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Home > Electronic Reading Room > Document Collections > Commission Documents > Commission Meetings, Slides, Transcripts, Meeting SRMs, and Full Written Explanation for Closed Meetings > 1997
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03/10/1997
1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
- - -
BRIEFING ON IMPLEMENTATION OF MAINTENANCE
RULE, REVISED REGULATORY GUIDE, AND CONSEQUENCES
- - -
PUBLIC MEETING
Nuclear Regulatory Commission
One White Flint North
Rockville, Maryland
Monday, March 10, 1997
The Commission met in open session, pursuant to
notice, at 2:42 p.m., Shirley A. Jackson, Chairman,
presiding.
COMMISSIONERS PRESENT:
SHIRLEY A. JACKSON, Chairman of the Commission
KENNETH C. ROGERS, Commissioner
GRETA J. DICUS, Commissioner
NILS J. DIAZ, Commissioner
EDWARD McGAFFIGAN, JR., Commissioner
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STAFF PRESENT AND PRESENTERS SEATED AT THE COMMISSION TABLE:
JOHN C. HOYLE, Secretary of the Commission
KAREN D. CYR, General Counsel
JOE CALLAN, EDO
ASHOK THADANI, Associate Director for Inspection &
Technical Assessment, NRR
JEFFREY SHACKELFORD, Senior Reactor Analyst, PRA
Branch
SAM COLLINS, Director, NRR
SUZANNE BLACK, Chief, Quality Assurance &
Maintenance Branch, NRR
RICHARD CORREIA, Section Chief, NRR
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P R O C E E D I N G S
[2:42 p.m.]
CHAIRMAN JACKSON: Good afternoon, ladies and
gentlemen. We are pleased to have the NRC Staff here this
afternoon to brief the Commission on the maintenance rule
implementation.
But before we begin, I'd like to ask for a moment
of silence for Nelson Sievering. About two hours ago, this
good friend and outstanding public servant, his funeral was
held in Chevy Chase a few miles from here.
Now, many of you knew Nelson Sievering who served
in many important positions with the United States
Government in the nuclear field. Most recently, he was our
governor to the IAEA. He served for many years at the IAEA
as Deputy Director General for Management.
His career began, like many of you, in the NRC in
the nuclear Navy, but he soon used his impressive technical
skills to advance vital United States policy objectives in
non-proliferation and the peaceful uses of nuclear energy,
first in Brussels and later with the State Department in
Washington.
I would like to salute Nelson Sievering for his
tremendous contribution to nuclear affairs. He fought a
courageous battle against the cancer which eventually took
his life this past Thursday morning.
. 4
I had an opportunity in my short tenure at NRC to
in fact interface with Nelson on a number of IAEA issues,
and we will all miss a true gentleman and nuclear statesman
of the highest caliber.
So I would like you, before we begin, to join me
in a moment of silence in recognition of Nelson Sievering.
[A moment of silence was observed.]
CHAIRMAN JACKSON: Thank you.
As you know, the maintenance rule was issued
because the Commission believed that proper maintenance is
essential to plant safety, and that there was a clear link
between effective maintenance and safety as it relates to
the number of transients and challenges of the safety
system. The rule became effective in July of 1996.
During this meeting, the Staff will discuss the
status and the results of maintenance rule implementation to
date, the changes to regulatory guide 1.160, and any
implications that these changes have on future maintenance
rule implementation activities.
Copies of the slide presentation are available at
the entrances to the meeting and also available are copies
of SECY 97-055, Maintenance Rule Status Results, and Lessons
Learned, which contains a copy of regulatory guide 1.160,
Revision 2.
And so, unless my fellow commissioners have any
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introductory comments, Mr. Callan, please proceed.
MR. CALLAN: Good afternoon. With me today at the
table are Sam Collins, the Director of the Office of Nuclear
Reactor Regulation, on my right; and on my left is Ashok
Thadani, the Associate Director of Technical Assessment in
NRR.
