MR. STELLO:
One last point, we did -- yesterday we 20 got a letter from INPO and I had talked to Zach Pate so that I 21 would be sure that, confident that I was fair in representing 22 the intent and the purpose of that letter.
23 We have had, I think, and he confirmed, fairly good 24 relationships and moving forward and developing indicator 25 programs.
And the purpose of the letter was to remind the
es 8
t 67 1
Commission that there are a number of areas you need to be 2
very sensitive and careful about.
We agree with them.
We 3
don't have any disagreement at all.
And the particular overall thrust of the letter was to try to make that point.
s 5-The one point that he does make, and I started out, 6
is to suggest in a fairly strong way that he recommended the 7
Comnission not adopt the performance indicators -- and maybe 8
I'd better use the exact language so that I don't --
9 COMMISSIONER ROBERTS:
"For use in a formal 10 regulatory sense."
11 MR. STELLO:
That's precisely it.
What he intended 12 by that '- and I explored this to make sure I understood it --
13 is he.did not want, an'd would be very concerned if we in fact 14 did adopt performance indicators and take regulatory action on
~
15 the basis of the indicators themselves.
That was never our 15 intent.
We don't believe you can do it.
We don't want to do 17 it, nor were we ever even hinting and suggesting that in'the 18 final days of performance indicator development you would do 19 that.
l I
20 COMMISSIONER BERiTi h(:
fait a minute, hold on.
21 You're not going to sit there and tell us that the intent was 22 never to use these indicators as a basis, in part at least,
~2 3 for regulatory action.
24 MR. STELLO:
No, there's no problem with in part.
25 It's as a basis by themselves for the regulatory action.
That
68 1
is a yardstick.
If these indicators fall outside of X, you 2
take an action.
We don't propose to do that, and that's what 3
he was --
4 COMMISSIONER ROBERTS:
But you certainly could.
5 MR. STELLO:
You're free to do anything you want to 6
do, or make any judgment you want to.
That's not what we're 7
proposing at all.
8 COMMISSIONER CARR:
Not only on the indicatcrs.
9 MR. STELLO:
On anything else.
10 COMMISSIONER CARR:
No, I mean, you wouldn't take 11 enforcement action based on indicators alone.
12 MR. STELLO:
Never, you couldn't.
'{
13 CHAIRMAN ZECH:
That's not what they're for.
14 COMMISSIONER ASSELSTINE:
That's right.
15 MR. STELLO:
It's a tool.
And then I finally asked 16 him the question, if we did in fact, with the reservations 17 that he has and concerns, properly use performance indicators 18 does he concur with the NRC continuing development of them, 19 and the answer is yes.
20 CHAIRMAN ZECH:
All right.
Anything else?
21 MR. STELLO:
No.
22 COMMISSIONER CARR:
Can I bring up one thing?
23 Somehow you've got to put in here some factor that takes care 24 of the repetitive type things that happen.
As you said, if 25 the same pump fails 16 times in a row, sooner or later that's
69 1
got to fall out so that we notice it.
l' '
2 MR. JORDAN:
Yes, sir, that would be through a cause 3
code type determination.
4 COMMISSIONER CARR:
All right.
5 CHAIRMAN ZECH:
All right.
Any questions from my 6
fellow Commissioners?
7 COMMISSIONER ASSELSTINE:
I had one other one.
8 Could you talk a little bit about how the performance 9
indicator program is going to fit in?
Admittedly, it's not 10 going to be a basis for regulatory action on its own.
How is 11 it going to fit in in the process?
How are the regions going l
12 to use it?
How does it fit in with the new team inspection
/
13 program, Vic, that you proposed the end of September?
How are 14 we going to use these indicators as a tool?
How are we going 15 to use them to focus in on plants and identify plants that we 16 are concerned about?
To perhaps make decisions on plants that 17 we're not concerned about?
18 MR. STELLO:
Let me speak to that very broadly 19 first.
It's my intent to hold, at about six-month intervals, 20 meeting of the senior management of the agency to get together 21 and speak to this very issue of overall performance of plants, 22 to try to assure ourselves the plants for which there's a need 23 for further regulatory aotention, we know what they are and 24 make sure that we're doing what we ought to do.
25 We intend to use this, with the Commission's J
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70 1
concurrence, and I think it's very important to do so, as one 2
of the tools of many others.
We clearly will have the SALP 3
reports.
We'll have LER data.
We will have -- to the extent 4
we have indicator data.
We'll have the results of the 5
inspection programs and take those all together and use it as 6
one of those inputs, just in the way we use SALP today as an 7
input in helping to make that judgment.
To me, that is 8
perhaps the most important and significant application of 9
them.
10 On a day-to-day basis, the program office directors 11 and the regional administrators, when these reports come out I 12 expect that they will review these reports and look at whether
(
13 they, in fact, suggest raising certain questions or deciding 14 that perhaps there's more questions to look at.
Maybe even a 15 need for further inspections and what kind, and in what 16 areas.
17 It will be used as a tool to help us regulate and 18 regulate better in every way we can.
I don't think we have 19 very good answers to that question, and I don't think we ever 20 will have good answers to that question until we've had more 21 experience.
I think the right time --
22 COMMISSIONER CARR:
But for a while, it will be just 23 telling you, is it a true indicator of what's really going on 24 at the plants.
25 COMMISSIONER ASSELSTINE:
That's right.
t
71 1
CHAIRMAN ZECH:
That's how you get started.
2 MR. STELLO:
That's what I propose to begin with.
3 CHAIRMAN ZECH:
Anything else?
t 4
COMMISSIONER ASSELSTINE:
No.
5 CHAIRMAN ZECH:
Commissioner Bernthal?
6 COMMISSIONER BERNTHAL:
Yes, I have some questions 7
and a comment or two.
First of all, as I go down this list 8
now, going back to the NRC-INPO comparisons, taking a naive 9
view, what are we doing that they aren't doing better, if I 10 may say so?
11 MR. JORDAN:
The INPO indicators are split between 12 operations, reliability, and some safety items.
Ours are not
{
13 looking at the thermal output the plant --
14 COMMISSIONER ROBERTS:
Which is of no concern to us.
15 MR. JORDAN:
That's correct.
16 MR. JORDAN:
So we have adjacent sets.
17 COMMISSIONER BERNTHAL:
I agree, but you're saying 18 they are doing more in the area of plant performance.
But in 19 the area of safety even, if I go down point by point on the 20 ones that you've chosen, I think I only see one -- no, do I 21 see one -- obviously not enforcement action index, which 22 probably shouldn't be there anyway, but I don't care to fuss 23 over that.
All the others are there on INPO's chart, and a 24 lot more, including many that various members at the table 25 here suggested are important, that are not on ours.
72 1
MR. JORDAN:
The others that they have on their list 2
are not as -- their set of 10 performance indicators.
