ML20247E886
| ML20247E886 | |
| Person / Time | |
|---|---|
| Issue date: | 05/02/1989 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8905260366 | |
| Download: ML20247E886 (90) | |
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION tb BRIEFING ON RESULTS OF MAINTENANCE TEAM INSPECTIONS LOCatiOD: ROCxv1LLE, MAaYLAND Da($l MAY 2, 1989 Pag 6S: 68 PAGES 1
NEALR.GROSSANDC0.,INC.
COURT REPORTERS AND TRANSCRIBERS 1323 Rhode Island Avenue, Northwest Washington, D.C. 20005 ~
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O DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on May 2, 1989 in the Commission's office at One White Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general gm.
informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with t
the Commission in any proceeding as the result of, or s
addressed to, any statement or argument contained herein, except as the Commission may authorize.
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< l 1 UliITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSIO!!
3 * *
- i 4 BRIEFIliG Oli REstiLTS OF MAIllTEllAl!CE
% TEAM ItTSPECTIOffS '
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- a 7 PUBLIC MEETING 8 * *
- 9 tiuclear Regulatory Commission 10 One White Flint Iforth 11 P.ockville. Maryland 12 13 Tuesday. May 2, 1989 14 15 The Commission met in open session, pursuant to 16 notice, at 2:00 p.m.. the Honorable LANDO W. ZECH, JR.,
17 Chairman of the Commission, presiding.
18 19 COMMISSIONERS PRESENT:
20 LANDO W. ZECH, JR., Chairman of the Commission 21 THOMAS M. ROBERTS, ""mber of the Commission 22 KENNETH C. ROGERS, Member of the Commission 23 JAMES R. CURTISS, Member of the Commission 24 k 25 l
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1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
I L-2 SAMUEL J. CHILK, Secretary 3 UILLIAM C. PARLER, General Counsel 1
a JAMES TAYLOR, Deputy Executive Director. Operations 5 FFAIIK MIRAGLIA. IIRR 6 J. ROE, UP.R 7 TONY GODY, URR 8 JERRY BLAKE, Region II 9
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1 E R Q C E E E I,E q S 2 (2:00 p.m.)-
3 CHAIRMAti ZECH: Good afternoon, ladies and 4 gentlemen.
5 Commissioner Carr will not be with us this-6 afternoon.
7 Today, the Commission will be briefed by members 8 of the NRC's Office of Nuclear Reactor Regulation, 9 concerning the results of the maintenance team inspections 10 performed in various power reactor sites around the )
11 country.
12 On March 23rd of 1988, the Commission published 13 its final policy statement on maintenance of nuclear pcuel 14 plants. This was a first step by the Commission to 15 provide a greater focus and emphasis on the need for 16 effective maintenance programs for nuclear power plants.
i 17 The staff's program of maintenance team 18 inspections, which began in June of 1988, is an important 19 extension of our maintenance policy statement. I believe 20 that the importance our licensees place on effective 21 maintenance will determine, to a large extent, the safety, 22 reliability and availability of plant operations.
23 Proper maintenance programs that are vigorously -
24 executed make a substantial contribution to safety and can
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25 contribute significantly to plant life extension.
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I l' ~1 This meeting is an information briefing'. .Co' pies, d.
2 - of the slides are available at.the entrance to the meeting 3 - room.
4 Do any of my f ellow Commissioners ' have any 5 opening comments before we begin?
6 MIo response.)
~7 If not, Mr. Taylor, you may proceed.
t 8 'MR. TAYLOR: Good afternoon, sir. . With me at 9 the. table are Mr. Miraglia and Mr. Roe, Mr. Gody :'and ~ Mr .
10 -. Blake, all'from the Office of. Nuclear Reactor Regulation.
11 Through the years, .the staff has ' engaged in 12 various team-type inspections and, as you indicated, abou't 13 a year ago the staff ran some pilot inspections and began 14 this major maintenance team-type inspection and, to the 15 extent that, as you will see today, more than 20 of these 16 inspections have been done, I believe this type- of 17 ' inspection has been very well organized by the staff, and 18 I believe the briefing will show that today.
19 I'll turn to Mr. Miraglia to continue the
~20 briefing.
21 CHAIRMAN ZECH: Thank you very much. Proceed.
22 MR. MIRAGLIA: Thank you, Jim.
23 Jerry Blake is from Region II. He's a -
p 24 maintenance -- from a programmatic point of view, they are b.
25 implementing NRR programs.
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1 CHAIRMAN ZECH: Well, welcome to Region II.
2 We're happy to have you with us today.
3 MR. MIRAGLIA: Jerry is a team leader, and 4 you'll hear from him later in the presentation relative to 5 the planning and the conduct of these inspect ns.
6 CHAIRMA!! ZECH: Fine. Thank you.
7 MR. MIRAGLIA: By way of background,. maintenance 8 has been an area of focus for both the industry and the 9 Commission, since probably '85 and a little earlier.
10 NUREG 1212 was issued in June of 1986, and it 11 was the status of maintenance in the nuclear power 12 industry and it was conducted by the staff, and that was 13 based on surveys and site visits that were conducted in 14 the '80 to '85 time period and, about that same time, INFO 15 public guidelines on the conduct of maintenance 16 inspections at nuclear power plants, and maintenance has 17 been chosen as an area of emphasis in the new NRR 18 inspection program for Fiscal Year '89 and '90.
19 The objective, as the Chairman has stated, is to 20 provide a focus to determine whether component systems and 21 structures at the nuclear power plant are being maintained 22 adequately to perform their intended functions, and to 23 direct licensee attention to maintenance activities, to -
I 24 generate improvement in the process. !
- i. i 25 The staff briefed the Commission earlier in the !
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1 year relative to the maintenance policy statement, and it I
L- 2 indicated th a t 'we were going to perform maintenance team 3 inspections in the forthcoming year, and the Commission 4 did ask to be briefed on the status of those inspections 5 and the findings of those inspections, after the' program 6 is underway for a while, and that's the purpose of today's
'7 reeting, is to indicate to you where we've been, how the 8 program has developed, and the results to-date.
9 With that, I'd like to turn the briefing over to 10 Mr. Gody, who will go over the development of the il maintenance team inspection.
12 C O M M I S S I O tI E R ROGERS: Could I just ask a 13 question? On ITUREG 1212, how many piants were involved in L.__.
la that survey. or sites? How does it conpare with ehnt's 15 just been done right now, for instance?
16 MR. MIRAGLIA: I think it was a larger sample.
17 MR. ROE: A larger sample. The approach was 18 taken to get all the currently operating plants. There 19 may have been a few that we did not accomplish that --
20 MR. MIRAGLIA: I think they were asked to
? 21 voluntarily submit information, so --
22 MR. ROE: And, currently, in this particular 23 maintenance team inspection, we've accomplished about 20- .
6 24 21 of the inspections, so we're about a third of the way L..-
25 through on a site basis.
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- 1 MR. MIRAGLI'A : On a site basis.
2 COMMISSIONER ROGERS: Fine. Thank you. ,
3 CHAIRMAN CECH: All right. Thank you. You may 4 proceed.
I 5 MR. GODY: Good afternoon.
6 CHAIRMAN ZECH: Good afternoon.
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'7 MP. GODY: As Mr. Miraglia stated, maintenance 8 was selected as the first area of interest in the 9 mandatory team inspections, in the NRC's fundamental 10 inspection program. Consequently, NRR, in conjunction 11 with the regional offices, developed a temporary 12 instruction, including inspection guidance and an 13 inspection tree.
14 This maintenance team inspection instruction was 15 developed from the Commission policy statement, existing 16 regulations and inspection procedures. The results of the 17 1985 maintenance survey were considered, and the INFO 18 guidelines on the conduct of maintenance.
19 I'd like to stress that this program, the 20 temporary instruction, really contains nothing new. It's 21 a combination of inspection activities that we've been 22 performing in the past, that we've put together in one 23 place and had a team look at it in a particular frame, at .
24 a particular period of time.
t 25 Inspection trees have also been used in the 1
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- 1 inspection process before. The health physics appraisal L- 2 teams used them during inspections in the early 1980s {
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3 Ue contracted EG&G. or the Idaho ifational l 4 Engineering Laboratory, to assist us in the development of 5 the temporary instruction. They had originally developed 6 the management oversight and risk tree concept, and also I
7 had recently developed a program for maintenance, for the 3 Department of Energy.
9 There are two trees used in each inspection, a 10 working tree that the team can utilize during the i
11 inspection and a presentation tree that the team may use j 12 to brief licenree management at the exit interview.
13 After development of the temporary instruction, 14 we asked the regions to provide senior experienced 1
- 1. 5 inspectors to lead the teams. Once the regions did that, 16 we assembled the teams in headquarters for one week of 17 training on the temporary instruction, the guidance and 18 utilization of the tree. We called the EG&G people in to o
19 perform part of that training.
20 Then we conducted three pilot inspections, at 21 Peach Bottom, Oconee, and Diablo Canyon. They were led by 22 team leaders from those appropriate regions, and the teams 23 consisted of members of trained team leaders. .
- 24 At the conclusion of those inspections, we k-25 conducted a lessons learned meeting, and made necessary (202)234-4433 NEAL R. GROSS & COMPANY, IIIC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHItiGTON, D.C. 20005
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l; . 1 revisions and adjustments to the temporary instruction.
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! 2 Following the pilot inspection, we also 3 conducted a two-day training program for team members here i 4 in headquarters -- again, this was in the temporary l
5 instruction utili$ation of the tree -- and we conducted 6 case studies using the results from the pilot inspections.
I 7 COMMISSIONER CURTISS: Just out of curiosity, 8 how did you pick those three plants for the pilot?
9 MR. GODY: We pretty much left them - up to the 10 regions. What we had wanted to do was get one that was 11 considered to have a good program, and two fair to 12 middling.