To Sam's right, Suzanne Black, the Chief of the
Quality Assurance and Maintenance Branch in NRR; to her
right, Richard Correia, the Chief of the Reliability and
Maintenance Section in Suzie's branch; and then at Ashok's
left, Jeff Shackelford, a senior reactor analyst in the
Probabilistic Safety Assessment Branch. And just as an
aside, Jeff will be heading to Region IV next week. One of
my last official acts in Region IV was to recruit him.
CHAIRMAN JACKSON: It was only fair.
MR. CALLAN: It was only fair. Region IV comes
out ahead in that trade.
CHAIRMAN JACKSON: By the way, I would like to
welcome Mr. Collins in his first appearance before the
Commission as Director of NRR.
MR. COLLINS: Thank you.
CHAIRMAN JACKSON: And I didn't get a chance to
say that kind of thing to you. You even have a real
nameplate. So welcome.
MR. CALLAN: Sam and I are used to sitting next to
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each other.
We last briefed the Commission on the maintenance
rule status almost two years ago on July 26th, 1995. At
that time, we had completed our pilot inspection program and
issued the Lessons Learned in new reg 1526.
We were also finalizing a revision to the
maintenance rule inspection procedure and were about to
begin training inspectors on the rule in preparation for the
July 10th, 1996 effective date.
Our presentation this afternoon is on the status
of the Staff's activities regarding the maintenance rule and
the results and lessons learned from our inspection efforts
to date.
And now, I'll turn the presentation over to Mr.
Thadani.
MR. THADANI: Thank you. Good afternoon. May I
have viewgraph number 2, please?
[Slide.]
MR. THADANI: Our intention is to cover some of
the background and rule requirements specifically, results
of the activities that we have been involved in since the
last Commission brief, and implications of -- at least our
understanding of what the implications might be of
performance-based rules, how it might impact some other
considerations. We will catch up on some of the issues that
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develop as a result of our actions.
And then finally, we will summarize our future
actions to complete the inspections.
May I have the next viewgraph, please?
[Slide.]
MR. THADANI: I thought I'd make just a few
general remarks, and then the presentation by Susan Black
and Richard Correia will provide additional information and
more details.
The Chairman noted the need for the rule and some
of the reasons that led to development of the maintenance
rule, so I will not repeat that.
Our thinking over the years has clearly evolved as
to what kind of rules one should be writing. Some of the
attributes that are very important, will the rule be clear,
that it can be and should be consistently implemented, the
requirements and meeting those requirements be inspectable,
that the rule include consideration of risk information and
be performance based.
A lot of attributes one would like to look for.
That's quite a challenge, as we're finding out, to insure
that these attributes are being satisfied by a given rule.
In fact, the maintenance rule is one of the first
risk-informed and performance-based regulations. As you
know, most of our recent regulations have been risk-
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informed. 50.62 is anticipated transients without scram, is
clearly based on a fair amount of risk analysis done by the
Staff, and the requirements are deterministic and fairly
proscriptive, but those requirements are, in fact, based on
considerations of risk.
50.63 is station blackout. Once again, a similar
approach was followed. Because there has been considerable
interest in the subject matter of the importance of safety,
and safety related, I will note that for these regulations,
the Staff clearly indicated that non-safety-related
components would be acceptable but the focus was on
reliability and availability. So these areas were laid out
in regulatory guides in terms of what would be acceptable to
meet these regulations.
As far as the maintenance rule is concerned, risk
information is used in a number of ways. First, since each
plant has done an individual plant examination based on the
inspections we have done to date, each licensee has in fact
utilized this IPE, although that is not required by the
rule. But that is the practice and that was the
encouragement provided both in NUMARC's document as well as
our regulatory guide.
Areas where they have used the IPE was, first of
all, to try to understand what structures, systems, and
components have higher safety significance and which ones
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have lower safety significance. And in some cases, if the
licensees choose to establish goals for performance of these
components, those goals could be numerical and, if
numerical, consistent with what was done in the IPE.