And 3
I'm sorry yours doesn't have the double asterisk arrangement 4
that we put on the slides.
But the scrams, safety system 5
actuations, safety system failures, forced outage rate and 6
collective radiation exposure are the five that INPO has that 7
are similar to ours, and in three of the cases, identic la.
I 8
COMMISSIONER BERNTHAL:
Significant event frequency, 9
of course, we know they have a major program where they 10 monitor -- and have for a long time -- where they monitor that 11 sort of thing.
12 MR. JORDAN:
But they don't have it included as an 13 indicator at this time.
14 COMMISSIONER BERNTHAL:
No, for reasons that escape 15 me.
But is surely is an INPO indicator.
16 MR. JORDAN:
And they don't have causes of events, 17 which is one that we plan to develop very strongly.
And the 18 LCO action statements they don't have, that we are anxious to 19 develop.
4 20 COMMISSIONER BERNTHAL:
So you're going to develop a 21 number of additional ones to the ones you have here?
22 MR. JORDAN:
So we expect to fill in, yes, sir.
23 COMMISSIONER CARR:
Plus I don't think we're privy I
24 to their performance indicators.
25 COMMISSIONER ASSELSTINE:
That's right.
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73 1
COMMISSIONER BERNTHAL:
I don't disagree with that, 2
and I believe we should not be privy to --
3 COMMISSIONER CARR:
I'm happy to have them do their 4
program, and I'm happy to -- we've got a responsibility to 5
look, too.
6 COMMISSIONER BERNTRAL:
True, but utilities have, 7
what with yet another inspection program, how many of these 8
things do we need, I guess is the question.
But let me go on 9
here.
10 COMMISSIONER CARR:
This is not to interfere basis 11 with the utility's normal way of doing business, isn't it?
12 MR. JORDAN:
No, this is transparent to the 13 utilities in terms of the collection --
14 COMMISSIONER BERNTHAL:
I understand that.
Have you 15 gone -- I know you've gone to Europe, but have you compared 16 what the Europeans might be doing in this area with what we're 17 proposing to do here?
18 MR. JORDAN:
Yes, sir.
That was the IAEA.
19 COMMISSIONER BERNTHAL:
I saw the IAEA, but I don't 20 consider that Europeans.
I mean, that's an international 21 effort, which is rather small, if I may say so.
What are the 22 Germans doing?
What are the Swedes doing?
23 MR. STELLO:
Jack is our representative on the group 24 that does this through the European countries and CS&I, and I 25 think he may be able to answer your question.
74 1
MR. HELTEMES:
I can give some background on the 2
question, at least.
When we get together with the major 3
European --
4 CHAIRMAN ZECH:
Jack Heltemes from AEOD.
5 MR. HELTEMES:
Jack Heltemes, AEOD.
L 6
CHAIRMAN ZECH:
Thank you.
7 MR. HELTEMES:
We get together on the major 8
countries that we share a lot of information with.
That's 9
France, Germany, Japan, and some of the smaller countries, 10 Belgium, Switzerland, The Netherlands.
We share a lot of 11 information on event type of things that happen.
But when it 12 gets to rates, when it gets to scram data, when it gets to ESF
('
13 actuations, when it gets to the numbers of significant events 14 on a plant specific basis, many of these countries are very 15 reluctant to discuss that type of information.
They do not 16 make them public.
17 So we've been very successful in getting some 18 information from various countries, but not across the board.
19 And we have never gotten to the point where we are here, where 20 they have a defined program, to my knowledge, underway in 21 their programs in their countries.
22 COMMISSIONER BERNTHAL:
Have we even learned what 23 kind of data and what information they compile, let alone 24 giving it to us?
That's actually not what I'm interested 25 in here.
The question is, do they have similar programs where
75 1
they are monitoring certain parameters like this and compiling 2
the data on them, which is what this really amounts to?
3 MR. HELTEMES:
In many countries the answer is no.
4 For example, there was a scram symposium in Japan and some 5
countries had to spend a great deal of time to go back to 6
their records to pull out that information on basic numbers of 7
8 So I can tell you, many countries do not actively 9
collect statistics like we're doing here.
10 COMMISSIONER BERNTHAL:
Do they have an opinion on 11 the wisdom and value of doing so?
Have you talked to them?
12 MR. HELTEMES:
I have not talked to them from the
(
13 standpoint of performance indicators.
We've only talked to 4
14 them from the standpoint of understanding their experience in 15 order to make a judgment, can we learn from it.
16 COMMISSIONER BERNTHAL:
I have to say I'm a great 4
17 believer in data and gathering data in a way that it makes it 18 useful.
And I think that's really what we're talking about 19 here.
I have no objection at all to what you've done.
It's 20 probably something we should have done years ago.
It l
21 certainly is in a form that's new and more useful than it's 22 ever been before.
So in that regard, we clearly are finally 23 doing something we should have done before, and I think the 24 Chairman deserves a good deal of credit for taking that 1
i 25 initiative.
76 1
Having said that, I'm a congenital skeptic about 2
smart people in Washington with computers and what they tend 3
to do with them.
We should bear that in mind, I think, as we 4
move ahead with this kind of program.
My early concern here 5
is, as you know very well, Vic, is that this was a trojan 6
horse, if I may coin a phrase here, for a return to the old 7
general operating criteria that this Commission rejected with 8
some resolution a few years back, a couple years back.
9 It clearly is not that now.
We're down to a rather 10 bare bones, elemental list of performance indicators.
In 11 fact, I have to say I'm somewhat wondering whether the bones 12 aren't so bare that we're coming in a poor second best to what 13 INPO is already about.
But as I understand it, you intend to 14 put more flesh back on the bones.
15 COMMISSIONER ROBERTS:
Wisely.
16 COMMISSIONER BERNTHAL:
Wisely we all hope.
17 COMMISSIONER ROBERTS:
No, that's not a given.
18
[ Laughter.]
19 COMMISSIONER BERNTHAL:
I do have a very broad 20 question to ask though, and that stems from my concern that we 21 are not going to make a mistake now with respect to operations 22 and the often subjective evaluations that go into plant 23 operations judgments.
That we're not about to make the 24 mistake there that many people say we made in respect to 25 backfits, hardware backfits after the TMI incident.
77 1
We all know we're embarking on an era here of new 2
focus on plant operations and that's all good.
But when I see 3
the EDOs recent memorandums on "new inspection methods."
And 4
I think of performance indicators, and I tally a list of all 5
of the inspections we already have, there must be half a 6
dozen, seven or eight different inspections we already 7
perform.
I wonder to myself, have we sat back and taken a 8
broad look across the board at all these different things 9
we're doing now and decided whether we're overlapping, whether 10 we're really doing the most effective thing, the most cost 11 effective thing from our standpoint, I have to say, to get at 12 the answers we really need?
