ML20211K058

Recommends That Commission Develop Policy Statement on Maint Program

ML20211K058
Person / Time
Issue date:	10/27/1986
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20209H803	List: IA-86-864, Recommends That Commission Develop Policy Statement on Maint Program ML20209H797 ML20209H839 ML20209H912 ML20210U813 ML20211K058
References
FOIA-86-864, TASK-PINV, TASK-SE SECY-86-316, NUDOCS 8611140269
Download: ML20211K058 (21)

Text

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POLICY ISSUE October 27, 1986 SECY-86-316 For: The Concissioners Frcm: Victor Stello, Jr.

Executive Director for Operations

Subject:

PAINTENANCE POLICY STATEMENT

Purpose:

To obtain Comission direction on development of a Policy Statement on Maintenance.

Background:

In 1985, the staff developed the Maintenance and Surveillance Program Plan (MSPP) and informed the Commission (SECY-85-129) of the objectives of the program, the technical and regulatory issues concerning maintenance, ano the proposed course of action. A phased approach was selected: Phase I, " Survey and Evaluation," was to describe the current status of maintenance in the industry by surveying existing maintenance practices and assessing their effectiveness.

Phase I was started in May 1985 and completed in May 1986.

The findings are published in the report " Status of Maintenance in the U.S. Nuclear Power Industry,1985" (NUREG-1212, Vols. 1 and 2). A copy of Volume 1 of that report is included as Enclosure 1.

Discussion: The staff has concludec that inadequate maintenance at some plants is a significant contributor to plant and system reliability problems and, thus, is of safety concern. The staff also found that there is substantial variability in maintenance programs, practices and effectiveness between utilities.

During Phase I, the staff has exchanged information on maintenance programs and practices with INP0 and NUMARC and has assessed the potential for industry's maintenance initiatives to improve maintenance performance.

Contact:

W. T. Russell, NRR 49-24803 Resnwe169xA <1 1

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These industry maintenance initiatives are described in NUMARC's letter to the EDC dated October 6, 1986 (Enclosure 2). They include:

Development and issuance of INPO 85-038, " Guidelines for the Conduct of Maintenance at Nuclear Power Staticns (Preliminary)."

Maintenance self-assessments using the INPO guidelines (pilotprogram).

Extension of the Peer Evaluator Program to maintenance.

Increased use of NPRDS.

Expanded use of INP0's Human Performance Evaluation System.

INP0 maintenance workshops.

Improved Maintenance Training through Accreditation.

Development of industry performance indicators (both overall and maintenance plant performance indicators).

It is the staff's opinion that the industry initiatives in general, and the INPO Maintenance Guidelines in particular, ha/e the potential to improve plant maintenance, if implemented on a consistent basis. However, there is no industry consensus, such as exists in the training area, to implement these programs on an industry-wide basis.

The staff believes a Commission Policy Statement on Maintenance (similar to those on Training and Qualifications and Fitness for Duty) is needed to (1) specify the l

Commission's long-term goals for nuclear plant maintenance programs, (2) specify the industry self-improvement initiatives which are being recognized, (3) articulate the respective NRC and industry roles in implementation of industry's maintenance improvement initiatives, and (4) specify the means of NRC oversight. The Policy Statement would indicate that to the extent the industry self-improvement initiatives are effective and implemented l

consistently on an industry-wide basis, the NRC would defer i development of new maintenance requirements.

The basic principles of such a Policy Statement were discussed during an August 15, 1986, meeting between the NRC

! staff and NUPARC. At that time, NUMARC did not agree with

the need for a Policy Statement. NUMARC's recent letter to the ED0 also questions the need fcr a Policy Statement. It is their opinion that maintenance is an integral part of overall plant operations and that their current efforts regarding performance indicators and industry performance goals are sufficient to improve maintenance performance.

The staff feels that an industry commitment and Maintenance Policy Statement delineating industry's comitment is essential.

In parallel with MSPP Phase II activities, the NRC will continue inspection activities with resources focused upon plants with poor maintenance performance and, if needed, will require plant-specific maintenance program improvements in accordance with existing NRC policies anc procedures concerning new requirements.