The third area that utilizes risk techniques is
assessing impact of removing any equipment out of service
for preventive maintenance. You recall the issue of on-
line maintenance where we were quite concerned about what
some of the practices might be, the need to pay close
attention to configuration control.
Having IPE provides an opportunity for the
licensees to understand impact on risk before taking any
components out for preventive maintenance.
In the fourth area, we are --
CHAIRMAN JACKSON: So let me just ask a question.
This use of IPE in the context of the maintenance rule
implies, then, a high degree of competence on our part in
the use of IPE for identifying systems and within the
configuration and control methodology for on-line
maintenance as opposed to specific numbers?
MR. THADANI: I think in relative terms, that's
exactly right, but I might add, it's more than the IPE
itself. IPE is one input.
The maintenance rule really -- implementation
calls for a panel. First, there's information coming from
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various sources, one of them being the individual plant
examination, and this interdisciplinary group takes a look
at the information and prioritizes it in terms of what is
high safety significance, what is low safety significance,
so it's more than just the use of the IPE in the -- as far
as the implementation is concerned.
CHAIRMAN JACKSON: Mr. Shackelford looks like he
wanted to say something. No?
MR. SHACKELFORD: I can just say that we've seen a
variety of approaches to using IPE, in particular in
assessing equipment out of service for maintenance, and it's
not always quantitative. In the spirit of the risk-based,
performance-based approach, we entertained a number of
approaches and we evaluate them on a case-by-case basis.
MR. THADANI: And the fourth area where risk
information is utilized is in trying to understand the
unavailability due to maintenance at periodic intervals
trying to make sure there's some balance in terms of
availability and reliability of structures, systems, and
components.
So those are areas where the implementation does
rely on risk assessments, at least as one input to those
decisions.
From a performance-based perspective, the
maintenance rule does give a great deal of flexibility to
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the licensees and, in fact, the definition of what is
required can vary from plant to plant because its
flexibility is provided, and I'll give you some examples and
then you'll hear some more details.
And this flexibility does make it challenging for
inspectors to get some assurance that the maintenance rule
is consistently implemented and enforced. This allowed
flexibility leads to differences among plants in many areas.
Differences can be driven by plant-unique design
considerations, different levels in terms of some emergency
operating procedures, as well as perhaps even different
definitions of system boundaries and so on, which leads to
the sense that the scope of the SSCs can be a variable from
plant to plant, and in fact is. Performance criteria can
vary from plant to plant.
If I may use an example, if one is interested in
focusing attention on, say, a pump, an identical pump, high-
pressure safety injection pump or some other in these
plants, performance criterion could be pressure drop across
the pump, could be flow, could be vibration or some other
indicator of performance of the pump.
One licensee could choose -- let's use vibration
as an example. One licensee could choose performance
criterion of 5 mills vibration as a trigger point, saying
maybe something's wrong if that vibration level is exceeded
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and taking further actions.
Another licensee may use 7 mills as a trigger
point, as a performance criterion. Both of them are
perfectly okay depending on the pump performance, and the
pump can very likely perform its function even beyond a
vibration level of 7 mills, but there are differences.
As a result of these differences, the inspectors
need to really understand what is the fundamental reason for
looking at that component, and that takes additional effort
by and large.
This was recognized up front, and because of that,
we have really expended significant resources up front in
the development of the guidance documents.
When we have a performance-based regulation, the
intent -- at least one element of that certainly is to give
licensees flexibility. It is very important to get up front
the industry input in terms of guidance, criteria,
understanding of criteria and so on. It does become
somewhat of an iterative process, and it was, indeed, very
important to allow a fairly long time period for these
interactions to take place. Naturally, this iterative
process also means expenditure of higher resources.
The training of inspectors becomes absolutely
essential and we'll come back and touch on what we mean by
that.
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In order to make sure there is consistency in the
early inspections, we make sure that there is -- all the
regions were participating in the inspection.