13 And the analogy to what we did not do in 1980 and 14 shortly thereafter, I think is very clear.
That's the reason 15 for my concern.
16 In other words, had we sat back and said -- had we 17 looked very carefully and said, now what is the most cost i
18 effective way to improve plant safety with a little more 19 retrospective look and a little more caution, we might have 20 done things considerably different on some of these hardware 21 backfits.
22 Can you speak to that briefly and assure me that you 23 are taking that kind of broad look and that we're not going to 24 do that as we seek to improve our inspections and regulation 25 of operations?
78 1
MR. STELLO:
The short answer is, we certainly would 2
never do that intentionally if we could avoid it.
I think 3
organizationally, however, we have been set up where a great 4
deal of that has gone on because of the organization we had.
5 But as you know, there's a proposed change.
6 When you give the responsibility and accountability 7
in one office for the entire safety of the facility, I think 8
you then have -- or should have -- I hope we all have, far 9
more confidence that those kinds of things you're concerned 10 about will not happen.
11 COMMISSIONER BERNTHAL:
Have you sat down and looked 12 at the broad sweep of all of our activities now as we're
[
trying to focus in on operations and improving our oversight 13 14 of operations?
If you haven't, you ought to do it, and decide 15 what we're doing that's most effective, and the most effective 16 use of our resources.
17 MR. STELLO:
I've answered it, yes, in the broadest 18 possible sense.
That's what prompted me to conclude that a 19 reorganization was in fact necessary to achieve that end 20 result.
21 COMMISSIONER BERNTHAL:
Okay.
22 MR. STELLO:
That new organization will in fact be 23 responsible for doing exactly what you just said.
24 Now with respect to performance indicators and where 25 we're going, I think that that ties together pretty
_, ~
79 substantially in the way in which I've described the 1
2 management meetings you want to hold every six months.
To try 4
3 to stand back and take a look at, have we been going in the 1
4 right directions with plants?
And if not, where do we need to j
5 change and put more emphasis and why, and do we really i
6 understand it?
4 7
I think the new inspection you're talking about, in 8
my view, is directly coupled to that kind of an activity.
9 COMMISSIONER BERNTHAL:
That's right.
10 MR. STELLO:
Where we have a plant and we're really 11 not sure and we want to go out and make a finding or a 12 diagnostic assessment of that.
That I think we've thought 4
13 through in terms of that limited -- but your question is in 14 fact much broader.
You're talking about the whole variety of 15 different kind of specifialized inspections, the PAT and the 16 CAT and the fire protection inspections and on and on and on.
4 l
17 And are all of those well-integrated and well thought out with 18 normal inspection program?
Have they been really, truly 19 coupled with the strength of the licensing process to make 20 sure that the weaknesses inherent in the licensing process are j
21 accommodated through inspections?
f 22 All of that -- has that all been done?
No.
The new 1
l 23 organization will in fact -- if the Commission concurs to go 24 forward with it -- do that.
i 25 COMMISSIONER BERNTHAL:
Good.
Let me just say that
80 1
-- again, I want to emphasize, I believe in information.
I 2
believe in gathering data and making use of the data you 3
have.
And if we can focus on that element of the performance 4
indicators, I think it's an excellent idea to do that and 5
probably should have done it a long time ago in a number of 6
these areas.
But I have expressed some concerns that I have.
7 CHAIRMAN ZECH:
Commissioner Roberts?
8 COMMISSIONER ROBERTS:
[ Shaking head negatively.]
9 CHAIRMAN ZECH:
Commissioner Carr?
10 COMMISSIONER CARR:
No.
11 CHAIRMAN ZECH:
Do any of the regional 12 administrators who I hope are still on the line have any
{'
13 comments to make?
Region I, any comments or recommendations, 14 Region I?
We have Tom Murley with us.
We'll ask him right 15 now.
16 MR. MURLEY:
Yes, I do have a couple comments.
I 17 think it's good that we have the performance indicators for us 18 to help us look for root causes and early warnings of problems 19 at a plant.
That is to say, if this program weren't going 20 forward we would have to do something like this almost on our l
21 own.
In fact, we had been doing something in the region.
And 22 I think the other regions had, too.
23 My staff feels kind of exposed not having this 24 information for us to look at, like scram rates and that sort 25 of thing.
So we're glad to have it.
i
81 1
I hardly need to mention that we see that the 2
benefits of this program, though, are going to depend 3
critically on the judgment of those people that use the 4
tools.
And we are somewhat nervous that -- and here, I guess 5
I'll expose our regional headquarters difference in 6
perspective.
We are somewhat nervous that the performance 7
indicators may be used by those down in the Staff in 8
headquarters as indicators of problem plants.
9 I am totally comfortable with the way that we're 10 using~them at the higher levels in the management.
B u t I ' m,-
11 again, nervous and my staff is that down in the Staff where 12 things don't always sometimes get paid attention to, that they
(
13 might be used as indicators of problem plants.
And I think 14 it's going to take real attention --
15 COMMISSIONER ROBERTS:
I share your concern.
16 MR. MURLEY:
-- to make sure that they're not 17 misused at these lower levels.
18 CHAIRMAN ZECH:
Thank you very much.
Region II, any 19 comments?
20 (No response.]
21 CHAIRMAN ZECH:
Region III, any comments?
22 MR. KEPPLER:
I would only add that I think the.ata 23 can be very useful to us in projecting a plant that is 24 somew' hat below average and helping us to focus on the root 25 cause problems ahead of time.
82 1
CHAIRMAN ZECH:
All right, thank you very much.
2 Region IV?
3 MR.
R. MARTIN:
I would echo the comments of the 4
other administrators, and just reaffirm, I believe what has 5
been stated several times.
And that is, this is one of a 6
whole series of tools that we use to add a perspective and to 7
help us in asking the right questions about a plant.
And we 8
consider it a good companion to other tools like SALP and 9
other indicators that we use.
And in that regard, it's a 10 useful tool.
11 We really do not believe that this is the device 12 that provides us answers, but rather gives us the prodding to 13 ask questions to pursue the answers that need to be sought 14 after.
So in that regard, we think it's a useful companion to 15 other tools we've developed for a similar purpose.
16 CHAIRMAN ZECH:
Thank you.
Region V?
17 MR. J. MARTIN:
I agree with the others.
This is a 18 very useful addition to the other tools we have, and I support 19 it.
20 CHAIRMAN ZECH:
Thank you.
Region II, are you there 21 are not?
22 MR. STELLO:
Let me just make one comment.
23 CHAIRMAN ZECH:
Yes, go right ahead.
24 MR. STELLO:
I think it both should be, I hope, 25 comforting to the Commission that we all are expressing the
83 1
caution and the concern and the potential for the misuse of i
2 these.
If they're misused, it's we as managers who have 3
failed.
If we don't manage what we're doing very well and 4
they are misused, I think we have us to look at it.