13 The inspection schedule itself involves a six-14 week period, including one week of prep, one week of in-15 office review, two weeks on-site time, and two weeks of 16 documentation. The twc weeks' on-site time may be split 17 by the one week in-office effort, according to how the 18 region generally runs their team inspections.
19 Teams are generally made up of six members, 20 including the team leader. Headquarters personnel and/or 21 contractors are also on the team.
22 The maintenance team inspection program was 23 developed in order to inspect and assess the effectiveness .
24 of the entire maintenance process at nuclear power plants.
25 In order to facilitate and standardize this assessment (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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- 1 process, we. developed the temporary instructions and the I
L- 2 logic tree.
3 Forty-three individual elements may be evaluated 4 during the course of the inspection. As we get on a 5 little, we have a tree. we've provided one to you. and 6 we'll talk about those.
7 'The instruction also provides detailed guidance 8 on the types of activities to evaluate, along with the 9 . acceptance criteria. It's designed to focus the 10 inspection on performance. The tree is intended to 11 provide a systematic approach to the performance of the 12 inspections, and to ensure consistency between the 13 regions. As I said earlier, it also presents a tool--
14 provides a tool for presenting inspection results to the 15 licensee.
16 The program itself consists of three major 17 sections: The overall plant performance, management 18 support of maintenance, and maintenance implementation.
19 Those sections are further subdivided into eight 20 categories. These are direct measures; management i 21 commitment and involvement; technical support; management la 22 organization; work control; plant maintenance 23 organization: maintenance facilities, equipment and .
- j. ; 24 materials control; and personnel control.
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25 We have initiators that the team gathers to get (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 L---_-___---___________- _ _ _ _ _ _ _ __ _ -___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _
11 1 into the inspection. They consider them, prior to the 2 inspection. The main one is recent component. failures of 3 significant equipment. They inspect the maintenance 4 activities related to the schedule of repair and the 5 prevention of further failure of that equipment.
6 Other selective examinations of equipment 7 failures attributed to maintenance are examined to 8 determine the adequacy of licensee corrective actions and 9 root cause determinations.
10 AEOD studies reveal that topics of interest such 11 as air systems, check valves, motor operated valves, were 12 the cause of many events, so we also have the teams review 13 those.
14 Observation of maintenance activities in 15 progress are a major part of the inspection. Probablistic 16 risk assessment information is also used to prioritize the 17 equipment reviewed by the team. The teams use these 18 insights to ensure that high risk equipment is being 19 maintained.
20 The observation of plant activities include a 21 plant walkdown, to look at the plant material condition.
22 If they see numerous leaky valves, they'll look at valve
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23 maintenance and that type of thing.
24 COMMISSIONER ROGERS: Do they actually look at a s
25 maintenance procedure being carried out?
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- ~ 12 i 1 MR. GODY: They look at --
make observation of F
2 work activities in progress. j l
3 Some of the teams have been scheduling 1 4 inspections during outages, so they would avail themselves 5 to that. That causes problems, in a sense, too, with the 6 licensee. However, the major gist of the inspection is to 7 focus on t'he performance of maintenance activities and the {
8 support activities associated with them.
9 CHAIRMAN ZECH: But they watch them doing the 10 actual maintenance --
11 MR. GODY: Absolutely.
12 CHAIRMAN ZECH: -- as part of the inspection.
13 MR. GODY: Yes, as much as they possibly can.
14 We stress, in the temporary instruction, that that portion 15 of the inspection should consist of about 80 percent of 16 the total inspection.
17 COMMISSIONER CURTISS: Back on Roman numeral I 18 here, overall plant performance related to maintenance, 19 one of the two charts that we've got here lists two direct 20 measures that you get from the historic data and plant 21 walkdown inspection.
22 MR. GODY: Right.
23 COMMISSIONER CURTISS: At least insofar as .
24 historic data is concerned, would that be a measure of how
\
25 good a maintenance program a utility has pretty much l
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.m 13 1 independent of the actual inspection itself?
2 MR. GODY: We hoped that it would. We looked at 3 ~ availability and LERs, that type of thing, in order to--
4 so I would say yes.
5 COMMISSIONER CURTISS: It looks to me like l 6 that's kind of a calibrated category where you look at l
7 plant performance from the otandpoint -- or maintenance l 8 from the standpoint of historic data --
9 MR. GODY: Right.
10 COMMISSIONER CURTISS: --
and it almost could 11 serve as a calibrating measure for the subjects that you l 12 address under Roman numeral II and III. I 13 MR. GODY: Yes. That would give them -- that, 14 along with the plant walkdown, would give them areas that 15 they would want to focus on during the inspection.
16 COMMISSIONER CURTISS: Okay.
17 MR. GODY: We have two -- have completed trees 18 from two inspections with me today. They won't show too 19 well on the monitors, so you've been provided copies of 20 them.
21 One tree shows a good program with satisfactory 22 implementation. As we go through the remainder of the 23 discussion, the briefing, you'll note that this is the -
24 predominant findings we have found, this type of thing--
l 25 good program with satisfactory implementation.
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- 1 CHAIRMAN ZECH: Green is good, yellow is not so
' - 2 good, and -- !
i 3 COMMISSIO!!ER ROBERTS: Yellow is satisfactory. 1 4 CHAIRMAN ZECH: -- red's bad, is that right?
5 MR. GODY: That's right.
6 CHAIRMAN ZECH: Yellow is satisfactory? l
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7 MR. GODY: Right. !
8 CHAIRMAN ZECH: Okay. 1 i
9 MR. GODY: The second tree had satisfactory !
10 programs with poor implementation. You'll notice there's 11 a considerable' amount of red on this particular tree. The 12 guidance itself tells the inspectors, the inspection team, 13 how to -- what to look at, how to evaluate it, and how to 14 roll it up into the various elements.
15 Note that the boxes on the tree are divided.
16 The upper, left-hand -- left half of the box is used to 17 evaluate the program or the process adequacy, such that is 18 an adequate program or process documented and in place.
19 The lower, right half of the box indicates the 20 evaluation of the implementation of the program or the 21 process. Is the process functioning as advertised? Is it 22 functioning effectively?
23 The general criteria for determining the ratings -
- i. 24 for the various elements are the good, satisfactory and v.
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. I blocks, and that's either not applicable or insufficient l 2 data.
3 The criteria for providing the rating for each 4 individual element is, good is green. It's more than 5 minimal efforts have been expended. The area has 6 desirable quantities, and very few minor improvements are 7 required.
8 Satisfactory is the yellow. That means it's 9 been developed. documented and effectively implemented, 10 and needed improvements are offset by better areas within 11 a particular limb of the tree.
12 Poor, red, is inadequate or no effort has been 13 expended in this area. And, as I said, the blue is 14 insufficient data or not rated.
15 COMMISSIONER CURTISS: And as I look at these 16 charts, just the rough overview that you get here is that 17 -- more so on the BU-2 chart, that they've got better 18 programs than they do implementation.
19 MR. GODY: Yes.
20 COMMISSIONER CURTISS: The programs are good, 21 but implementation falls short.
22 MR. GODY: Right.
23 COMMISSIONER CURTISS: And a similar schematic _
24 for BU-1.
25 MR. GODY: Yeah, and that's the prevalent thing.
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6 1 Once Jerry's done with his conduct of inspection, I'll get I
L_ 2 into some of the individual elements of the tree.
3' CFAIRt!Aff ZECH: Before you go on, I don't see 4 docu:ren ta tion in vary many of those blocks. Tell us a 5 little bit about how you look into documentation.
6 MR. GODY: Well, documentation is the work 7 request, maintenance work request.
8 CHAIRMAN ZECH: Well, I want to know -- here's a 9 pump. When was it maintained? What did they do to it?
10 ^ When did they do it? How much did they do to it?
11 COMMISSIONER ROBERTS: Five point three.
12 'MR. GODY: I'm sorry.
J 13 CHAIRMAN ZECH: Have they got any real, solid u
14 documentation?
15 1 R. GODY: Yes. Work control aspects --
it's 16 section 5 -- establishing --
maintain equipment records 17 and history, work prioritization, job planning, 18 scheduling.
19 CHAIRMAN ZECH: I understand that, but--
20 scheduling, planning and all that kind of thing, but what 21 happened to the pump. I want to know what happened to the 22 pump. Do I have to look at all kinds of job orders and i
23 try to figure out where they were, or do you have ,
24 something that shows the pump?
i 25 MR. GODY: Hopefully, the licensee has--
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17 1 maintains equipment records and the history of that_ pump.
2 CHAIRMAff ZECH: But what if he doesn't, though. )
3 MR. GODY: Well, if he doesn't, then he's not-- !
4 COMMISSIONER CURTISS: That would be a red box 5 then.
6 MP. GODY: Yes, that's true. l 7 CHAIRMAN ZECH: Right.
8 MR. MIRAGLIA: It would be red.
9 CHAIRMAN ZECH: Okay. Well, I just mention it 10 because document ; ion is so important. You can have a 11 good program, and it can be very well maintained and the 12 plant run well and all that, but if you can't show what 13 you've done, it's not very smart, in my judgment, on the 14 part of the utility ' because , if he's got a good program, 15 he ought to be proud enough to have documented it to the 16 extent he could show what he did.
17 MR. GODY: Right.
18 CHAIRMAN ZECH: To me, that's going to be very 19 important to us when we eventually get into plant life 20 extension. If somebody can show where you've been 21 carefully maintaining the plant for a long time, and 22 you've replaced certain parts and you've got a good 23 documented system of maintenance, it's going to make a ..
24 difference, I would think, to our reviewing staff when you 25 look at maintenance programs.
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. 1 Maintenance is not only important' to plant 1
2 operations, but it's important to document it properly.
3 MR. GODY: True, and that's -- it's in the tree 4 in several places, the process.
5 CHAIRMA11 ZECH: Okay. I saw it in a couple 6 places, but I- just want to make sure that that's an 7 important part of your inspection, too.