We have also a panel at NRR. Every time there are
issues coming up, the panel evaluates these issues and makes
decisions in terms of what enforcement actions, if any, are
to be pursued. This is, again, to make sure that issues are
being looked at in a consistent manner.
To be able to do these things, it's clear that we
have to expend significant resources and we have spent a lot
of resources on the maintenance rule.
CHAIRMAN JACKSON: I think Commissioner McGaffigan
has a question.
COMMISSIONER McGAFFIGAN: I just want to break in
at some point. At the very outset, you talked about the
ideal rule, clear, consistently implemented, inspectable and
enforceable, risk-informed, performance-based.
You've talked about the risk-informed aspects of
this rule and the performance-based aspects of this rule so
far, but the paper also goes in to point out that there is
also -- this is less than a pure risk-informed rule, because
of the term risk-informed, the PRA implementation plan
followed four years later, and so there are elements that
aren't risk-informed.
And then on the performance-based, there's a lot
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of deterministic/proscriptive elements to the rule, and
there obviously are tradeoffs. If we're headed -- if this
is the goal, there are tradeoffs that one faces among these
various items. Resources, you've just been mentioning.
Performance-based rules, at least this one has been very,
very resource intensive.
What advice do you have to the Commission with
regard to balancing these various things, and should we
recognize that it's a spectrum, that there's no -- we have
to tailor it to each circumstance?
MR. THADANI: I think, broadly speaking, this
approach is quite reasonable to go forward if we recognize
that, until we get a lot of experience, there may be some
return down in later years. Having gone through this
intensive interaction up front, these intensive -- these
inspections are programmatic inspections. These are not
performance-based inspections.
So I think we have to wait and see, are there
other issues that are going to develop. Once we truly get
into inspections for cause, that is, performance criteria
are established, and our intention is not to get involved
unless the performance criteria are tripped, some trigger
initiates NRC involvement, that there may be a problem.
COMMISSIONER McGAFFIGAN: But you have to get
somewhat proscriptive. You're going through this level of
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inspections now, and I don't want to preempt the whole
briefing, but you're going through this level of inspection
now, which is somewhat prescriptive or programmatic, in
order to establish a baseline from which you can then judge
later and hopefully get some resource benefits, both to the
Commission and to the licensee, but we're not there and we
won't be there for some time.
MR. THADANI: I think it will be difficult to
predict. We need some experience to see how it comes out,
what kinds of problems we run into at a future date.
But you are quite right. Some elements ultimately
will end up being proscriptive. And again, let me use an
again.
I indicated that the performance criteria could be
probabilistic, numerical, or deterministic, like I used the
flows, vibration level.
Now, it's very difficult if one is looking for an
unreliability of, let's say, failure of 1 in 1,000 demands.
One needs a fair amount of data, and data in terms of
challenges, successes to be able to make some estimates of
what the underlying reliability might be.
And in fact, there may be yet another concern.
Can we wait until that component fails before we take
action?
One of the attributes we were looking for was
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early indication of failure so that one does not take action
after a failure has taken place, but rather, degradation is
taking place, to be able to identify some trigger points in
terms of degradation. That necessarily, I think, has to be
deterministic.
So it seems to me that the approach that is being
utilized is a mixed approach, probabilistic in terms of, as
I said, looking to see where one ought to be doing more and
where one ought to be doing less.
In terms of components, structures, and systems
that come up in the most safety significance category, one
could perhaps tolerate failures, but I think in the high
safety significance category, very likely you would have to
have a mixture of the two.
We'll wait and see once we get more experience in
terms of our reaction, industry actions, can they maintain
the performance criteria, how often do they get tripped,
what our involvement will be. I think time will tell how
that plays out.
COMMISSIONER McGAFFIGAN: My only comment is, this
paper, the SECY 97-055 that they're basically briefing on
today, it's very informative for somebody coming to the
Commission as I did six months ago in terms of laying out
the nuances here.