5 You've heard the senior managers express the 6
concerns.
I think that ought to also be comfort that we'll be 7
watching and assuring that that does not in fact happen.
8 CHAIRMAN ZECH:
All right, thank you.
Let me just 9
say, I would like to commend the Staff for the effort they've 10 made.
I fully appreciate that this is a real serious and 11 difficult job; a real challenge to come up with something very 12 meaningful.
And I look at it as a very good start.
There's a 13 ways to go but it's a good start, and I appreciate the effort 14 that Ed Jordan and many others on your team have gone to.
15 I think it's a very responsible action on our part.
16 It is a management tool.
It does have limitations.
We've 17 discussed that in some length here and heard all the 18 Commissioners express their views on that.
It does require a 19 lot of care.
It does require final judgment.
And by itself, 20 as expressed by several of the region administrators --
21 MR. GRACE:
Hello?
22 CHAIRMAN ZECH:
Region II, are you there?
23 MR. GRACE:
Yes.
24 CHAIRMAN ZECH:
Did you have any comments to make?
25 MR. GRACE:
Yes, please.
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84 1
CHAIRMAN ZECH:
Go right ahead.
/
2 MR. GRACE:
The region thinks that the performance 3
indicator program is going to be a very useful tool.
So far 1
4 as our experience with it in discussing problem plants has 5
confirmed, I think, the regional administrators judgment as to 6
what the problems -- where the problem plants are.
I think 7
it's also going to be useful as a back-up to what the regions 8
are doing in case we're asleep at the switch and don't j
recognize problems on a day-to-day basis or if we've failing 9
i 10 to keep headquarters adequately informed.
11 I think that it's also important that we heed our 12 own advice and not go overboard with the quantitative.
In 13 other words, we should practice what we preach.
Because in 14 fact, there are a lot of other indicators that we're sensitive 15 to that can't all be listed or identified or defined 16 completely; quite subjective and just not quantifiable.
17 But it's going to be a very useful supporting 18 program for the regions.
I think though, if the indicators i
19 identify a problem plant before the regions were aware of it, 20 I would feel that we haven't been doing our job.
But i
21 nevertheless, it's going to be important in that respect to, 22 in case we have'been asleep at the switch.
But we're very 23 supportive and we're encouraged so far with our discussions i
j 24 and the data that is supplied in confirmation of the regional 25 administrators' judgments of where the problem plants are.
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..,-.,--.___,_..,,_-,,,y-__----
85 1
CHAIRMAN ZECH:
All right, thank you very much.
We 2
appreciate those comments.
3 Let me just conclude by saying that I think this is 4
an initiative that focuses the attention of the Commission, 5
the Staff on operational performance and on safety.
And in 6
this year 1986 when we have as many plants operating as we do, 7
I think that's where we should be focusing our first priority 8
because safety of operations is our business and our primary 9
job.
10 Let me just conclude, unless there are any other 11 comments?
12 COMMISSIONER BERNTHAL:
May I ask just one short 13 quick one here that escaped me before?
Has there been an 14 assessment done for this set of indicators that you're 15 proposing or for some of the others that you may propose that 16 we've talked about as to whether that imposes new requirements 17 on the licensees in terms of reporting and paperwork and all 18 these things that OMB loves to look at?
19 MR. STELLO:
Yes, and there are none.
20 COMMISSIONER BERNTHAL:
There are none?
21 MR. STELLO:
Right.
22 COMMISSIONER BERNTHAL:
Okay, thank you.
23 CHAIRMAN ZECH:
Commissioner Asselstine, do you have 24 25 COMMISSIONER ASSELSTINE:
Lando, one quick comment.
e 86 1
I agree with your comments.
I think the Staff presentation 2
was an excellent one.
We threw some fairly tough questions at 3
you.
It's obvious that a lot of thought and effort has gone 4
into this.
I think the Staff is approa~hing this-in a very c
5 careful and responsible way.
t 6
If anything, I'd like to see you keep plugging away 4
7 on some of the other indicators that we've talked about that i
8 aren't in the package already.
I think it's a good 9
presentation.
It's an important program.
I 10 MR. STELLO:
Thank you.
11 CHAIRMAN ZECH:
Thank you very much.
Anybody else?
12 COMMISSIONER ROBERTS:
It was an encellent 13 presentation.
14 CHAIRMAN ZECH:
All right, with that I'll ask my 15 fellow Commissioners after their review of this if they could 16 vote, perhaps by notation, next week.
And with that we'll 17 adjourn the meeting.
18 (Whereupon, at 11:57 a.m.,
the Commi sion meeting 19 was concluded.]
I l
20 i
i 21 22 23 I
l 24 25 l
1
. - -., _... -,.... ~... - _ _...... - _ -. _. _,,.. _. - -. -. - - -.. -. - -,,..
\\
i 1
1 2
REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5
meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7
TITLE OF MEETING:
Briefing on Status of Performance Indicator Program (Public Meeting) 8 PLACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING:
Friday, November 7, 1986 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken
- (
13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.
17
~7)
(*
18
--- GL215:?- !$5.2 'k
=--------
Pamela Briggle 19 4
20 21 22 Ann Riley & Associates, Ltd.
23 24 25
PERFORMANCE INDICATOR PROGRAM FOR OPERATING NUCLEAR POWER PLANTS EDWARD L. JORDAN, DIRECTOR IE/DEPER 1
TASK GROUP CHARTER OBJECTIVE:
DEVELOP A MINIMUM SET OF PERFORMANCE INDICATORS AND RECOMMEND METHODS FOR USING INFORMATION TO MAKE TIMELY REGULATORY DECISIONS ABOUT PERFORMANCE.
ASSUMPTIONS:
1.
EVOLVING SALP IS THE CORNERSTONE OF EFFORTS TO EVALUATE LICENSEE PERFORMANCE.
2.
TRENDING A SET OF SAFETY PERFORMANCE INDICATORS IS NECESSARY TO DETECT CHANGE BETWEEN SALPs AND PROVIDE ADDED OBJECTIVE INPUT.
3.
STRUCTURED DECISIONMAKING IN RESPONSE TO DECLINING PERFORMANCE IS NECESSARY.
4.