8 If I were a utility executive, I'd want to make 9 sure my maintenance was documented. You know, 30 years 10 ago you didn't have much documentation and abody -- you 11 know, it was not looked upon as something necessary. You 12 had a good mechanic. He stayed there forever.' He could 13 run around, and he knew all the equipment. Pretty simple 14 equipment. He could handle it and do it, and you could 15 ask him what he did two years ago and he could probably 16 tell you.
17 flo w our plants are so complicated, and 18 documentation has been looked upon as something very 19 important, and so I just hope that that's an important 20 part of your maintenance inspection because --
21 MR. MIRAGLIA: I think the tree forces, Mr.
22 Chairman -- the tree forces you to look at documentation 23 in the different ways -- .
24 CHAIRMAff ZECH: Good.
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. 1 of it. In order to look at the work history, you would go I
L- 2 to the maintenance records. You would look at the work i 1
l 3 history on the one limb of the tree, work - control 4 processes, the testing procedures, whather there was 5 rework and retest, and so there has to be a conscious look 6 at documentation at various elements and bcxes in that 7 tree.
8 MR. GODY: Right.
9 CHAIRMA!! ZECH: Good.
10 MR. MIRAGLIA: And each licensee perhaps 11 maintains his records and documentation in a different 12 way, but the tree sort of indicates the team -- focuses i
13 the team on -- focusing on the documentation., to pick the u _.
14 path, and then also they check via the implexntation. i rs 15 the documentation representative of the work that they're 16 actually performing. And perhaps Jerry Blake can get into 17 some of that at the time he talks about how the process is 18 put together.
19 MR. GODY: I'd like to add to that, at the 20 lower, right-hand corner of the tree is a legend and, in 21 there, green is the element is well documented. So, we do 22 look in each one of these elements, at the documentation 23 aspects. -
24 CHAIRMAN ZECH- Fine.
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25 COMMISSIONER ROGERS: And just a question on the (202)234-4433 UEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
-' 20 1 tree, the concept of the tree. Was any thought given one 2 way or the other, with respect to indicating the 3 importance, the relative importance of any of these 4 activities? And the Chairman's question brings, you know, 5 this tc mini because it looks like an organizational 6 chart, in a sense, and in an organizational chart, you 7 sort of think of a hierarchy of individuals or functions.
8 This may not have the same significance, and I 9 wonder has any thought been given to being able to 10 identify the most critical elements of the tree, to its 11 import.ance?
12 MR. GODY: I think --
13 MR. MIRAGLIA: Well, let me take a crack at it, 14 and then Ton;, who has been perhaps more actively 15 involved, can further out. I think with respect to the 16 tree that you have here, it's a representation of an 17 organizational way of saying we have defined maintenance 18 in a very broad context. It's not just working on a 19 particular component or pump. There's many elements of 20 it. There's the planning of it. You have the support i 21 activities. What are the training and quality of your 22 craftsmen? Is engineering involved? Is operations 23 involved? .
24 And, so, this here was a graphical
(~ representation to focus the many elements that go into the 25 (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C: 20005
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. 1 maintenance kind of activity. I think for the purposes of I
L_ 2 the presentation display, it indicates the areas that one 3 would have to look at and one would focus on. I think the 4 prioritization and the importance of the areas goes to the l 5 next level in the tree initiators, when you look at what 6 has been their equipment history? Has history been such
'7 that this particular pump or equipment has been giving 8 them problems? From a PRA perspective, is that the 9 important kind of thing?
10 And I think the tree is a way of providing some 11 kind of uniform framework into examining the complex subject of maintenance, and that from this depiction -- in 12]
13 fact, from the results that you hear today -- we haven't L __
14 ascribed weights to any individual box, in that kind of 15 context.
16 Tony, you might want to add to that.
17 MR. GODY: Yes. Actually, during the 18 development of the concept, we did consider weighting the 19 various elements of the tree. Because of the many things i 20 Frank said and the differences at different utilities and 21 the enormous number of areas to look at, and there are I
22 some elements under each of these elements, we felt it 23 would be getting into --
be getting too detailed, being .
24 too prescriptive for the team leaders.
I-25 We have experienced team leaders and team i
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. 1 members making --
forming their own judgments on these 2 areas. So, we did think of it. We didn't incorporate it 3 into it.
4 CHAIRMAN ZECH: Let's proceed.
5 MR. BLAKE: I'm going to be talking about the 6 conduct of inspections, and the first area shows that I'm 7 going to be talking about team composition, preparation 8 and what we do on-site.
9 For team composition, the TI, or temporary 10 instruction, has us with a team leader; two engineers, 11 reactor and project type engineers supplied by the region:
12 and one radiation specialist, and two engineer support 13 from headquarters. They're either NRR or contractor.
l 14 We found that the keys to the successful team 1
15 are with the experience and knowledge of the team leader, l
16 along with the experience and the attitude of the 17 engineering inspectors and the radiation specialist, and l 18 that's why we have preparation time to bring them together 19 as a team.
20 You know, the team leader -- we found that his 21 biggest job is to use the tree to keep the focus, keep the 22 inspection on track, and to keep it focused on what it's 23 there for, and that is the assessment of maintenance. ,
24 He's got to be aware of enforcement policy, but
(' 25 not tied down to it. He's got to be prepared to take (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 l l
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1 ownership of all issues, and that's how we develop-I
.t .
2 anything --
our findings as issues that the team follows 3 up on. And he's got to be able to defend all the findings r 4 of the team as if they were his own.
5 He's got to be able to conduct --
to have daily 6 team meetings and bring a group of people with varied 7 backgrounds together, and get the synergism that comes 8 from having different people looking at areas and building 9 on each other's findings. And he's also got to look at 10 the human factors side of the problems that are coming up, l 11 and decide whether the problems are being --
the working
, 12 conditions and the physical- layout are part of the i 13 problem, or whether they are actually -- che utilities are t____
14 working on trying to make the conditions so that they are 15 not part of the problem.
4 16 Engineering inspectors. We try to have at least 17 one senior inspector from each of the three major 18 disciplines -- in the mechanical, electrical and 19 instrumentation and controls.
20 They have to take the lead in those particular 21 disciplines. We also like to have the fourth engineering 22 member be somebody with resident inspector type experience 23 where he can go interface with operations people in the _
24 control room, and find out what maintenance's number one I
25 customer thinks of the product, and how -- what kind of (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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1 interface, what kind of interaction do we have between 2 operations and maintenance.
3 And then these fellows all have to be 4 comfortable dealing with all levels. They have to be able l 5 to go out and' talk'with the craft on their level, and turn 1
6 around.and go in and sit down with any site vice president 7 and discuss the same issue at his level.
8 Radiation specialist we look for is one that is 9 not only attuned to ALARA considerations and how you plan 10 for ALARA, but he's got to have the attitude to --
the 11 willingness to go look at personnel safety issues, along 12 with the ALARA because he's -- with a team this size, we 13 need people doing a little double-duty and take -- when 14 they're looking at radiation safety, it's very easy to 15 look at personnel safety at the same time.
16 The preparation part of the inspection starts j I
17 with a telephone call to the licensee where we announce 18 the inspection, and we tell him the numbe: of things that 19 we need to prepare for the inspection -- that is, the 20 procedures, we identify a list of procedures and things 21 that we'd like to have copies of, and then we follow that 22 up with a letter. ]
i 23 And after we've given him time to gather the ~
24 information, the team leader -- from most regions, the
(
' 25 team leader will go to the site and meet with management, (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND A*/ENUE, N.W., WASHINGTON, D.C. 20005
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4 25 1 establish an interface with the management, get to know l~
t . 2 the layout, and pick up all the information we need to ;
l 1
3 bring back for preparation time. j I
4 The interfaces that are typically established 'l 1
"i are the team leader meets with eithei the site r,anager or I
6 rhe maintenance superintendent on a daily basis, 7 throughout the inspection, when we're on-site.
- 8 Key individual discipline members meet with the 9 discipline engineering specialists when there are issues 10 to be resolved, and the health physics manager typically 11 interfaces with the radiation specialist.
12 COMMISSIONER CURTISS: At this stage, and before i 13 you get to the site and conduct your -- begin with your L_
14 detailed walkdown, just roughly how long a period is this 15 that we're talking about, is it a week, or a day, or a 16 couple of days?
17 MR. BLAKE: We generally announce the inspection
! 18 three to four weeks in advance, and the team leader will 19 go to the site either two or three weeks prior to the 20 inspection, and then the team itself is assembled and has 21 a week of preparation with the procedures and paperwork 22 that the team leader brings back.
23 And things that the team leader also uses in .
24 preparation is, generally gets together with the regional 25 UPRDS coordinator and reviews NPRDS file for that ;
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1 particular plant, and- sometimes requests printouts of I
2 typical --
~ we'd ask for a printout of the last 18 to 24-3 months' worth of inputs for a particular system, that 4 system's of interest.
5 Ue also get information from liRR and from' people 6 that are doing the FRA work, and they give us our cut sets 7 or component and system list that we can use so that we 8 know, from a PRA standpoint, which we should consider to 9 be the most important components, and that way the team 10 can find out whether the utilities are considering these 11 systems and components as important as the PRA says they 12 should.
13 We also look at some of our URC files, past 14 inspection reports. We find it useful to look at sign-it 15 data. Sign-it puts out a nice list that tells us every 16 time the plant changes power level from 100 percent power, 17 it generally has a reason. An awful lot of times the 18 plant doesn't come down all the way, but they'll come down 19 to 80 percent or they'll come down to 60 percent, and 20 there's a statement out to the side that says it's because l 21 of maintenance, and so we can go back at that time frame 22 and find out what maintenance they were doing. Sometimes 23 it's just regular surveillance test, but a lot of times ,
24 there's a piece of equipment that caused them to reduce
\' 25 power for a day or so, and these are useful in (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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.- 27 1 preparation.
l l[ , 2 Team meetings are very important. We start team l
3 meetings with the first day that the team gets together.