We tend to use risk-informed and performance-
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based all the time, and when you get into the nuances of
actually looking at probably the most risk-informed,
performance-based rule we have, it's -- we're well into gray
areas. We're well into the continuum.
And several pages go through the examples of where
we're being less than pure if we're headed towards a pure
model, which we probably won't because life is not --
doesn't allow us to work --
CHAIRMAN JACKSON: Purity is an ideal.
MR. THADANI: Yeah, it's an ideal.
CHAIRMAN JACKSON: Why don't you go on.
MR. THADANI: But in any case, the 20 inspections
that we have conducted so far, and I want to make sure I
don't overstate this, they indicate that, generally, the
programs that the utilities have in place are adequate.
That's not to say that we haven't found problems.
We've found problems, a range of issues, and we
would come back to one issue that relates to the language in
the rule itself in the -- what we have found in terms of the
industry actions in that area, and we'll talk about, is
there need to revise the regulation proposal, at least for
the Commission to revise the regulation or not, but we'll
come back and indicate to you our thinking at this point.
By and large, I think the language in the rule has
had some impact in terms of licensees having taken that part
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of the rule less seriously than the other parts.
COMMISSIONER McGAFFIGAN: That's the configuration
control part?
MR. THADANI: That's basically the configuration
control on-line maintenance issue where the rule does not
say that the licensee shall have those programs. It says
they should, and so OGC will say it's very difficult to
enforce that part of the rule.
And I might as well note that we did identify --
in fact, Jeff was actively involved -- did identify a number
of concerns, and these concerns have been relayed to the
licensees. They appear to be receptive to those comments.
We intend to go back, take a look to see what's
actually being done and come back to the Commission with a
recommendation subsequent to that once we get all that
information together. We're not prepared at this time to
say we propose changing the regulation, at least at this
time.
Since the last briefing, we have trained, as I
said, a number of other inspectors and other Staff. Total
number of people -- we have three levels of training and
we'll go into that. The number of people we have at least
trained or given them some sense of what the maintenance
rule calls for is 900, and a fairly large number of people
have had fairly thorough training in the maintenance rule
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itself.
We have developed enforcement guidance and
established an enforcement panel. We work with the industry
to revise guidance documents, and, as I said, we have
completed 20 inspections so far.
Suzie Black will cover the rule background and
then Rich Correia has been on every inspection --
MR. CORREIA: Half.
MR. THADANI: Half of them, okay -- most of the
inspections, is going to go through the status and some of
the details.
MS. BLACK: Thank you. As a way of background,
the rule was issued on July 10th, 1991 and it was to take
effect on July 10th, 1996. This was giving two years for
the guidance documents to be issued, as well as three years
for licensees to establish their programs and have them in
place by the effective date of the rule. They were to
gather two cycles of data.
The industry guidance document is NUMARC 93-01.
It was -- it provides one acceptable method of implementing
the rule. Currently, to date, all licensees are using that
method.
Revision 2 was issued in April 1996, and that was
after our pilot program. It included the lessons learned
from our pilot program.
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Regulatory Guide 1.160 endorses 93-01. Revision 2
was just completed a couple weeks ago and is attached to
your Commission paper.
Our Inspection Procedure 62706 provides guidance
for our inspectors for the baseline inspections.
We also have an Inspection Procedure 62707 which
is used by our residents as part of the core program.
This is more what you would call performance-
based inspection procedure. It's used to observe
maintenance activities as well as follow up on events.
Now, the maintenance rule itself, if you use the
guidance in 93-01 to implement it, first what you do is
determine which structure, systems, and components are
within the scope of the rule. I hope you won't mind if I
start saying SSCs because it gets to be quite a tongue
twister after the 15th time.
But anyway, the scope of the maintenance rule is
safety-related structures, systems, and components, as well
as some non-safety-related.
The first category is those that are relied on to
mitigate accidents or transients or used in the emergency
operating procedures. An example of that would be a startup
feedwater pump or perhaps gas turbines.