Recomendation: That the Commission:

1. Direct the staff to prepare and su'mit o a proposed NRC Policy Statement on Maintenance.

2. Note the FD0 has directed NRR and IE to implement PEise II of the Maintenance and Surveillance Program as it relates to assessing the effectiveness of industry's recent maintenance initiatives.

l gQy J.

We Stello, J Executive Director for Operations

Enclosures:

1. NUREG-1212 Vol. 1 (Commissioners, SECY, 0GC only)

2. NUMARC letter of October 6, 1986, from W. Owen to V. Stello

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-4 Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Wednesday, November 12, 1986.

Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Wednesday, November 5, 1986, with an information copy to the Of fice of the Secretary. If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

DISTRIBUTION:

Commissioners OGC (H Street)

OI OCA CIA OPA REGIONAL OFFICES EDO

, OGC (MNBB)

ACRS ASLBP ASLAP l SECY

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Acanta, ca. 20339 4 g Enclosure 2 PO. Box 33189

, Charlotte. N.C. 28242 NUCLEAR UT11JTY MANAGEMENT AND RESOURCES COMMITTEE October 6, 1986 Mr. Victor Stello, Jr.

Executive Director for Operations U. S. Nuclear Regulatory Comission Washington, D. C. 20555

Dear MNo:

This letter provides coments on the Maintenance and Surveillance Program Plan (MSPP) Phase I report and the draft schedule of MSPR Phase 11 projecti, dated ~Augu5i 12, 1986. The NUMARC Maintenance Working Group has reviewed these documents, and has recently interacted with menters of your staff (August 15,1986). Specific coments on the MSPP documents are provided in attachments 1 and 2 for your consideration. Additionally, and at Bill Russell's request, attachment 3 provides an update of some of the industry initiatives and activities as originally reflected in the MSPP section 3.4.

As expressed in our previous correspondence in Noventer 1984, January 1985, and March 1985, we remain concerned with the overall direction and thrust of the MSPP. We believe the documents project a perception of maintenance in the industry that is too negative with respect to current industry initiatives and progress. Additionally, the need, intent, and purpose of a Comission policy statement on maintenance is not clear.

We have been pleased with the positive interactions between the NRC staff and NUMARC during the past two years and believe both organizations, and the industry as a whole, have benefited overall in the maintenance l

area. Please call me or Jim Miller, if you have any questions related to this matter.

Sincerely, l

l W. H. Owen Vice Chairman NUMARC Steering Comittee

WH0/jw l

Attachments cc: H. R. Denton W. T. Russell Z. T. Pate C. O. Woody EDO ~ g022g3

IAGELCCU W. H. Owen, Jr.

NUMARC L2tter of 10/6/86 NUMARC COMMENTS ON.THE SCHEDULE OF MSPP PHASE II PROJECT (DRAFT)

(DatedAugust 12, 1986)

This attachment follows the sequence of and provides coments on sections of the subject document.

Paragraph 2 - @jective The lead in sentence states in part, " Develop recomendations for good practices." We welcome any suggestions that identify areas in which good practices might be developed. We feel that the actual writing and publication of good practices is best done by the industry using the existing INP0 processes in order to avoid duplicating efforts that could cause actual or perceived conflicting direction to the nuclear power plants.

Subparagraph one in part states, " Improve the development and use of measures of plant maintenance performance." As you know NUMARC has been working with INP0 to develop a valid set of indicators that measure maintenance performance. We are currently collecting data on ten maintenance indicators that are being used as tools by utility maintenance management.

However, we believe that the broad area of maintenance cannot be measured in isolation; rather it is best measured by viewing overall plant performance and by using the associated overall plant performance indicators and long-term goals currently being developed and used by the industry under the auspices of INPO. It is recomended that the NRC staff continue to coordinate the NRR maintenance indicator effort with the overall plant performance indicators currently being developed and continue to work closely with INP0 and the industry in order to use information that is i consistent.