4 It's very important that they be organized and that the L 5 team leader establish himself as that. And they start 6 with, like I say,.the first day of preparation week, and l 7 they continue right on through the early part of the 8 report preparation phase.
9 Now, on-site inspection, as you can see from the 10 slide --
(slide) --
starts with a detailed walkdown. As 11 soon as the team arrives on-site, and the teant is fully 12 badged and has their proper dosimetry, they, either as a i 13 group or individually, tour as much of the plant as is L_
14 accessible, looking for indicators of maintenance--
15 ongoing maintenance, or indications where -- of plant l 16 conditions that may need maintenance. And that becomes 1
17 the subject of the'first day's team meeting --
you know, 18 what areas look like they need work, and which areas we 1
19 ought to be emphasizing.
20 We're looking for such things as packing leaks, 21 oil and grease leaks, broken conduit connections, any type 22 of indicator that says that there's wear and tear on a a
23 plant.
24 Use of the tree that we've been talking about-- i i !
25 we, in our region, tend to use the tree in preparation by (2021234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600
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1 the team so they get familiar with the areas. We'll use
'2 it again as a team, after the completion of the 3 inspection, when we're trying to pull our findings 4 together and make an assessment.
5 In the meantime, it's the team leader's job +-
6 the inspectors are out looking at maintenance in the 7 field, dealing with engineers, dealing with the day-to-day 8 conduct of maintenance and the condition of the plant, and 9 they come in with their findings at the end of the day, 10 and have the team meeting, and that's when the team leader 11 uses the tree and asks them, well, you've got~an issue 12 that's in this area, have you explored what are the 13 engineering -- what's engineering doing about it? What's 14 QC's involvement? What kind of parts are available for 15 this job? Is the store doing a good .. job of .nroviding 16 parts? And that's where you start getting into the 17 different parts of the tree.
18 And that's how we maintain this 80-percent focus 19 on implementation. We keep the team out there looking at 20 what's going on, from observing, watching the mechanics.
21 Are the I&C technicians doing the jobs, following the 22 procedures, to looking at the equipment itself, inspecting 23 it, reviewing engineering analysis that had been out, the .
24 root cause analysis, and do they make sense? Are they
25 well thought out? Do they really tell the story?
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.- 29 1 And then when we get back to the office, after I
c 2 the final week on inspection,_that's when we' sit down w3.th 3 the tree again, and analyze what does it mean, and where 4 are the strengths and weaknesses, and what does that mean 5 ro the various parts of the chart.
6 Any questions?~
7 CHAIRMAN ZECH: Not at this time, I don't think.
8 Let's proceed.
9 MR. BLAKE: I'll turn it over to Tony.
10 CHAIRMAN ZECH: Thank you.
11 MR. GODY: One point I'd like to make. these 12 team meetings are a very important aspect of these team i 13 inspections, maintenance team inspection, any team
.w 14 inspection, that's the interaction between the team 15 members in the evening, where they go over the areas that 16 they've looked. They may have been in separate areas.
17 They get together and find commonalities, as far as 18 problems go, or even strengths, but that's one of the i
19 major points of a team inspection, is that interaction.
20 The inspection status -- the team inspections,
, 21 maintenance team inspections are currently planned to 22 cover all operating sites t.y the middle of Fiscal Year 23 1991. To-date, we've conducted 23 inspections and four ,
24 are currently in progres .
i
!* - 25 CHAIRMAN ZECH: Does that 24 mean 24 completed?
i l
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i f 1 MR. GODY: Twenty-three have been completed, and I 2 .four are currently in progress. j I
3 CHAIRMAN ZECH: Okay.. Thank you.
4 MR. GODY: We've received results from 21 of the 5 inspections, and those results have been used to formulat-
-6 the conclusions shown on the following slides.
7 The overall ratings, the findings overall',
8 indicate that all plants have at least a satisfactory 9 program in place, with nearly half of them evaluated as 10 good. The implementation of these programs, however, was 11 considerably weaker.
12 This same overall conclusion repeats in nearly 13 every branch of the tree. Sufficient programs were in 14 place, but they were not effectively implemented, or not 15 implemented as well.
16 COMMISSIONER CURTISS: Just so I understand the 17 numbers here, the 4.8 percent shows up throughout the pie i
18 charts. Is that --
19 MR. GODY: That's one plant.
20 COMMISSIONER CURTISS: --
just for one plant?
21 MR. GODY: Yes.
22 COMMISSIONER CURTISS: Okay.
23 MR. GODY: And that's the plant here with the .
24 poor implementation.
25 COMMISSIONER CURTISS: All right.
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- 1 MR. GODY: The first element of the tree was I
L - 2 plant performance related to maintenance. These are the 3 areas where we review the operating data and the general 4 plant condition during walkdowns. The results in this 5 area indicated some need for improvement in housekeeping 6 and plant material condition but, as you can see, it's 7 about a 50-50 split again, with the one plant rated as 8 poor.
9 The next area was the management support of 10 maintenance. This reflected that the programs were 70 11 percent satisfactory and 30 percent good, with the 12 implementation 85 percent satisfactory, 10 percent good,
! 13 and about 5 percent poor. Again, programs in place, L_
14 implementation not as well conducted.
15 One area in particular that we had problems in 16 management support, was the engineering support area. That i
17 area showed -- and that was the technical support area, i 18 engineering support within technical support, clearly, the 19 weakest of all the categories in management support.
20 One of the most significant findings from the
- \
21 maintenance team inspection is that engineering support to 22 maintenance was weak and required improvement, with 23 approximately 30 percent of the sites having poor - ,
i 24 implementation.
L ,. . -
25 Some of these problems were -- examples of these (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WA3HINGTON, D.C. 20005 w-mm-----
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+' 1 probl ems , 'repe ti tive failures of equipment were not 2 identified as a basis for changes in the scope of the 3 preventive maintenance programs; inadequate root cause 4 analysis was performed for equipment failures; engineering 5 involvement in the resolution of problems was not clearly 6 evident, and despite vendor recommendations, some 7 preventive maintenance activities were not conducted, and 8 no technical evaluations were performed to support 9 exclusions.
10 The next area was maintenance implementation.
11 As I said earlier, this portion constitutes at least 80 12 percent of the inspection. And the maintenance 13 implementation is subdivided into four areas -- work 14 control, plant maintenance organization., maintenance 15 facilities, and personnel control.
16 The implementation area, the programs were about 17 an even split of 30-50 with the implementation lagging--
18 75 percent satisfactory, 20 percent good, and 5 percent 19 poor, f 20 CHAIRMAN ZECH: Give us some examples of the I
21 poor ones. What were specific areas where you saw poor 22 performance?
23 MR. GODY: Yes. On this one particular tree .
24 with all the red, those were poor.
l 25 CHAIRMAN ZECH: First, how about looking at the l
l (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 l _- _ _ _ _
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'- engineering support chart, first, and then .tell me, in 1
i 2 that area, what in engineering support specifically did i 1
l 3 you. find poor.
4 MR. GOIJY . Engineering support?
5 CHAIR!!AN ZECH: That's it. We've got it on the 6 screen now. That's the one I'm talking about, 4-2, 4.2. l 7 (Slide) 8 MR. GODY: That's where the repetitive failures 9 of equipment were not identified as a basis for changes in 10 the scope of the preventive maintenance program.
11 Engineering did not perform adequate root cause analysis 12 for equipment failures. Engineering involvement in the 13 resolution of problems noted on work orders during the 14 performance of the job was not clearly evident. And 15 despite vendor recommendations, preventive maintenance 16 activities were not conducted, and engineering did no 17 technical evaluation to support these exclusions.
18 Engineering resolution of problems took a 19 considerable amount of time, some cases up to two years, 20 and no -- well, that's about the examples I have.
21 CHAIRMAN ZECH: You mentioned engineering 22 support earlier as weak, and I would say that is, indeed, 23 a key conclusion from what you've told us so far, that -
24 that is something that is a vital factor in a good 25 maintenance program, that is good engineering support.
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. ~,
,1 MR. GODY: Right.
I L- 2 CFAIRMAti ZECH: On the next chart, maintenance 3 implementation, it looks, r e a 't l y , pretty good. You do 4 have a few -- 9 M 11 nunb r of poor implementation, rould 5 you giv us an3 specifics in thM area?
6 MP MTRAGLIA: The next chart --
7 c.HAIRMAN ZECH: The next chart --
3 MR. MIRAGLIA: -- would be an example of.a weak 9 area in that limb of the tree.
10 MR. GODY: That was performance of maintenance 11 trending. Fifty percent of the programs were in place 12 were satisfactory; 30 percent were good: -15 percent were 13 poor, t_ _.
14 CHAIPMAt! ZECH: But what -- in maintenance 15 trending, what specific areas of maintenance, do you 16 recall?
17 MR. GODY: They were keeping equipment 18 histories, but they wera not evaluating those histories to 19 see if any trends were developing.
20 CHAIRMAN ZECH: I see.
21 COMMISSIONER CURTISS: They weren't loing 22 reliability trending on their equipment is what you're 23 finding here? -
24 MR. MIRAGLIA: Some facilities had programs 25 which talked about a reliability-based type maintenance (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 KHODE ISLAND AVENUh', N.W., WASHINGTON, D.C. 20005
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-- 1 program, but those programs weren't fully implemented.
2 COMMISSIONER CURTISS: They've got a stack of i 3 documents that shows they're good employers, but they're 4 not looking for the trends in their equipment in those 5 areas.
6 MR. MIRAGLIA: And though there are indications 7 that people are perhaps tending in that direction, but the 8 implementation is severely lagging.
L 9 MR. GODY: Some other examples of problems in 10 the trending, programs were not . capable of identifying 11 repetitive failures over a long period of time. They did 12 not identify subtle trends or individual component failure 13 trends.