DEVELOPMENT AND USE OF OTHER INDICATORS FOR SPECIFIC PROGRAM AREAS REMAIN WITH THAT 0FFICE.
l 2
PI DEVELOPMENT PROCESS SELECTION OF PIs FOR TRIAL PROGRAM SELECTION OF PLANTS FOR TRIAL PROGRAM DATA COLLECTION AND REVIEW FOR THE TRIAL PROGRAM COORDINATION WITH INDUSTRY VALIDATION / CONFIRMATION OF THE PIs SELECTION OF THE MINIMUM SET DEVELOP METHOD OF ANALYSIS AND MONITORING PROVIDE RECOMMENDATIONS TO COMMISSION IMPLEMENTATION CONTINUE DEVELOPMENT 4
3
SELECTION OF Pts CRITERIA (IDEAL ATTRIBUTES OF PIs):
PIs RELATED TO NUCLEAR SAFETY / REGULATORY PERFORMANCE DATA AVAILABLE TO NRC READILY AND TIMELY DATA NOT SUSCEPTIBLE TO MANIPULATION DATA COMPARABLE BETWEEN UTILITIES PIs WORTHY GOAL FOR UTILITY PIs REFLECT A RANGE OF PERFORMANCE PIs INDEPENDENT OF EACH OTHER PIs LEADING OR PREDICTIVE OF FUTURE PERFORMANCE SET OF PIs BROAD EN0 UGH TO CORRELATE WITH SALP h
r l
l 4
-_,..r,._.-____._--__.
mm.
,_r-__,.,
m.
_,,_. __~___ _ _.--_-._ _, -..,__._ _
O o*
SELECTION OF PLANTS CRITERIA:
ONESITEWITHSAMEREACTdRTYPESOPERATEDBYDIFFERENT LICENSEES ONE SITE WITH DIFFERENT REACTOR TYPES OPERATED BY SAME
~
LICENSEE DIFFERENT SITES WITH SAME REACTOR TYPES OPERATED BY SAME LICENSEE DIFFERENT SITES WITH DIFFERENT REACTOR TYPES OPERATED BY SAME LICENSEE DIFFERENT REACTOR TYPES GOOD, POOR, AND AVERAGE PERFORMERS TURNAROUND SITUATIONS NEW PLANTS 50 PLANTS AT 30 SITES SELECTED FOR THE TRIAL PROGRAM 5
s PIS AND DATA SOURCES FOR TRIAL PROGRAM 1
LEAD DATA SOURCES AND PERIOD RESPON-El 31.h11!TY HQ (84-85)
REGIONS
- 1. SCRAMS 1A.
AUTO. SCRAMS AE0'D AE0D
(>15% POWER)
IB.
(<15% POWER)
~
- 3. SAFETY SYSTEM ACTUATIONS AE0D AEOD
- 4. SIGNIFICANT EVENT NRR/0 RAS NRR/ORAS.
FREQUENCY
- 5. SAFETY SYSTEM FAILURES NRR/0 RAS NRR/AEOD
- 6. UNPLANNED SHUTDOWNS RI NUREG-0020 IST QTR.,
1986
- 7. CAUSES OF EVENTS IE/DEPER FROM ABOVE FROM ABOVE (OVERLAY ON PIS 1, 2, ITEMS ITEM 3, 5 & 6)
- 8. FORCED OUTAGE RATE AEOD NUREG-0020
- 9. LC0 ACTION STATEMENTS RI 85 & 1ST (LC0 HOURS FOR SELECTED QTR. '86 SYSTEMS OF SELECTED PLANTS) 6
+
s*
PIS AND DATA SOURCES FOR TRIAL PROGRAM LEAD RESPON-DATA SOURCES AND PERIOD El SIBILITY HQ (84-85)
REGIONS
- 10. FRACTION OF CONTROL RII JUNE / JULY ROOM ALARMS THAT ARE
'86 (BACK, CONTINUOUSLY ALARMING IF READILY (OFF-NORMAL) ABOVE 70%
AVAIL.)
POWER
- 11. AVERAGE AGE OF OUTSTAND-RII JUNE / JULY ING AUDIT ITEMS
'86 (BACK, IF READILY AVAIL.)
' 86 (BACK, IF READILY AVAIL.)
- 14. TOTAL INTEGRATED IE/DI NUREG-0713 EXPOSURE
'86 (BACK, IF READILY AVAIL.)
l
ENCE FOR ROS/SROS,
'86 (BACK, NUMBER OF FULLY-STAFFED IF READILY OPERATING SHIFTS, NUMBER AVAIL.)
0F ACTIVE LICENSES l
- 17. OVERALL MAINTENANCE NRR/DHFT NRR/DHFT j
INDICATOR 7
o-CONFIRMATION / VALIDATION VALIDITY THRU, RELATIONSHIP TO LOGIC MODEL STATISTICAL ANALYSIS COMPARISON OF INDIVIDUAL PIs TO SALP COMPARISON OF PI SETS TO SALP I
8
a s'
RELATIONSHIP OF PIs TO LOGIC MODEL PLANT SAFETY I
LOW FREQUENCY HIGH AVAILABil ITY INHERENT DESIGN OF TRANSIENTS OFSAFETYSYSTEMS FEATURES AND LOW POTENTIAL FOR COGNITIVE ERRORS HIGH TRAIN LOW POTENTIAL I
AVAILABILITY FOR COMMON-CAUSE FAILURES PIs PIs PIs A
- SCRAMS'
- 0RCED OUTAGE
- CAUSE' CODES
- ESF ACTUATIONS
.C0 ACTION ANNUNICATORS i
- SAFETY SYSTEM STATEMENTS AUDIT ITEMS ACTUATIONS'
- SAFETY SYSTEM MAINTENANCE
- SIGNIFICANT EVENT FAILURES
- BACKLOG
\\~
ls FREQUENCY' TURNOVER RATE UNPLANNED SHUTDOWNS EXPERIENCE ENFORCEMENT ACTION INDEX' INT. EXPOSURE OVERALL MAINT. IND.*
'5ELEGIED FOR IHE OPTIMUM SET WITH SOME DEFINITION CHANGES 9
-_._,,..._.._m-
s*
COMPARISON OF NRC, INP0 8 IAEA INDICATORS NRC INP0 HQA
SCRAMS ( >15% POWER)
SCRAMS WHILE PART OF IB.
SCRAMS ( <15% POWER)
CRITICAL, PER 1000 INCAPABILITY HRS. CRITICAL 2.
ESF ACTUATIONS
- 3.
- SAFETY SYSTEM ACTUATIONS UNPLANNED SAFETY SYS. ACTUATIONS
- 4. 'SIGNIFICANT EVENT NO. OF SAFETY '
FREQUENCY RELATED EVENTS (A,B&C)
- 5. ' SAFETY SYSTEM FAILURES SAFETY SYSTEM SAFETY SYS. INOP./ ~
UNAVAILABILITY UNAVAILABILITY 6.
UNPLANNED SHUTDOWNS INCAPABILITY FACTOR 7.
CAUSES OF EVENTS HUMAN ERROR, (0VERLAY ON PIS 1, 2, MECH /IsC/ELEC.
3, 5 & 6)
FAILURE
- 8. ' FORCED OUTAGE RATE FORCED OUTAGE FORCED OUTAGE RATE RATE 9.