Subsection 3 states in part, " Define maintenance needs, including the role of preventive maintenance." NUMARC encourages NRC staff participation with the industry in order to better identify valid and priority areas for improvement. In this regard, NUMARC has and will continue to conduct information exchange meetings with the NRC staff.

Subsection 4 states, " Define goals for nuclear power plant reliability l that fosters management involvement in ensuring effective maintenance, I including the use of performance measures and incentives." It is believed that the industry as a whole and individual utilities are in a better position to establish appropriate goals. As stated above, the industry under the auspices of INPO is currently doing this. Therefore, it is requested that the NRC staff work closely with INP0 in this area to avoid conflicting signals to the industry.

W. 03. Owen NUMARC Letter of 10/6/86 Subsection 5 states in part, " Develop and implement performance oriented maintenance criteria and standards." The NRC staff's intended purpose in developing and implementing performance oriented maintenance criteria and standards is not clear. INPO has already developed and implemented performance oriented maintenance performance objectives and criteria that are used for plant and corporate evaluations. In addition, INP0 has published a preliminary document entitled, " Guidelines for the Conduct of Maintenance at Nuclear Power Stations," INP0 85038, that elaborates on the performance objectives and criteria used by the industry in our pursuit of excellence. We believe, by these and other industry efforts, that the industry performance is improving and will continue to improve. Duplication of these efforts by the NRC staff does not appear to be warranted and could be counterproductive. Of course, NRC comments on these industry efforts are welcomed.

Subsection 6 states in part, " Identify approaches to maintenance which enhance the interface between maintenance and operations." NUMARC welcomes NRC staff review of this area and suggestions resulting from such a review. The NRC staff should recognize that the industry and each utility work on the maintenance and operations interface on a daily basis. The operations-maintenance interface is part of the many faceted area of team work which receives attention at each utility. We also work on this as an industry. For example, the Septent>er 1986 INP0 Operations Superintendent Workshop included 24 Maintenance Superintendents as participants.

The theme of the workshop was improving the operations-maintenance interface.

Additionally, operations-maintenance coordination is an integral part of the INP0 evaluation process; findings are made when warranted.

Subsection 7 states, " Coordinate NRC and industry initiatives related to maintenance." We consider this a worthwhile effort and look forward to continuing cooperation with the NRC staff in the area of maintenance.

Paragraph 3 - Maintenance and Surveillance Program Phase II Projects We offer only one coment on this paragraph since the projects listed are dependent upon the objectives and issues discussed above.

Project 6. " Prepare Comission Policy Statement on Maintenance,"

is not clear as to what would be accomplished at this point in time.

We have discussed this with the NRC staff and asked that the objectives '

of such a policy statement be provided to us. Additionally, there are no agreed upon measures that can be used to determine that desired results are to be achieved in the area of maintenance. We believe that from the NRC perspective, these measures should be based on an established relationship between maintenance and safety. From the utility perspective, safe and reliable plant operation on a cost-effective basis should be considered.

Maintenance as defined in the MSPP is a very broad area. In fact, maintenance activities are conservatively estimated to encompass over 70 percent of the activities in the plant that offer an opportunity for error. We believe that maintenance can not be isolated from the overall operations of a nuclear power plant. Accordingly, the industry's overall plant performance indicators and the challenging goals set by the industry for 1990 are providing us focus and direction in maintenance.

ATTACHMENT 1 W. H. Owen NUMARC Lsttar of 10/6/86 It is recommended that further dialogue between the NRC and NUMARC take place to discuss and resolve the need for a policy statement.

Paragraph 5 - Milestones We offer only one comment on this paragraph. Maintenance, as being broadly defined by the MSPP, encompasses many areas and people, and should be accorded incremental milestones with long-term objectives beyond the three years shown in the MSPP Phase I and II milestones. However, we agree that it is appropriate to monitor progress and to expect improvement during this time frame.

NUMARC Lettsr of 10/6/86 I

MSPP PHASE I REPORT (NUREG-1212 Volumes 1 and 2) l The following general coments are provided based on a review of the subject report by the NUMARC Maintenance Working Group and interactions  ;

with the NRC staff: )

o The Eisenhut to Stello forwarding memorandum dated May 16, 1986 and the subject documents tend to project a generic image of maintenance in the industry that we feel is too negative.

o Some of the coments in the subject documents conflict directly with existing industry programs and initiatives, could cause confusion to the utilities, and could be counterproductive to nuclear power in the United States.

o The objectives in Volume 1 appear to have a bias toward developing maintenance rules.and regulations.