14 Information documented on completed work 15 packages was not adequate to assist in root cause analysis 16 and failure trend analysis. Some programs were 17 fragmented. Reviews did not see all the available failure 18 information. System engineers only saw PM work packages 19 and not corrective maintenance work packages.
20 Sites where MPDS was being maintained but not 21 utilized to identify component failures, trends in those 22 components.
23 CHAIRMAN ZECH: All right. -
l 24 MR. GODY: Okay.
l (~
25 MR. MIRAGLIA: That brings us to the summary of (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 i i
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- 1' 'where we are,. based-upon the~ inspections and---- ;
- .a
-2 CHAIRMAM ZECH: Before you get to the summary, 3 could you give ' us any particular noteworthy good
~4 practices?
5 .MR . GODY: Yes. Let me first - tell you ~ some '
6 common findings _we found throughout, and that ~ was failure i
7 to use' or follow procedures, inadequate procedures, I&C
- 8 was i generally weaker than the other areas, . generally 9 weaker than electrical and mechanical' maintenance. I 10 mentioned inadequate or a- lack . of training analysis.
'11 Shallow:or poor root cause. analysis. Informa1' control or 12 lack of control of contractors. Difference in approach to
- 13 . safety related as opposed ' to . balance-of-plant equipment.
14 Inadequate' spare part . procurement- and storage, resulting _
15 from inadequate planning.
16 As far as.the strengths go, in the work control 17 area, establish work control and maintenance work 18 scheduling were generally - evaluated as good. Strengths 19 noted was a program capable of scheduling various -- and 20 controlling various types of activities simultaneously.
j 21 CHAIRMAN ZECH: Did you noti & eay programs that i 22 were good enough that you should take special note of and 23 pass it along to others? -
24 MR. GODY: Yes, I'm sure we have. I can't 25 provide you that information.
l 1
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- 1 MR. BLAKE: I could comment on one, one of the 2 charts you've got here. The teamwork displayed between 3 operations, maintenance and the other people involved in 4 maintenance at Grand Gulf was exceptional.
5 The meetings having to do with_ maintenance were 6 conducted by operations, and everything was done as a 7 ww. There was no attitude at that' facility, of "that's 8 y u a and this is mine". It was "This is our plant, let's 9 fix it", and that was -- we felt that was exceptional, 10 too.
11 CHAIRMAN ZECH: Very good.
12 MR. GODY: I have several other strengths that 13 were identified, too.
14 CHAIRMAN ZECH: Excuse me, but along the same 15 line, one of the strengths like that I've found, at least 16 it's been my observation, watching maintenance during my 17 plant visits and noting that the operations people and the 18 maintenance people are working-together, which is the.way 19 it ought to be -- one of the greatest strengths there is 20 communications, I've found, because if they're 21 communicating properly, and they all know --
especially I
22 the question I like to ask them when I see some !
23 maintenance going on, I say, "Who's in charge of this .
24 program?" Well, of course, they're doing the maintenance, i
~
25 they are in charge of that, but I say, "Well, who's in l
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- 1 charge of the plant?"
I L . 2 And if they know that the operators are in 3 charge, that's kind of the right answer, as f ar. as I ' m-4 concerned. Often, they're in communication directly with 5 the operators, and -- depending on the maintenance, of 6 coursa -- but if there's a good, tight system of 7 communications and there's a good working teamwork 8 relationship between the operators and the maintenance 9 organizations, and there's an understanding, clearly, that 10 the operators are in charge, especially if the plant is 11 operating -- even if it's not operating, they ought to 12 know the operator is in charge, but when the plant is
' 13 operating, as you know, that's the time when we have trips L.-
14 occasionally, and not only maintenance but surveillance 15 going on, so the communications is vital.
16 Did you see any communications, specifically 17 good or bad, indications during your maintenance i 18 inspections? Did you note that specifically, or do you 19 recall any particularly good or bad communication 20 interfaces?
21 MR. ROE: There has been one good example that l 22 we have seen, not necessarily maintenance inspection, but l 23 an outgrowth of other of our views associated with .
l~
24 operations and maintenance, and that is at some of the new a
' ~
25 power plants, especially I remember the McGuire plant, l
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i . I where che operations department and the maintenance 2 department are on the same shift, so they rotate together, j
.3 They see each other every day. They're part of a team.
4 In many plants, the operations depa . ment may 5 rotate on a different scheme than the. maintenance 6 department, so there .always is a different interface.
7 Duke has intentionally had that combination so that there 8 is a team that rotates consistently throughout the day.
9 CHAIRMAN ZECH: That would be a good --
10 MR. MIRAGLIA: I think also to point out --
1* CHAIRMAN ZECH: --
thing to point out, I think, 12 to perhaps others.
13 MR. MIRAGLIA: Mr. Chairman, I think the 14 maintenance team inspection reports indicate strengths 15 that are observed in the maintenance team inspection, as 16 well as the weaknesses.
17 CHAIRMAN ZECH: Well, it's important to point 18 out the strengths, and I just mention communications as an 19 example.
20 MR. GODY: I've got several other strengths.
21 The last area on the tree was personnel control, and this 22 area, the inspection stands out as the strongest.
23 Inspection to identify the ratio of experienced 24 maintenance personnel to apprentices was approximately 3-25 to-1. The on-site experience at several sites was (202)234-4433 NEAL R. GROSS & COMPANY, INC. (2021232-6600 i 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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. 1 considered a strength.
I t_
2 The licensee also had well-defined programs for 3 staffing and promotions, and with well-defined job 4 descriptions and attributes for new hires. Other 5 strengths, examples of strengths were use of the 6 centralized work control center with multi-disciplinary 7 review and assignment of an HP, a health physicist, to 8 help coordinate. That was identified at Arkansas.
9 Use of mock-ups for complex jobs reducing 10 potential for errors and ALARA considerations, given 11 radiation dose low at Wolf Creek. Use of a qualification 12 matrix by maintenance supervisors, for work scheduling and i 13 planning, again, at Wolf Creek.
t_. ._
14 High quality maintenance facilities maintained 15 at Davis-Besse, and the use of predictive maintenance at 16 Davis-Besse. Those are some of the notables we found in 17 inspections.
18 CHAIRMAN ZECH: Well, let me give you a couple 19 observations that I've noticed, I think, in looking for 20 maintenance during my plant visits. The biggest thing 21 I've found, I think, is that -- does the organization I
. 22 itself recognize the importance of maintenance?
23 In other words, we focus on the operators. Most 24 people appreciate the importance of the role of the i
' ~
25 operators, but do they focus on the maintenance people?
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'i And my feeling has been that that's not always the case.
2 The good examples, the good maintenance plants 3 that I think I've seen are the ones that have a 4 recognition of their maintenance people, the importance of 5 their role. And it's people and recognition of the 6 importance of maintenance.
7 If it's pointed out --
at the plants I go to, 8 they try to take me to the maintenance people, ask me to 9 talk to the maintenance people, or else emphasize 10 maintenance during the briefings. To me, the management 11 leadership involvement, acknowledgement, recognition of 12 the importance of maintenance starts +o be -- at least 13 that's on the top of my list. And it's the people 14 themselves. Are they respected as much as the operators, 15 for example.
16 Do they view maintenance as truly important?
17 And those are some of the things that I think you can kind 18 of sense in a visit to the plant sometimes, and do the 19 maintenance people -- have they got a good professional 20 maintenance group? Do they have good maintenance 21 facilities?
22 Some plants, you know -- some have very fine 23 training facilities for maintenance as well as operation. -
24 More plants are moving in that direction, I think, but the 25 maintenance training is important, and sometimes I've seen (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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42 I.
p 1 some excellent maintenance training facilities. So, that, i
L - 2 to me, is a recognition of 'the importance of maintenance 3 on the part of plant management. So, that is kind.of the 4 starting point.
5 Usually, when you see a plant that has that kind 6 of emphasis on maintenance, you find good maintenance in 7 the plant. So, I think it's important that you -- you 8 know, thinking about the contribution of maintenance to 9 safety and to our regulations, it's important, I think, to 10 try to identify those maintenance practices that are good il practices and contribute to safety and perhaps land 12 themselves to better all around maintenance to the plant, 13 better all around operations, better all around t_ _
14 reliability and safety. So, it's important to look at the 15 good practices, too, because you have mentioned, you know, 16 inadequate procedures. That's pretty basic.
17 You've mentioned failure to follow procedures.
18 That's also pretty basic. So, if you see that frequently, 19 you know, it's not very impressive, but I fhink you must 20 look at the constructive side because there are good 21 maintenance practices out there that should be brought to 22 the attention of those who aren't making adequate
. 23 procedures and those who aren't making adequate -
24 implementation of those procedures and who are not k ... -
25 following through on their procedures as they should (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
43 l' because the good practices in maintenance are not that i
2 difficult, but they do require senior plant attentioni j 3 emphasis, and a belief that it's important.
4 MR. GODY: Yes. Well, maybe I didn't emphasize ,
5 that enough, but the report does, and the inspection does i
6 stress strengths as well as weaknesses. i 7 CHAIRMAN ZECH: Good, because it is important.
8 I think we're making a greater contribution to this 9 inspection effort, which is a rather sizable one, if we 10 mention the good practice as well as those who are not so 11 good.
~
12 So, I think that those utilities who will learn 13 most from your efforts, will recognize that if they want 14 to improve, perhaps that there are some ways that aren't 15 too difficult, that they can improve. And so I do think 16 that's worth emphasizing.
17 All right. Let's proceed.
18 MR. MIRAGLIA: Mr. Roe will give the summary.
19 MR. ROE: In summary, since early 1980s the 20 staff has had a focused interest on nuclear power plant 21 maintenance. Early in the '80s, the Salem anticipated i
22 transient scram, in 1983. The Davis-Besse, San Onofre and 23 Rancho Seco events in 1985 highlighted the importance of -
24 maintenance for nuclear safety.