LCO ACTION STATEMENTS (LC0 HOURS FOR SELECTED SYSTEMS OF SELECTED PLANTS)
- 10. FRACTION OF CONTROL OUT OF SERVICE ROOM ALARMS THAT ARE CR INSTRUMENTS CONTINUOUSLY ALARMING (OFF-NORMAL) ABOVE 70%
POWER ll.. AVERAGE AGE OF OUTSTAND-ING AUDIT ITEMS
- 12. MAINTENANCE BACKLOG CORR. MAINT. BACKLOG, HIGHEST PRIORITY MWRS/ TOTAL MWRS COMPLETED, PREVEN-TIVE MAINT. ITEMS OVERDUE, PREVENT./
TOTAL MAINT., MAINT.
OVERTIME "SELELIED FOR THE OPTI. MUM SET WITH SOME DEFINITION CHANGES 10
a s*
COMPARISON OF NRC, INP0 & IAEA INDICATORS NRC INP0 LAfA 13, ' ENFORCEMENT ACTION INDEX 14.
TOTAL INTEGRATED COLLECTIVE RAD.
COLLECTIVE EXPOSURE EXPOSURE ANNUAL DOSE 15.
TURNOVER RATE / VACANCIES 16.
AVERAGE YEARS OF EXPERI-ENCE FOR ROS/SROS, NUMBER OF FULLY-STAFFED OPERATING SHIFTS, NUMBER OF ACTIVE LICENSES
- 17. '0VERALL MAINTENANCE INDICATOR EQUIVALENT AVAIL-TIME AVAILABILITY ABILITY FACTOR THERMAL PERFORMANCE CAPACITY FACTOR FUEL RELIABILITY VOL OF LOW-LEVEL NET VOL. OF SOLID RADWASTE SOLID RADWASTE INDUSTRIAL SAFETY NO. OF DAYS LOST LOST-TIME ACCIDENT DUE TO ACCIDENTS RATE MAINT. RAD. EXPOSURE LOST-TIME ACCIDENT RATE IN MAINT.
"SELELitD FOR iHE OPTIMUM SET WITH SOME DEFINITION CHANGES 11
COMPARISON OF NRC, INPO & IAEA INDICATORS NRC INP0 LAfA UNPLANNED AUTO SCRAMS WHILE CRITICAL DUE TO MAINT.
SKIN / CLOTHING CONTAMINATIONS POSITIVE WHOLE BODY COUNTS >1% MPBB CHEMISTRY HOURS OUTSIDE OF OWNERS GROUP GUIDELINES aux SYS. CHEMISTRY HRS. OUTSIDE OF STATION LIMITS CONDENSATE PUMP DISCH. 0 LEVEL 2
CONDENSER AIR IN-LEAKAGE SG BLOWDOWN CATION CONDUCTIVITY FW CATION COND.
Rx WATER SP. COND.
ENVIRONMENTAL PROTECTION INDI-CATORS (E.G. RAD.
DISCHARGE)
NO. AND FRACTION OF PRESCRIBED TESTS COMPLETED NO. OF DEFICIEN-CIES UNCOVERED BY TESTS NO. OF MAJOR MODIFICATIONS 12
OPTIMUM SET OF PIs FOR FINAL PROGRAM 1.
AUTOMATIC SCRAMS WHILE CRITICAL:
THIS IS IDENTICAL TO THE INDICATOR, UNPLANNED AUTOMATIC SCRAMS WHILE CRITICAL, USED BY INP0.
IN ADDITION, THE NUMBER OF AUTOMATIC SCRAMS FROM AB0VE 15% POWER PER 1000 CRITICAL HOURS AND THE NUMBER O MATIC SCRAMS WHILE CRITICAL BELOW 15% POWER WILL BE MONITORED 2.
SAFETY SYSTEM ACTUATIONS:
THIS IS IDENTICAL TO THE INDICATOR, UNPLANNED SAFETY SYSTEM ACTUATIONS, USED BY INP0 AND INCLUDES ACTUATIONS OF ECCS (ACTUAL AND INADV AND EMERGENCY AC POWER SYSTEM (ACTUAL).
3.
SIGNIFICANT EVENTS:
THESE EVENTS ARE IDENTIFIED BY THE DETAILED SCREENING OF OPERAT EXPERIENCE BY NRR AND IE, AND INCLUDE DEGRADATION OF IMPORTANT SAFETY EQUIPMENT, UNEXPECTED PLANT RESPONSE TO A TRANSIENT OR A MAJOR TRANSIENT,-
DISCOVERY OF A MAJOR CONDITION NOT CONSIDERED IN THE PLANT SAFETY ANALYSIS, OR DEGRADATION OF FUEL INTEGRITY, PRIMARY COOLANT PRESSURE B0UNDARY, OR IMPORTANT ASSOCIATED STRUCTURES.
4.
SAFETY SYSTEM FAILURES:
THIS INCLUDES ANY EVENT OR CONDITION THAT ALONE COULD PREVENT THE FULFILLMENT OF THE SAFETY FUNCTION OF STRUCTURES OR SYSTEMS.
TWENTY-1 FOUR SYSTEMS OR SUBSYSTEMS WILL BE MONITORED FOR THIS INDICATOR.
5.
FORCED OUTAGE RATE:
THIS INDICATOR'S DEFINITION IS IDENTICAL TO THE ONE USED BY INPO AND THE NRC GREY BOOK (NUREG-0020), AND IS THE NUMBER OF FORCED OUTAGE HOURS DIVIDED BY THE SUM OF FORCED OUTAGE HOURS AND SERVICE HOURS.
6.
MAINTENANCE BACKLOG:
THIS IS IDENTICAL TO THE INDICATOR, CORRECTIVE MAINTENANCE BACKLOG GREATER THAN 3 MONTHS OLD, USED BY INPO.
IT IS THE FRACTION OF ALL CORRECTIVE MAINTENANCE WORK REQUESTS, NOT REQUIRING AN OUTAGE AND ARE MORE THAN 3 MONTHS OLD.
7.
ENFORCEMENT ACTION INDEX:
THIS INCLUDES ALL ENFORCEMENT ACTIONS ISSUED AS A RESULT OF INSPE COMPLETED IN A GIVEN PERIOD WEIGHTED BY SEVERITY LEVELS ADAPTED FR 10 CFR 2.
8.
EQUIPMENT FORCED OUTAGES PER 1000 CRITICAL HOURS:
THIS IS THE INVERSE OF THE MEAN TIME BETWEEN FORCED OUTAGES CAUSED EQUIPMENT FAILURES.
THE MEAN TIME IS EQUAL TO THE NUMBER OF HOURS THE REACTOR IS CRITICAL IN A PERIOD DIVIDED BY THE NUMBER OF FORCED OU CAUSED BY EQUIPMENT FAILURES IN THAT PERIOD.