Since the subject report has been issued as final documents and has been presented to various groups, we consider it inappropriate to provide extensive coments. However, we would like to offer coments on several selected findings and conclusions to provide examples as to the basis for the overall coments provided above.

In section 2.1 the statement is made, " Radiological Exposure. Personnel exposure levels (total and maintenance-related) remained stable between 1980 and 1984 according to NUREG-0713, ' Occupational Radiation Exposure '

at Comercial Nuclear Power Reactors.' The only significant and consistent pattern noted was that BWRs have approximately doubled the mean exposure level as those experienced by PhRs. Maintenance-related radiological

exposures represent about 46 percent of the total exposures." Section l

3.5 states, "The major portion of occupational radiation exposure and many radiological hazards occur to personnel perfonning maintenance activities."

We believe that the above statements are misleading. Addendum 1 to this attachment, " Performance Indicators for the U.S. Nuclear Utility Industry," was distributed by INPO in June 1986 and shows that collective radiation exposure per unit has a decreasing trend. We believe this more accurately represents actual performance in the industry. Furthermore, to state that maintenance-related radiological exposures represent about 46 percent of the total exposures without providing amplification can be misleading. Taken in the broad context defined in the MSPP, maintenance activities should be expected to represent the majority of the radiation exposure experienced in our industry. Therefore, maintenance activities represent the greatest opportunity to reduce radiation exposure in our industry. Recognizing this, maintenance has been a focal point in our industry exposure reduction efforts with results reflected in the performance shown in the addendum 1 to this attachment.

. ATTACHMENT 2 W. H. Owen NUMARC Lett:r of 10/6/86 In section 2.2 under the paragraph which leads in with "Other major findings based on the resident inspector's responses," the statement is made that "There are no formal predictive maintenance programs at one-fourth of the sites . . ." This statement appears to be misleading which may be caused by the term " formal," and the understanding of the meaning of formal. The data provided in attachment 3 to this letter shows that considerable predictive maintenance is being used by the industry.

We believe that predictive maintenance is a growing aspect of preventive maintenance in our power plants.

Also in section 2.2, the statement is made, "The maintenance staff at a majority (70 percent) of the plants spend one-fourth or less of their time on preventive maintenance tasks." We believe that the perception provided in this statement is misleading. Using the broad definition of maintenance in the MSPP, preventive maintenance includes many activities such as technical specification surveillances, other surveillance activities, operator preventive maintenance activities, performance monitoring, etc.,

in addition to the preventive maintenance activities performed by maintenance craftsmen. As an industry we are endeavoring to better quantify this data in order to reflect an accurate picture. Data provided to INP0 by 33 stations, which use man-hours as the measuring basis, indicates that the median ratio of preventive to total maintenance for the industry is about 30 percent. The best quartile value is about 44 percent for the 33 stations that were able to provide this data. The industry has not established an optimum preventive to total maintenance ratio that ensures plant safety and reliability on a cost effective basis. We are continuing to pursue this important area.

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Addendum 1 to Attachment 2

W. H. Owen l MUMARCletter of 10/6/86 g, ,t JUXE 1986 Nuciear Pow Periormance Indicators for the US. Nuclear Utility Industry

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ATTACHMENT 3

, W H. Owen NUMARC Letter of 10/6/86 UPDATE TO MSPP SECTION 3.4 (Interactions With Outside Organizations)

Nuclear Utility Management and Resources Connittee (NUMARC) and INPO The following new activities are provided for your information and use.

a. NUMARC contributed to the development and subsequent issuance of INPO 85-038, " Guidelines for the Conduct of Maintenance at Nuclear Power Stations (Preliminary)," and INP0 85-026, " Writing Guideline for Maintenance, Test and Calibration Procedures (Preliminary)," both of which are currently being applied by the nuclear utilities.