25 The staff has taken many steps to ensure the (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 i
t l-
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- 1 improvement of maintenance in the industry. These include I
g, 2 the survey of maintenance, which we published in NUREG l 3 1212; close coordination with the INPO staff on 4 maintenance guidelines; the development of the policy
~5 statement for the Commission; and, mest recently, our 6 development and implementation of the maintenance team 7 inspection program.
8 We are now through approximately one-third of 9 the team inspections. We see the results to-date showing 10 that maintenance programs, the papers, the documents that 11 have been developed, are adequate or they are good.
12 However, we also see that the implementation of these t 13 documented programs are lagging.
L_
14 Based on the inspection results to-date, we see 15 a continued need for improvement in the maintenance 16 activities at the nuclear power plants. That's a summary 17 conclusion of our plan presentation. We're open for any
- 18 additional questions, sir.
19 CHAIRMAN ZECH: All right. Thank you very much.
20 Commissioner Roberts?
21 COMMISSIONER ROBERTS: On your t'ee, under 2, 2.0 _
22 management commitment and involvement. What are the .
[
23 criteria used to evaluate 2.2 management vigor and ,
1 24 example? j 4
t I
v b 25 MR. GODY: Management vigor and example is some l 26 of the things that Chairman Zech said. If you see a (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 )
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1 respect for the maintenance organization, provided good 2 tools, good working conditions, management gets out to the 3 plant --
4 COMMISSIONER ROBERTS: Can you quantify that?
5 MR. GODY: Yes. It's how much managenent is 6 involved in maintenance activities or the support of 7 maintenance activities, and how they demons.trate that to 8 the remainder of the staff. That's what we mean by 9 management vigor and example.
10 But what I'm looking for is the --
11 MR. TAYLOR: You really assess it. You don't 12 quantify it, as such. It's more --
13 MR. GODY: Right.
14 MR. TAYLOR: -- by talking to people --
15 MR. GODY: Judgmental evaluation of management's i
l 16 involvement.
17 MR. TAYLOR: -- finding out is management paying 18 attention, and assessing that.
19 COMMISSIONER ROBERTS: So, it's a subjective 20 evaluation?
21 MR. TAYLOR: That's an assessment.
22 MR. GODY: Absolutely.
23 MR. TAYLOR: Yes, sir. -
l 24 COMMISSIONER ROBERTS: All right. Next 25 question. In these maintenance inspection visits, have (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 L__________ _ _ _ _ _ _ _ - . -
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46 1~ violations been found that resulted in enforcement action?
I L- 2 MR. GODY: Oh, yes. Collected data on 16 sites 3 resulted in 39 violations. Twenty-five of those were 4 'against Appendix B.
5 COMMISSIONER ROBERTS: So, you're telling ne 6 that we have the existing regulatory mechanisms to address 7 problems in maintenance?
8 MR. GODY: Yes.
9 MR. MIRAGLIA: Clearly, in the safety --
10 MR. GODY: But not the balance-of-plant.
11 MR. MIRAGLIA: Clearly, in the safety --
12 COMMISSIONER ROBERTS: Ah, well, wait a minute 13 now, let's take one thing at a time.
L__
14 MR. GODY: Yes, we do.
15 COMMISSIONER ROBERTS: Thank you. That's all I 16 have.
17 CHAIRMAN ZECH: Commissioner Rogers? i 18 COMMISSIONER ROGERS: Well, just -- that, ]
19 really, was r. question also that I wanted to ask, maybe in 3 20 a little bit different way, but the same idea, I think.
21 Did you find any evidence of unsatisfactory 22 maintenance practices, that it would be difficult for us 23 to cite the licensee for a violation?
24 MR. GODY: In the balance-of-plant, sometimes--
. _ l 25 presents a difficulty. However, in these inspections, we (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 j 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 l I
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1 call for stre'ngths and weaknesses. And when we identify 2 weaknesses in the transmittal letter to the licensee. We I l
3 ask them to address the weaknesses, to respond as to their 4 corrective action to the weaknesses. And though there may 5 not be a specific requirement associated with that 1 6 weakness, we still ask them to address it, but in other 7 areas --
8 MR. TAYLOR: So, not every deficiency represents 9 a violation --
10 COMMISSIONER ROGERS: A violation.
11 MR. GODY: No.
12 MR.. TAYLOR: -- per se.
13 COMMISSIONER ROGERS: Well, I'd like to pursue 14 that a little bit. I mean, how serious would some of 15 these deficiencies be that would not, could not constitute 16 a violation?
17 MR. GODY: Well, depending on the seriousness, 18 you can make anything a violation. If it's really 19 serious, we'll find the regulatory basis to make it a 20 violation. It's as simple as that.
21 I have an example of one of the utilities.
22 There was an air system problem, water in the air system, 23 and it was balance-of-plant. So, what they cited them -
24 against was air system configuration differed from the 25 FSAR, and the violation was issued against 10 CFR 50.71, (2021234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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l 48 1 failure'to update the FSAR.
i L- 2 So, with some innovative thinking and planning 3 by the inspection teams, you can generally tie something 4 that's serious enough, to a regulation.
5 MR. MIRAGLIA: The other thing,. in the context 6 of balance-of-plant where you have to perhaps be 7 innovative in that kind of context, main % nance nd good 8 maintenance will perhaps keep you out of trouble, and that 9 there is balance-of-plant equipment, if not properly 10 maintained, leads to challenges to operators, and that 11 kind of thing.
12 CHAIRMAN ZECH: It leads to safety concerns --
13 MR. MIRAGLIA: That's right.
c_
14 CHAIRMAN ZECH: -- and to safety challenges of 15 the steam supply system.
4 16 MR. MIRAGLIA: And if you lock historically at 17 trip reductions, we've come a long way. Our data 18 indicates that, the industry data indicates that, and 1
19 major improvements were made by looking at feedwater 20 control systems, for the most part, are not safety-related 21 systems. And it's the maintenance and the care and 22 feeding of feedwater control systems that have led in that 23 reduction of trips, challenges to operators, and the like.
24 Similarly, if you just look at that improvement 25 and saying there is still a number of trips out there, (202)234-4433 ITEAL R. GROSS & COMPAtW , INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
49 1 it's in the electronic hydraulic systems under turbine.
2 Again, not a safety-related system. However, it leads to 3 trips; trips lead to challenges to operators, and there is 4 that link there. And, clearly --
3 COMMISSIONER ROGERS: When you use ,that ter.,
6 safety-related system, I just think you should -- you 7 could -- you ought to make sure we all understand what it 8 is you're -- that's a technical term that you're using, 9 you know, that's not an evaluation term.
10 It is safety-related, that's what we're finding, 11 but you're using a technical--
12 MR. MIRAGLIA: In the context and in the --
l l 13 COMMISSIONER ROGERS: -- NRC term here when you l
l 14 say that, and I think it's wise to make sure that you're 15 putting quotes around that --
l 16 MR. MIRAGLIA: Yes, sir.
17 MR. TAYLOR: That is in quotation marks, yes, 18 sir.
19 COMMISSIONER ROGERS: --
and that's a point that 20 I think we all have to appreciate, that technical 21 definition is --
1 22 MR. MIRAGLIA: Yes, sir. Our arcane j arg; .n 23 that's grown with time. -
24 COMMISSIONER ROGERS: Well, I think we should be 25 careful about it, though, because we are learning that (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 j 1_
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50 lq 1 that was not the full answer in how to define a safety-1 L- 2 related system.
3 MR. MIRAGLIA: Yes, sir.
4 MR. TAYLOR: We agree.
5 COMMI S SIGIJER ROGERS: Yes. Have you seen any 6 correlations between the results of your inspections, that 7 might relate to any of the other indicators of 8 maintenance? In other words, did you see anything that 9 might, for instance, provide some useful correlation.with 10 the AEOD in maintenance-effectiveness indicators, based on 11 the 11PRDS component failures? Have you had a chance to do 12 that?
13 MR. GODY: We haven't studied that yet. What we c_
14 have studied was the correlation with the existing 15 performance indicators, and we found none.
16 COMMISSIONER ROGERS: You found none.
17 MR. GODY: Right, no correlation with the--
18 that's over the period, you know, the one-third of the 19 plants being inspected.
20 COMMISSIONER ROGERS: Yes, right.
21 MR. GODY: As far as the NPRDS performance 22 indicator that's being proposed and worked on now, no, we 23 haven't. -
24 COMMISSIONER ROGERS: I'd be interested in --
~
25 MR. MIRAGLIA: I think we would agree with the
/
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1 AEOD basic findings that the NPRDS is out there and it's
.2 being used in different ways and to different degrees, 3 within the industry and, clearly, that maintenance 4 trending is consistent with the report that AEOD gave you, l 5 as how various utilities trend maintenance information is 6 quite different, but there's that kind of consistency in:
7 observations.
8 COMMISSIONER ROGERS: There's a question whether 9 this gave a little additional insights into the utility of 10 that indicator that AEOD is developing, though.
11 MR. MIRAGLIA: I think our observations are 12 basically consistent, but I don't think we've sat down and 13 compared notes to that kind of detail.
14 COMMISSIONER ROGERS: When do you expect to do 15 that?
16 MR. GODY: Well, shortly -- as a matter of fact, 17 in June -- we're going to have completed almost half of 18 the inspections. We're all going to get together, the 19 regions and us, go over the program to-date, and see if we 20 have to make any adjustments, and that would be a good 21 time to discuss it.
22 -
MR. TAYLOR: We could go today to AEOD and have 23 them part of that review, mid-point review. -
24 MR. GODY: Yes, have AEOD involved in it. Yes.
(
25 And that would be a good time to discuss it.
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I i- . I l 1 52 1 COMMISSIONER ROGERS: Well, we certainly are q r
l L'- 2 very interested in those results of that comparison. You 3 found that about 28 --
5 percent of the 28 plants were 4 rated as poor, but then you had 29 percent were poor in 5 implementation or engineering support, 25 percent in 6 implementation of maintenance trending.