The second category is those whose failure could
prevent safety-related SSCs from fulfilling their safety
. 21
function. An example would be perhaps instrument error or
heating, ventilating, or air-conditioning systems.
The third category would be those whose failures
could cause a reactor scram or actuation of a safety-related
system, for example, feedwater or circulating water.
CHAIRMAN JACKSON: And that would be an example of
perhaps what would not be in what we call safety related?
MS. BLACK: Right.
CHAIRMAN JACKSON: But it has safety significance
within the scope of this rule?
MS. BLACK: True, because they initiate
transients, and that was one of the purposes of the rule.
CHAIRMAN JACKSON: Right.
Commissioner Diaz.
COMMISSIONER DIAZ: I'm glad to see that the EDO
came with reinforcements this afternoon. I'll go back to my
original point this morning and I'm sure you're ready for it
now.
Let's look at the definition of safety-related
system or components, and I -- you know, I am puzzled. It
is not a complete definition. It essentially excludes all
those SSCs that have no relationship to a design-basis
event.
You can say, which ones are those? Well, we used
to really be very specific in detailing any SSC that was
. 22
part of the fuel, the primary coolant, you know, pressure
boundary, every one of those things that we relied upon to
prevent the consequences of an accident that are outside of
the design basis.
Well, the rule, of course, specifically, I'm
talking about the SSCs that are inside of an envelope of a
design basis and excludes the systems that are used or put
to use or normally used for normal and anticipated
transients, and I'm sorry, but I don't understand it.
There is something in here that is implied in the
word, and I'm sure it was meant to be included, but I don't
see it. And it's not there anymore.
And, you know, you look back at Appendix B, you
look back at whatever you want to, you see, you know,
structure -- SSCs, not repeated, that prevent or mitigate,
and that includes all of the systems. But in this
definition, they're excluded.
We only are dealing with -- the scope of the rule
is dealing exclusively with systems that are inside of the
design basis accident envelope and no other system
structures, and we deal with those that are safety related
and those that are not safety related.
Those that are non-safety related but are required
to function for the function of the safety related are of
course what we used to call safety significant. It's just
. 23
one level below safety related, safety related being one
level below important to safety, and -- but it's out of
there. Where are they? I don't see where these systems
are. I'm sorry.
CHAIRMAN JACKSON: Let me ask a question in this
the generic way. Where is "safety significant" defined for
the purposes of this rule?
MS. BLACK: Well, that goes beyond the scope
issue. Safety significance goes into how you monitor, and
so safety -- once you get the scope of what's under the
rule, then you determine what's safety significant and what
isn't, and that's done by the expert panel that Ashok was
mentioning before.
They do use PRA insights and performance -- or
importance measures that are defined in 93-01, but that --
it doesn't relate back to what's in our "outside of scopes."
COMMISSIONER DIAZ: You know, it's easy to fix.
Now, it might take two years, but all you have got to do is,
when you get into the definition, are relied on to remain
functional during normal operations, anticipated transients,
and following design postulated events to insure the
integrity of the reactor cooler. And those are the kinds of
things we always said, but it doesn't say it.
MR. THADANI: By and large -- I may be getting
into this and regret it later on, but by and large --
. 24
COMMISSIONER DIAZ: I assure you, you will.
MR. THADANI: Safety-related structures, systems,
and components are clearly a subset of what is important to
safety. Those languages appear in different regulations, as
you well know. Appendix B applies to safety-related
structures, systems, and components.
COMMISSIONER DIAZ: I'm sorry. I need to
interrupt you. Appendix B specifically goes and says those
systems to prevent or mitigate, and then it goes and says,
those systems are needed during normal operations,
maintenance.
And this doesn't say that. This specifically says
that those systems are only -- they are in the envelope of
the design basis, and we have left all the other systems
out.
MR. THADANI: When you say "this," you mean the
maintenance rule?
COMMISSIONER DIAZ: Absolutely.