b. Several utilities have volunteered and are conducting pilot self-assessments using the maintenance guideline referred to above in order to determine the worth and techniques for conducting such a self-assessment.

c. NUMARC conducted a survey of predictive maintenance activities that, based on the information provided by 74 responding plants, i indicates predictive maintenance is a growing aspect of preventive

! maintenance at the nuclear utilities. Addendum 1 to this attachment l provides information on this matter.

d. Nuclear utilities are fully supporting the Maintenance Peer Evaluator Program (analogous to the SR0 Peer Evaluator Program), that was implemented by INPO in May 1986.

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e. Considerable inter-utility interactions to provide technology transfer is occurring both nationally and interr.ationally between individual utilities and through the INPO processes.

f. Utilities are beginning to increase their use of NPRDS now that the engineering data base exists and failure reporting data history is increasing (e.g., the nu2er of on-line data searches by utilities

, has more than doubled in the past two years).

g. Utilities are voluntarily establishing programs and becoming participants in the INP0 initiated Human Performance Evaluation System which is aimed at focusing upon and helping to resolve human performance issues. Currently there are 15 U.S. and 2 international utilities participating in this program. The participating U.S. utilities represent 33 nuclear units, with 5 more planning to participate in 1986 and others in 1987.

h. Maintenance training accreditation continues on schedule with the objective of 183 craft programs et 61 plants ready for accreditation by Deced er 31, 1986. As of Septentier 17, 29 maintenance craft programs are accredited and 143 more have self-evaluation reports

ATTACHMENT 3 W. H. Owen

. N'JMARC Litt2r of 10/6/86 submitted. In addition, several NT0L plants are pursuing maintenance craft accreditation ahead of the accreditation program schedule.

Seven NTOL maintenance craft programs are accredited and 17 more self-evaluation reports submitted.

1. The industry has and is establishing overall plant performance indicators and long range goals, and is providing associated supporting data to INP0 in order to provide measurable indicators of performance for the industry.

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'C 1 *2 W. H. Owen NUMARC Letter of 10/6/86 April 4, 1986 TO: NUMARC EXECUTIVE GROUP MEMBERS Gentlemen:

On February 7,1986, a survey of predictive maintenance activities was requested from each NUMARC Executive Group member to obtain information to be used during the NUMARC briefing of the NRC Commissioners on February 26, 1986.

This letter provides generic results of that survey for your infomation.

Based on the information provided by the 74 plants that responded, the following are highlights of predictive maintenance programs that are being used:

o 99% of the plants have implemented a vibration monitoring program, making this the most widely used predictive maintenance tool. Most of these programs monitor balance of plant (965) as well as safety-related systems (100%), and the results are generally trended (93%).

o 96% of the plants have implemented programs that monitor equipment lubricating oil for quality and for wear particles. Again, most plants apply these programs to balance of plant (80%) as well as safety-related components (93%) with the results trended (695).

o 88% of the plants have programs to monitor bearing temperature.

o 59% have implemented motor-operated valve dynamic testing (and many others stated they will have this program in the near future).

o 54% have started infrared thermal monitoring. .

o 455 have acoustic monitoring programs.

o 23% have adopted radio-frequency monitoring of the main generator.

In addition to these programs, 48% of the plants have other programs that I

they have implemented that were not addressed on the survey form, such as condenser air in-leakage, electrical insulation checks, heat exchanger and equipment perfomance monitoring, and periodic testing of breaker response time.

Enclosure 1 provides the numerical responses to the survey fom (Attachment

A) and a breakdown in bar chart form (Attachment S) showing the usage of each l type of predictive maintenance. In addition, copies of your survey responses are enclosed for your convenience.

If you have any questions relating to the survey, please call Joe Colvin (404-980-3218).

Yours truly, l

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Chairman l Enclosures l

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- Enclosure 1 PREDICTIVE MAINTENANCE SURVEY RESULTS Each utility provided NUMARC with data concerning which forms of predictive maintenance their stations have implemented, what major systems and equipment are included, and how the results of the various predictive maintenance progra are used. Generic results are depicted in Attachments A and B to this paper, .

t your plant (s) data is provided as a separate enclosure.