13
o COORDINATION WITH INDUSTRY JUNE 11, 1986:
AIF/INP0/ UTILITY REPRESENTATIVES AUGUST 15, 1986:
INP0 MEETING SEPTEMBER 15-16, 1986:
ANS EXECUTIVE SEMINAR SEPTEMBER 15, 1986:
AIF/INP0/ UTILITY REPRESENTATIVES INDUSTRY COMMENTS CONSTRUCTIVE STAFF RECOMMENDS REMOVAL OF MAINTENANCE BACKLOG BASED ON INDUSTRY COMMENTS 1
14
SAMPLE REPORT FORMAT INDUSTRY
SUMMARY
TABLE LATEST SALP 4-QUARTER AVERAGE LATEST QUARTER PLANT PROFILE TREND LATEST QUARTER VS 4-QUARTER AVG DEVIATION FROM INDUSTRY MEAN DETAILED PLANT ANALYSIS CHART QUARTERLY' DATA (8 QUARTERS)
INDUSTRY AVERAGE CRITICAL HOURS 15
+
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SAMPLE INDUSTRY
SUMMARY
TABLE (PARTIAL)
- SALP TREND ** ****** PERFORMANCE INDICATORS *********
I I
ITOTAL SCRAMSI SAFETY SYS I SIGNIFICANTI I
I I
I ACTUATIONS I EVENTS I
I ILATEST SALP SALP I 4'QTR QTR 14 QTR QTR 14 QTR QTR I i
1 REPORTIAVG END IAVG END lAVG END' I
I PLANT LOP MN SUR QP DATE 186-2 86-2186-2 84-2186-2 86-21 i
6 i
i s
i I
I I
l-1 I
l INDIAN POINT 2 12 2D 1 12/95 1 2.75 4 1 1.50 3 1 1.00 2I
- INDIAN POINT 3 12D 1 1
2 03/86 1 3.33 5 1 0.50 21 0.25 1 i I
I I
i l KEWAUNEE 11 1
2D 2 03/86 1 1.75 4 1 1.00 2 1 0.25 1 1 I
I I
I I
- LA CROSSE 12 2 11 2 03/85 1 3.00 5 1 3.25 7 1 1.00 1 1 1
I I
I I
- LASALLE 1 13 3D 3D 3D 02/86 I i 1.25 1 1 0.25 0 I t LASALLE 2 13 3D 3D 3D 02/86 1 1.75 3 1 2.75 21 0.25 1 1 I
I i
I I
I LIMERICK l1! 2 2 1
06/06 1 1.00 0 1 4.50 51 0.00 0 I I
I I
I I
I I
I MAINE YANKEE 12I 2 11 01/86 1 2.00 2 1 1.25 1 1 1.25 0 1 l
l l
1 1
I MCGUIRE 1 13 2 2 2 06/86 1 1.25 0 1 2.00 1 I 0.75 '
0 1
- MCGUIRE 2 13 2 2 2 06/96 1 2.50 0 1 2.25 1 1 0.50 0 1 I
I I
I
- MILLSTONE 1 11I 1 1
1 05/85 l 1.25 1 1 2.00 1 I 0.25 0 1 I MILLSTONE 2 til 1 1
1 05/85 1 0.50 1 1 0.25 0 1 0.00 0 I
(
i MILLSTONE 3 12D 2D 3D 03/96 1 5.00 3 1 1.33 0 1 0.00 0 :
1 I
I I
I I
! NONTICELLO 31 1 2 2 08/86 8 0.25 0 1 3.25 7 1 0.75 3 I I
I I
I l
I i
i NINE MILE POINT
!!! 2 11 08/85 l 1.50 2 1 2.75 2 1 0.50 0 1 I
I I
I I
I I NORTH ANNA 1 12D 2 2 2 05/95 1 1.25 2 1 1.25 2 1 0.75 0 I I NORTH ANNA 2 12D 2 2 2 05/85 1 1.25 4 1 0.25 1 1 1.00 1 I i
i i
I i
! OCONEE 1 11 2D 1 2 06/06 i C.50 1 1 0.00 0 1 0.25 1 1 I OCONEE 2 11 2D 1 2 06/84 1 0.75 0 1 0.50 0 1 0.25 0 1 I OCONEE 3 11 2D 1 2 06/86 1 0.75 0 1 1.25 0 1 0.00 0 I I
I I
I
- OYSTER CREEK 2D 3D 2D 10/85 1 1.25 0 1 1.50 4 : 1.00 0 :
1 I
I
- PALISADES 12 3D 3D 3D 02/86 1.00 1 : 3.00 2: 0.75 1 :
I
- PALO VERDE 1 12 2 2 2
12/85 1 3.50 1 : 3.00 0 1 1.75 1 :
- PALO VERDE 2 12/85 : 3.00 3 : 0.67 2: 0.75 3 :
i 16A
e
.e SAMPLE INDUSTRY
SUMMARY
TABLE (PARTIAL)
I
- PERFORMANCE INDICATORS ****************
I I
I SAFETY SYS IFORCED CUTAGI ENFORCEMENTIEQUIP CUTAGESI I
I FAILURES I
RATE (%)
lACTION INDEXtPER 1000 CRITI i
14 QTR QTR 14 QTR QTR 14 GTR QTR 14 QTR QTR I I
IAVG END IAVG END IAVG END lAVG END 1
1 PLANT 186-2 86-2186-2 86-2186-2 86-2 186-2 86-2 1
,e i
i I
I I
i I
I I
I I
l
~
l INDIAN POINT 2 1 0.25 0 1 5.75 14 1 4.00 1 1 1.53 4.7 !
I INDIAN POINT 3 1 0.00 0 1 2.50 7 1 1.00 0 1 1.70 3.3 I I
I I
I i
i KEWAUNEE I 0.25 0 1 0.75 1 1 2.75 4 1 0.78 1.7 I I
I I
I I
I I LA CROSSE I 0.00 0 1 7.00 7 1 5.75 3 1 1.28 2.6 I I
I I
I I
I I LASALLE 1 1 0.25 0 1 4.75 0 1,41.25 13 1 I LASALLE 2 1 2.50 2 131.50 48 140.25 7 1 0.60 0.9 I I
I I
I I
I LIMERICK I 2.00 3 1 1.00 0 1 0.75 0 1 0.38 0 t i
I I
I I
I I MAINE YANKEE I 0.25 0 1 7.50 3 1 2.75 3 1 1.15 0.9 I I
I I
I I
I MCGUIRE 1 1 0.75 1 1 1.00 1 118.50 1 1 1.23 0.9 I I MCGUIRE 2 1 0.75 0 112.50 3 118.25 0 1 1.55 0 I i
i I
I i
! MILLSTONE 1 1 1.25 0 1 1.75 0 1 1.50 0 1 0.00 0 I I MILLSTONE 2 1 0.75 1 113.00 1 1 0.75 0 1 0.13 0 I I MILLSTONE 3 1 1.33 0 120.50 7 8 3.75 1 1 0.65 1.3 !