7 Now, what was the overlap of those two, roughly, 8 25 to 30 percent of the plants, were they common --
9 MR. MIRAGLIA: They're common.
10 COMMISSIONER ROGERS: Was the overlap 11 essentially the 5 percent, when you're all said and done?
12 How do they fit together?
13 MR. MIRAGLIA: I don't know if we can answer t
14 that now --
15 MR. BODY: I don't think we know that answer 16 right away.
17 MR. MIRAGLIA: -- but that's something we could-i 18 provide to you. I don't know if you broke it down that 19 way.
20 MR. GODY: No, I didn't, but --
21 COMMISSIONER ROGERS: Well, I'm sort of curious 22 because those are rather large numbers, rather large i 23 percentages, and yet the overall statement is that we've .
p 24 only got about 5 percent of those plants that were rated k- poor and. yet, in implementation of engineering support, 25 (202)234-4433 NEAL R. GROSS & COMPANY, INC. (T32)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, c.C. 20005
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1 nearly 30 percent --
2 MR. TAYLOR: A higher number. A higher number 3 in trend maintenance.
4 MR. MIRAGLIA: Yes, you unders tand . that 's 5 because it rolls up into the overall, and each limb of the 6 tree rolls up to an overall, and then there's an overall 7 on the three basic limbs.
8 MR. TAYLOR: Well, I think that's certainly a 9 significant indication that that many are weak in that 10 area, and those are important --
11 COMMISSIONER ROGERS: Well, I guess --
how bad 12 do they have to be to be rated poor in your --
I think 13 that's what it comes down to because I would.think a lack 14 of implementation of engineering support to a maintenance 15 program -- you know, that's pretty poor right there. You 16 don't have to --
17 MR. MIRAGLIA: Mr. Gody went over some of the 18 examples, and I think some of those exemples would be 19 enough to say that that's --
you know, poor root cause 20 analysis more than once, no support, or not doing what the 21 vendor recommends with no evaluation, those kinds of i
22 things would clearly influence the judgment 'of the team
, 23 and pushing them down into a poor rating.
, 24 MR. GODY: That's where the weighting goes in, k
25 with their judgment.
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.54 1 COMMISSIONER ROGERS: Well, I think it's I
L - 2 important to try to understand how you come to that 3 conclusion of 5 percent because that's -- if this is a 4 representative sample of the whole industry, and we're 5 talking about only 5 percent are poor, that's.relatively a 6 small number.
7 COMMISSIONER ROBERTS: Isn't the 5 percent one 8 plant?
9 MR. GODY: Yes, one plant.
10 MR. MIRAGLIA: It's the results to-date. The 11 overall is the results to-date. Now, whether that 12 maintains itself over the next two-thirds of the 13 inspections we're to do, remains to be seen.
L_
14 MR. TAYLOR: But I think even those plants that 15 are satisfactory have numbers of areas of weakness and --
16 MR. MIRAGLIA: Weakness.
17 MR. TAYLOR: -- vulnerability and, you know, 18 you'd like to see everybody be in shape.
19 COMMISSIONER ROGERS: Well, I think we should be 20 cautious about --
21 MR. TAYLOR: They're not.
22 COMMISSIONER ROGERS: --
landing on that 5 23 percent number as representative of what the industry is -
24 at the moment because --
- b. ' Absolutely. It is --
25 MR. MIRAGLIA:
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l 55 1 COMMISSIONER ROGERS: -- it is only one plant, 2 and --
3 MR. MIRAGLIA: And it's the saddest to-date.
4 COMMISSIONER ROGERS: Yes -- and the fluctuation 5 in that, the statistical fluctuation in that number is 100 6 percent.
7 MR. TAYLOR: Well, let me draw an example. In 8 the chart you have, maintenance inspection tree for a 9 plant that was good, with lots of green, is ignoring the 10 role of PRA in the maintenance process, 11 !!ow , we all believe that PRA with its dominant 12 sequences, is sending us messages, and one would think 13 that the, you know, the dominant sequence equipment would 14 stand out in the worry of all in the plant, including the 15 people who are responsible for maintenance. So, they know 16 that that particular series of equipnment may, indeed, 17 contribute to the dominant sequence to potential core 18 effect, and, you know, that's the -- if you have the PRA, 19 you ought to use it.
20 COMMISSIONER ROGERS: Well, that sort of leads
. 21 into my next question, which is of those~ 28 plants, how j i
i 22 many did use the PRA in their maintenance prioritization 23 process?
24 MR. ROE: Well, maybe we can answer the question i
x~ ,
25 a little bit differently than a quantitative one. We 2
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1 found out that even those plants that do have a PRA, are I
L ;- 2 not effectively using it. And we do have a certain sample 3 of the plants that do have either a plant reference or 4 something close enough to be able to utilize it, and they 5 weren't all effectively utilizing it.
6 MR. TAYLOR: And that may link- engineering 7 involvement to maintenance because the engineering -- the 8 system engineers and so forth, are going to be, and --
, l 9 MR. MIRAGLIA: That's usually where the FRAs and 10 dominant maintain --
11 MR. TAYLOR: -- that's where the dominant memory 12 of PRA should be.
' Well, I think one of the problems 13 MR. BLAKE:
L-14 you have is that the planners are a lot of times setting 15 priorities, and they're not linked to the PRA. The 16 engineers may be, but the planners have an idea of what 17 things are important. If they don't know that it comes 18 from PRA, if some of them know that it comes from 19 engineering, but there's no link, no direct link, and 20 that's why it comes out red.
21 COMMISSIONER ROGERS: Well, it sounds to me that 22 you're finding that there are some rather serious 23 deficiencies in the programs, even those that more or less -
l 24 are okay, they still have some rather serious deficiencies
.L 25 in them, and I think we want to keep that very much in
)
1 l'
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" 1 mind as we look at this whole picture.
l 2 CHAIRMAN ZECH: Thank you.
3 Commissioner Curtiss?
4 COMMISSIONER CURTISS: Just a coupie of 5 questions on the tree. As I looked at this, I was 6 intrigued not to see a box on preventive maintenance. Is 7 that because PM is infused throughout all of this, and 8 this is looking at both corrected and preventive?
9 MR. GODY: Yes, preventive maintenance is 10 addressed in the temporary instruction.
11 COMMISSIONER CURTISS: So, there's nothing here 12 that you would look at in a chart that would jump out at 13 you --
14 MR. MIRAGLIA: These same activities would be 15 involved on the conduct of a preventive maintenance 16 program or another maintenance program.
17 COMMISSIONER CURTIST I wanted to isolate 18 preventive maintenance and look at one of these charts or 19 look at one of the reports and evaluate how effective a 20 utility was on PM. It doesn't look like it would jump out 21 from the chart. Would it jump out from the report?
22 MR. MIRAGLIA: I think within the conte::t of the 23 TI, there's some discussion of preventive maintenance, and -
24 we can give you a -- there's a judgment as to how much are i
25 chey doing relative to corrective maintenance, and we do (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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1 get a feel for their PM program as opposed to their I
L - 2 corrective maintenance.
3 MR. TAYLOR: Yes. Some of the planned 4 maintenance in the outege, for example, when you're in 5 there and look at it, is strictly preventive -- you know, 6 taking the pump down because it's time is preventive 7 maintenance. Isn't that right, Tony?
8 MR. GODY: Yes.
9 MR. TAYLOR: So, you would pick that up with 10 corrective maintenance.
11 COMMISSIONER CURTISS: If a utility were doing 12 absolutely no preventive maintenance, though, when you go 13 through your walkdown, and you look at the PRAs, and you 14 look at the SALPs, and the information that you gather, 15 the equipment reliability, it wouldn't necessarily jump 16 out at you, it wouldn't be a finding of some sort that a 17 utility had no preventive maintenance program.
+
18 Is there a way to get at that, or is there 19 something in this process that permits us to say, or to
- 20 conclude in looking at one of these, that a utility either
)
21 is placing th. 'ght amount of emphasis, or not enough, on 22 preventive mainter.ance?
23 MR. GODY: The amount of emphasis we don't get l
24 into, but the temporary instruction itself directs the l
Li .
l, 25 inspection team toward preventive maintenance and (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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59 1 corrective maintenance.
2 COMMISSIONER CURTISS: Okay.
3 MR. BLAKE: One of the things that utilities 4 like to plot is the ratio of preventive maintenance to 5 corrective maintenance, and th-y always come right up to 6 the team and tell us what that is, and where it used to 7 be, and how they're improving and, of course, that's one 8 of the - things we try to look at, is to see, are . these 9 numbers real because we see -- you know, we've seen some 10 indications where planners are sending people out to 11 correct things with a preventive maintenance on their work 12 order.
13 MR. TAYLOR: There's been a lot of dialogue 14 among the utilities about what is the right ratia of 15 preventive maintenance to corrective maintenance. That 16 number has been mentioned in many utility forums It's 17 not -- some people ~believe it ought to be 50 to 60 18 percent, but that number has been -- it's kind of like a
, 19 judgment, a balance, depending on the equipment.
20 COMMISSIONER CURTISS: Two other questions on 21 the chart here, on --
I guess on the BU-2, there's one 22 box that I didn't understand -- 6.5 there at tnr very 23 bottom. Do I understand --
the one tha t ' s blue-slash- .
24 yellow. Blue means you didn't lock at a program?
i 25 MR. GODY: Yes. Not enough information on the (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 l
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I .. l 60 1 program.
1
-L._ 2 COMMIS SIOl'ER CURTISS: .You . come up with a box, 3 that, on the program side, you did look at, but- on the 4 implementation side has a conclusion. I wasn't sure I 5 knew what that kind of color coding meant.