MR. THADANI: No. I think the maintenance rule's
scope is much broader than that and it's broken down in
parts. One part says all safety-related structures,
systems, and components. That's one part.
Another part is --
COMMISSIONER DIAZ: No, sir. Read the defining
paragraph above it. It doesn't say that. It says, means
. 25
those safety -- those SSCs that are relied on to remain
functional during our --
CHAIRMAN JACKSON: I think that we're not going to
resolve this issue in this meeting. I think it is more
important for us to try to understand where the Staff is at
this stage of the game and then we can come back and
consider, you know, how that is affected by lack of clarity
with respect to the definitions.
Perhaps once they've gone through it, we can have
a clearer understanding, so why don't you go ahead.
MS. BLACK: As I was saying, the scope of the
maintenance rule usually is about 60 percent of plant
structures, systems, and components, although that can vary
a lot depending on how licensees do their scoping. It can
be as low as 50 percent and I've seen it almost 80 percent
at some plants.
Then the expert panel determines the safety
significance or makes that cut between high safety
significant and low safety significant, and that is usually
about 30 percent of the in-scope systems end up being high
safety significant.
The monitoring then varies depending on the safety
significance of the structure, system, or component. High
safety significant SSCs are monitored at the system or train
level and reliability and availability are both monitored.
. 26
For low safety significant, normally operating
system, they are monitored at the plant level, monitoring
scram safety system actuations or unplanned capability loss.
Standby systems are monitored like they were high
safety significant. They're monitored at the train level
and at least reliability is monitored.
COMMISSIONER ROGERS: Excuse me. Could you just
explain what you mean by monitored at the plant level?
MS. BLACK: Monitored at the plant level would be,
you would set performance criteria of no more than two
scrams per cycle or no more than X number of safety system
actuations, and then when you reach that trigger, you would
go and look at what components were causing that and monitor
it more closely under (a)(1).
But if you monitored all the systems under the
maintenance rule like you do the high safety significant,
the monitoring requirements would be pretty extensive.
And also, monitoring varies with performance.
Most -- using 93-01, licensees before the date of the rule
are supposed to go back and look at their data to see if
they meet the performance criteria.
You can monitor your SSCs under paragraph (a)(2)
but you have to demonstrate effective preventive
maintenance, and this you do by meeting your performance
criteria that the licensees set for themselves. And if
. 27
these standards aren't met, then the SSCs must be monitored
under (a)(1) or licensees must take corrective actions and
set goals and monitor against those goals.
And the final part of the rule is the periodic
assessment in which the program must be assessed every
refueling cycle to evaluate the overall effectiveness of
maintenance at the plant. And also, they must balance at
that point reliability and availability to determine if
they're not doing too much preventive maintenance and
causing too much unavailability of the system.
COMMISSIONER McGAFFIGAN: Could I clarify if this
is the right time? The Staff has clarified to the industry
that it is not a problem to be under (a)(1).
MS. BLACK: Right.
COMMISSIONER McGAFFIGAN: There is nothing you're
going to hold against them if they're in paragraph (a)(1) as
opposed to paragraph (a)(2)? There was apparently at the
outset some misgiving with regard to the staff's intentions
on that, but you have clarified that?
MS. BLACK: We hope so, and I'll do it again right
now. Having systems in (a)(1) is not looked upon as a
problem by the NRC and won't be considered in the self-
grades and that type of thing.
And the other part of (a)(3), which Ashok talked
about, was the part that encourages licensees, when
. 28
performing preventive maintenance, to assess the total plant
equipment that's out of service to determine the effect on
safety functions.
COMMISSIONER DIAZ: Excuse me. Is there a
difference between performance goals in (a)(1) and
performance criteria in (a)(2)?
MS. BLACK: Yes.
COMMISSIONER DIAZ: Could you --
MS. BLACK: A lot of times the goals that are set
when somebody goes into (a)(1) can have the performance
criteria from (a)(2) as the goals, but we like to see a goal
that is specific to the problem.