l t
i I
I I
I I MONTICELLO I 1.00 2 1 0.25 0 1 1.00 0 1 0.13 0 I i
I I
I i
i I
I NINE MILE POINT I 0.25 0 1 5.00 0 1 4.25 3 1 1.23 3.4 I I
I i
i I
I I NORTH ANNA 1 I 0.50 0 110.25 3 122.00 10 1 1.08 1.4 I I NORTH ANNA 2 1 0.00 0 1 4.75 8 120.25 to I 0.50 1 1 I
I I
I I
I I OCONEE 1
! 0.50 0 1 6.50 12 110.00 31 1.38 2.6 I I OCONEE 2 1 0.00 0 1 3.25 0 110.50 0 1 0.85 0 t i OCONEE 3 1 0.00 0 111.00 0 1 9.75 0 1 1.88 0 1 I
I I
I
! OYSTER CREEK I 2.50 1 1 8.00 0 115.50 6 1 0.73 0 I I
I I
I I
I I PALISADES I 0.25 0 124.75 50 117.50 13 1 1.63 1.7 I
(
l i
I I
I I
I PALO VERDE 1 1 2.00 2 150.50 35 120.00 36 1 2.30 0 1 I PALO VERDE 2 1 0.67 2 !
1 5.00 16 I 3.80 3.8 I I
I I
I 16B
.s PLN E A
- Trends Performance Indicators oeciined im,ro,,,
- 1. Screms, e) Tetel (Qtr. 86-2) ysy/yy/yyyy
,.s,o b) > I 5%/t 000 Crt!. Hrs. (Qtr. 84-2) -w///////////////
2.s e e) < 15% Power (Qtr. 86-2) 0.0
- 2. Sofety System Actotions (Qtr. 86-2) -
-e.se
- 3. Significant Events (Qtr. 88-2) -
-e.e
- 4. Sefety System Follures (Qtr. 86-2) -
0.58
- 5. Forced Outoge Rote (Qtr. 86-2) -
-35.37
- 6. Enforcement Acilon index (Qtr. 86-2) -
-I.10
- 7. Equipment Forced Cutogos/1000 Celt. Mrs. - -1.73 (Qtr. 86-2)
-2.N2 -1.5 2 -d.S 0 0.5 1 1.'S $ 2.5 1
Devletions from Previous 4 Qtr. Plant Woons (Measured in Standard Deviations)
Deviations from Industry Means PIM A Perforrnance Indicators 8elow Avg. Perf.
Above Avg. Perf.
- 1. Scroms, e) Total (4 Qtr. Avg. end 86-2)
- 0. A s b) > 15%/1000 Crti. Hrs. (4 Qtr. Avg. end 86-2) -
.2s c) < 15% Power (4 Qtr. Avg. end 86-2) 0.75
- 2. Safety System Actotions (4 Qtr. Avg. end 84-2) -
c.se
- 3. Significant Events (4 otr. Avg. end 86-2) -
c.so
- 4. Sofety System Follures (4 Qtr. Avg. end 86-2) -
0.73
- 5. Forced Outoge Role (4 Qtr. Avg. end 86-2) -
0.44
- 6. Enforcement Action Index (4 Qtr. Avg. end 86-2) -
0.34
- 7. Equipment forced Outages /1000 Crit. Hrs. -
0.s7 (4 Qtr. Avg. end 86-2)
-2.5-2 -i.S d -d.5 0 0.5 $
1.'S k 2.5 l
p Devictions from industry Wecns (Woosured in Stenderd Deviations)
t, 4
1
.1 A.
TOTAL SCRAMS l
PLANT A
84-3 TO 86 2
o
,o LEGEND 8
-228 7__
213e Scroms N
hj\\
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to70 g
1ese
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f N
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_ Crit. Hrs.
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h O
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I 8
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4 36 f..,
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o o
84-3 84-4 85-1 85-2 85-3 85-4 86-1 86-2 YEAR - QUARTER D@
9
+
5 6.
ENFORCEMENT ACTION INDEX PLANT A
i 84 3
TO 86 2
1 2
ffM indox f
22ae 2159
\\
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te7o Indus. Avg.
1sa.
j
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N
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_ Crit. Hrs.
Fa 3....
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5 E
E O
O 84-3 84-4 85-1 85-2 85-3 85-4 86-1 86-2 YEAR - QUARTER L _. __ _.
4 MILESTONES FEBRUARY 1987 PROVIDE FIRST QUARTERLY REPORT BASED ON PI DATA THROUGH DECEMBER 1986 MAY 1987 PROVIDE SECOND REPORT BASED ON DATA THROUGH MARCH 1987 AUGUST 1987 PROVIDE THIRD REPORT BASED ON DATA THROUGH JUNE 1987 NOVEMBER 1987 PROVIDE FOURTH REPORT BASED ON DATA THROUGH SEPTEMBER 1987 DECEMBER 1987 REFINE PROGRAM BASED ON EXPERIENCE GAINED AND RESULTS OF CONTINUED DEVELOPMENT r
19
1F r
,s' STAFF RECOMMENDATIONS COMMISSION APPROVAL OF THE PROGRAM CONTINUED PI DEVELOPMENTAL WORK PERSONNEL RADIATION EXPOSURE / SITE PROGRAMMATIC / PREDICTIVE INDICATORS FURTHER REVIEW 0F SYSTEMS AND CAUSE CODES LC0 ACTION STATEMENTS SAFETY SYSTEM / TRAIN UNAVAILABILITY RELIABILITY / RISK-BASED INDICATORS CONSIDERATIONS BASED ON OCTOBER MANAGEMENT MEETING USE OF TWO-QUARTER DATA (INSTEAD OF ONE QUARTER CURRE USED)
EVALUATION OF NEW PLANTS AS A SEPARATE GROUP EVALUATION OF PWRs AND BWRs SEPARATELY 20
4.04c0.0 Document Control Desk, 016 Phillips TRANSMITTAL T0:
ADVANCED COPY TO:
The Public Document Room l
3G\\
/
DATE:
/0 /L
/
I 3 :-
SECY Correspondence & Records Branch 2at FROM:
4 3
3 Attached are copies of a Commission meeting transcript and related meeting 3 ll document (s). They are being forwarded for entry on the Daily Accession List and No other distribution is requested or placement in the Public Document Room.
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required.
3 h bit o M b h c m % e.
Meeting
Title:
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Meeting Date:
ll 'l Irle Open X
Closed 3 :
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3 :
s i Item Description *:
Copies
[
Advanced DCS 3
- 8 Sj-to PDR g
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- 1. TRANSCRIPT to/ ( lthe @ks S!-
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- 2. Se u 86 - 317 A
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- POR is advanced one copy of each document, two of each SECY paper.
C&R Branch files the original transcript, with attachments, without SECY papers.
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