6 MR. BLAKE: Well, can I answer that because that 7 came from our region.
8 COMMISSIONER CURTISS: Are they listening?.
9 MR. BLAKE: Probably. The reason for that is, 10 if we got into an area and this happened to be a 11 peripheral area of -- if we got indications that something 12 was working, but we had problems in another area, then we 13 didn't bother to -- or didn't take the time to go look for -
u . _. -
14 the written program that established how things were 15 supposed to work in that area, we just made note of the 16 fact that there were interfaces and they seemed to be 17 working on a satisfactory level, nothing to write home 18 about, but we didn't take the --
use the manpower to go 19 read the written program.
20 MR. MIRAGLIA: This is -- 80 percent of the 21 material is being done and watched in the field, and they i l'
22 were able, based on their observation, to nake the, i
23 judgment about the implementation, yet they didn't perhaps . 4 1,
24 --
I 25 COMMISSIOfiER CURTISS There may not be any (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 I
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- I 1 formal procedure, but they --
)
2 MR. MIRAGLIA: Or if there was, they didn't go I 3 back and look enough to come to a judgment relative to the 4 documentation, and that's all that's indicating. Based on 5 their observations of what they saw, they would say that 6 whatever is out there appears to be working, whether there 7 was a written program or not, and they didn't spend the 8 resources to document the program.
9 COMMISSIONER CURTISS: One other question on the 10 chart. The criteria rating that you've got down at the 11 very bottom, where you put an X in, is there some reason 12 on these two charts, that the X'es weren't put 'in , or 13 would a completed chart have the X'es entered?
14 MR. GODY: No, that -- some regions do use it, 15 some don't.
16 COMMISSIONER CURTISS: It's an option.
17 MR. GODY: Yes, it's up to them.
18 MR. BLAKE: We took that as an option, and we 19 did not roll that one up that way.
20 MA. GODY: That's just a mark good, 21 satisfactory.
22 COMMISSIONER CURTISS: I guess I have one other 23 question, picking up on the point that Commissioner Rogers .
24 made about how this approach calibrates with other things 25 that we've been doing.
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62 1 Do you have a . feel, based upon the 21 that I I'
.L_ 2 you've done to-date, the 28 plants that you've done so I
3 far, whether the findings that you've seen square with 4 SALP ratings that we've had on maintenance?
5 MR. GODY: There's a good correlation with the 6 SALP. The one plant that was poor had a SALP 3 in 7 maintenance.
8 MR. ROE: If you were to take and distribute the 9 findings of the plants ue've done so far, against the SALP
.0 ratings, you'd find a very,'very close correlation. Maybe 11 not plant by plant, but overall you'll find a very close 12 correlation. We've looked at it. There is some change.
13 The SALP sometimes captures an historical period that L._
14 could be as much as 18 months old, so there could be some 15 improvement, but overall there's a very close correlation.
16 COMMISSIONER CURTISS: One other quick question.
17 How would you, just major points, compare and contrast 18 what you do here with the IMPO team inspections? What do 19 you cover that they don't? What do they cover that you 20 don't? And what are the differences that you see in terms 21 of -- not the mechenism for taking enforcement action, I 22 realize that's a separate question, but in terms of what 23 you cover, and your focus and approach, are there major .
_ 24 differences?
k- 25 MR. GODY: I think this has been developed, we e h (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 l
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- 1 look at pretty much the same areas that INPO looks at in 2 their evaluations. There's just so much you can do in 3 maintenance and its related activities. It closely 4 parallels the TNPO guideline areas.
5 COMD' sSIONER CURTISS: Okay.
6 CHAIRMAN ZECH: In the area of predictive 7 inaintenance, can you talk to us just a little bit about 8 that? Did that come out much in your inspections, the 9 subject of predictive maintenance? You mentioned 10 corrective maintenance a few minutes ago, and you 11 mentioned maintenance that may be planned. How about 12 predictive maintenance?
13 MR. GODY: Well, based on the reports we've i
14 reviewed so far, the ones that have come in, slightly more 15 than half of the utilities have a formal predictive 1
16 maintenance program, and it varies --
17 CHAIRMAN ZECH: You may recall our policy i statement that we have in effect now suggests that they 19 should consider predictive rnaintenance. So, about half of 20 them have it, huh?
21 !!R . GODY: Yes, programs in all varying dugre:es, 1
l 22 CHAIRMAN ZECH: How does it look to you? How l
l 23 does the predictive maintenance program look? Is it an .
f- 24 aggressive program, or i t' it just on the books? !
l
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25 MR. GODY: No. In rm cases, it's just on the 1
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1 books. They implement it to various degrees. I think i- 1 L.. 2 Davis-hsse and -- wha t 's the other one? One plant in 3 Region II have strong programs, and strong implementation 5 4 of those programs.
5 CHAIRMAN ZECH: But they do have corrective j 6 maintenance programs as well as predictive maintenance 7 programs, huh?
8 MR. GODY: Oh, absolutely, yes.
9 CHAIRMAN ZECH: The corrective maintenance, but 10 not so much in the predictive area. In other words, 11 they're not looking ahead. They're looking corrective, 12 which is kind of looking ahead, rather than just 13 preventive maintenance?
u 14 MR. GODY It's like a new concept, and they're 15 just getting into it, yes.
16 CHAIRMAN ZECH: That's what I mean, and there're 17 not too many of them getting into that, is that what 18 you're saying?
19 MR. GODY: Half of them have programs that we've 20 locked at. It's a little early to decide, but it is new.
21 so --
22 CHAIRMAN ZECH: All right. Well, I'm sorry 23 Commissioner Carr is not here today because I know he has .
p ., 24 a particular interest in this subject, but I'm sure his
~~
25 staff will brief him on it, and ha'11 read the transcript, (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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65 1 too. I know he has a keen interest in the subject of 2 maintenance. Also, I think he shares my view about the 3 importance of balance-of plant as it impacts on safety 4 and, to me, that is our responsibility.
5 I think that you can look at some of the 6 significant events we've had, not only the Salem event 7 which was mentioned earlier, but other events that 8 certainly indicate that maintenance certainly could well 9 have been a key contributor to a significant problem. So, 10 whether it's in the balance-of plant or the primary plant 11 itself, the steam supply system, it seems to me that 12 maintenance is a safety factor that should be our 13 business.
14 As far as quantifying management efforts. it's 15 always very difficult to do that, but it seems to me you 16 can at least look at the number of resources, that is 17 people, how many mruntenance people are involved; what 18 quality are they; what training do they have; what 19 background do they have; also, are they site people i
20 employed by the facility, or are they contractors; what l 4
j 21 percent is contractors; what percent is -- you know, not )
1 l
22 that contractors can't do an excellent job in maintenance, 1 23 but what kind of a commitment does the facility have? -
24 Those are things you can quantify, I think. l
(" 25 Also, the maintenance facilities at the site,
- I 1
1 l
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- 1 how much maintenance can they do at the site? 1 i !
L_ 2 you can do a fair amount. I've found others don't do j 1
3 much. They have to send most of it out somewhere. And, 4 also, you can quantify the training facilities. Do they 5 have good training facilities? Some of them have very 6 fine training facilities. Others don't have as good as 7 perhaps they should.
8 Those are things you can look at, and I think 9 those are real indicators of how at least'to attempt to 10 quantify management efforts towards supporting maintenance 11 but, as far as I'm concerned, maintenance has a 12 significant contribution to safety of plant operations and 13 should be a continuing program that we view very L ._
la carefully, and I would hope that the industry continues 15 their improvements and their emphasis on maintenance, 16 which I think we've all seen in recent months and years.
17 Well, let me thank you all for a very fine 18 discussion here today. This maintenance team inspection
. 19 effort that we're undertaking is a very important one. I 20 know you've only looked at, I guess, roughly something i
21 ?v '0; percent of the plants, but still that's a pretty 22 good indication.
I i
23 You have identified some areas that need -
1 1
24 attention. Are you going to continue these inspections?
L.A Yes, sir.
25 MR. MIRAGLIA:
l (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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- 1 MR. GODY: Yes, sir.
2 CHAIRMAN ZECH: You didn't emphasize that today.
3 Do you intend to inspect all the plants?
4 MR. MIRAGLIA: Yes, sir, this fiscal year and 5 next fiscal year we hope to --
6 CHAIRMAN ZECH: Finish when?
7 MR. MIRAGLIA: Yes, sir.
8 MR. GODY: Mid FY91.
9 CHAIRMAN ZECH: Mid --
10 MR. MIRAGLIA: Fiscal Year '91.
11 CHAIRMAN ZECH: Fiscal YcTr '91.
12 MR. MIRAGLIA: Yes, sir.
13 CHAIRMAN ZECH: It's a big effort, but I think 14 it's a worthwhile one. Clearly, you're gaining a great 15 deal of experience and knowledge, and I would think, from 16 your visits, the utilities are benefitting also.
17 I think the attention, again, that you're 18 placing on it, we're placing on it, and the utilities and 19 the industry across-the-board is placing on maintenance is 20 very appropriate and important.
21 I'd certainly continue to keep up this I
- j 22 inspection program and, Mr. Taylor, I '< n o w you and the ]
1 23 senior people will continue the staff's emphasis in the .
24 area of maintenance.
{
25 Are there any othnr questions from my fellow !
1
- l (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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ll- 68 1 Commissioners?
1 L . 2 (No response.) .
3 If not, thank you very much.
4 Ue stand adjourned.
5 '( W h e r e u p o n , at 3:23 p.m., the m*eting was 1 6 adjourned.)
7 8
9 10 11 12 13 L __
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1 21 22 23 .
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I. _. _ .-_.---._-_________-___________---_-__-__-__J:_:---____-_.__._-__ a
CERTIFICAT$ OF TRANSCRI'BER This is to certify that the attached events of a meeting of the United States Nuclear Regulatory, Commission entitled:
TITLE OF MEETING: BRIEFING ON RESULTS OF MAINTENANCE TEAM INSPECTIONS PLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING: MAY 2, 1989 were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
SY Wncp a y a Reporter's name: PHYLLIS YOUNG l-l 1
l 1
i l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RNOOf ISbAND AVENUE, N.W.
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FROM:
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