The eight programs that were specifically addressed were:

o Vibration Monitoring o Acoustic Emission Monitoring o Radio-frequency Monitoring o Bearing Temperature Monitoring o Thermography / Infrared Thermal Monitoring o Motor-operated Valve Dynamic Current / Voltage Testing g o Oil Monitoring (wear particle analysis) o 011 Monitoring (oil quality analysis)

The following is based on information received from 74 plants:

o 99% of the plants have implemented a vibration monitoring program, making this the most widely used predictive maintenance tool. Most of these programs monitor balance of plant (96%) as well as safety-related systems (100%), and the results are generally trended (93%).

o 96% of the plants have implemented programs that monitor eq'.:f pment lubricat.ing oil for quality and for wear particles. Again, most plants apply these programs to balance of plant (80%) as well as safety-related components (93%) with the results trended (69%).

o 88% of the plants have programs to monitor bearing temperature.

o 59% have implemented motor-operated valve dynamic testing (and many others stated they will have this program in the near future),

o 54% have started infrared thermal monitoring.

o 45% have acoustic monitoring programs.

o 23% have adopted radio-frequency monitoring of the main generator.

In addition to these programs, almost half (48%) of the plants have other programs that they have implemented; some of these are:

o Condenser Air In-leakage Monitoring o Electrical Insulation Checks o Heat Exchanger and Equipment Performance Monitoring o Periodic Testing of Breaker Trip Response Time As you can see, the majority of our plants have implemented, to some degree, multiple predictive maintenance programs to detect equipment degradation by various methods. Using these programs, our industry is getting better at anticipating equipment problems to take correcti <e action prior to failure.

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Attachmen:

INDUSTRY PREDICTIVE MAINTENANCE ACTIVITY INFORMATION FOR NUMARC UTILITY GENERIC RESULTS PLANT Check the predictive maintenance techniques and follow-up actions being used at each nuclear station. If information is identical at all stations, one sheet and a footnote t::

this effect are sufficient. If remarks are appropriate, please use back of this page or an additional page.

If Yes Check Ramaining Blocks As Applicable No Yes Used on used on Used on Results 'Results Safety-Related Turbine Balance of Used for Trended Equipment Generator Plant Equip. Planned Other than Maint-Turbine Gen. enance*

73 73 68 70 69 A. Vibration Monitoring 68 7T g 3 3 g g B. Acoustic Emission 33 Monitoring 31 4 6 15 9 7T g g g g g C. Radio-Frequency 16 Monitoring g 2 15 1 8 5 g g g g g D. Searing Temperature Monitoring 65 59 61 53 56 36 g g g g g g E. Thermography / Infrared 41 Thermal Monitoring 34 14 30 30 12 77 g -g g g g F. Motor Operated Valve 46 Dynamic Current / 43 6 32 33 25 voltage Testing 7T g g g g g G. Oil Monitoring (Wear 70 63 ParticleAnalysis) 62 54 59 48 77 g M M M M H. Oil Monitoring (011 70 67 Quality Analysis) 69 59 60 48 77 g g g g g I. Other (State Type- 35 briefly) 33 24 30 32 28 7T 3 g 3 3 g

• For this survey, planned maintenance activities are those performed prior to equipment failure that were initiated by predictive maintenance results.

Plant / Utility

Contact:

Phone No:

Please complete the survey and return it using ovarnight mail to Joe Colvin, INPO, 1100 Circio 75 Parkway Suite 1500 Atlanta, Ga., 30339 as soon as possible, but no later than February 18, 1986. If desired, the survey results can be telecopied to Joe Colvin at IMPO (telecopy neber 404-953-7549). If additional information is needed, call INP0 Maintenance Department (404-953-7645).

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70 70 ypes CMes 70- __ 74 Stations Reporting

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Monitoring D= Bearing Temperature g 50- _ _

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j 45- E= Thermography / Infrared e -

41 Thermal Monitoring M 40~

P= Motor Operated Valve H

35 O

Dynamic Current /

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