For instance, if there was a -- one of the plants
we went to had a reactor coolant pump shaft problem and one
shaft had actually broken and they were concerned that the
other shafts which had the same material were going to
perhaps fail, and so they set a goal of a certain level of
vibration. If they hit that level of vibration, they
thought there was a greater chance of that shaft breaking
too and so they were going to shut down and replace it.
So we like to see the goal specific to the
corrective action or the problem and have them monitor it
more specifically under (a)(1) than it is under (a)(2).
COMMISSIONER DIAZ: So there is a difference in
actually the level of specificity or the --
. 29
MS. BLACK: Usually.
COMMISSIONER DIAZ: -- level of demanded safety
usually between --
MS. BLACK: We like to say usually because of the
flexibility in the rule, but, yes. If there hasn't been a
problem identified, specific corrective actions that have
been taken for that problem should be monitored to make sure
that the problem has been corrected before you go back into
(a)(2).
COMMISSIONER DIAZ: Have there been problems
between performance goals and performance criteria, or that
is very well understood by everybody?
MS. BLACK: Has there been a problem? I think
that during the pilots there was a problem because we had to
put out more clarification on that specific issue that we
expected the goals to be more specific to the problem than
the performance criteria, yes.
And now Rich will discuss the results of the
baseline inspections and the clarifications in the
regulatory guide.
MR. CORREIA: Thank you, Suzie.
Could you go to slide 6, please?
[Slide.]
MR. CORREIA: As Ashok said earlier, we have just
completed the 20th baseline inspection last week. Each
. 30
inspection, we're finding, is unique because of this
flexibility licensees are given to develop and implement
their program.
Each time the inspectors prepare, they have to
start fresh with a new program, the different ideas, and
evaluate those as to whether or not they meet the
regulation.
For example, one of the differences we have seen
is how licensees scope SSCs into the rule. Some have done
it by systems, some have done it by function, which tends to
increase the overall number. We have determined that both
are perfectly acceptable but, again, it causes you to step
back and evaluate these programs in more detail.
You can't necessarily take what you learn from a
previous inspection on to the next because it may be quite
different.
Overall, I believe licensees are doing an adequate
job implementing the rule. As Ashok said, we have seen
problems; we have issued many violations, but the violations
tend to be specific to a particular part of the requirement,
not that they did not meet a requirement.
For example, high safety significant SSCs should
be monitored against both availability and reliability. In
some cases, we found that one of the two was not being
monitored, so they established the (a)(2) programs, but how
. 31
they were monitoring a particular system or group of systems
varied and that was one example.
Two of the sites have had no violations. One site
had a Level 3 violation with no civil penalty, and the rest,
a combination of some varied Level 4 violations.
COMMISSIONER DIAZ: Any program that was not
acceptable, not adequate of the 20 that you could say --
MR. CORREIA: No. They've all implemented
programs, developed programs. The problems we've seen are
specific to a certain part of the rule.
One of the problems that seems to be related to
some of these violations are that some licensees did take
full advantage of the three years that the Commission gave
them to implement the rule. They got late starts -- they
all developed the programs but took longer times to actually
implement them and resulted in some of the problems we've
seen.
Next slide, slide 7, please.
[Slide.]
MR. CORREIA: Two of the common findings we have
seen on these baseline inspections, one is inadequate
reliability performance criteria/goals. Some licensees were
monitoring reliability by counting the number of MPFFs,
which is a maintenance preventable functional failure,
failure of the function that placed the SSC in the scope of
. 32
the rule.
Without an adequate technical basis -- for
example, if they chose to monitor unavailability for the
high-risk system, high-safety system, there may not have
been a link back to the PSA assumption, for example.
COMMISSIONER DIAZ: So this implies that everybody
monitored availability in an adequate fashion, because the
only inadequate was reliability?
MR. CORREIA: In this particular case I was citing
here, it related to reliability, using a number of failures
over a period of time without considering demands or a link
back to the PSA assumption.
CHAIRMAN JACKSON: How do the inspectors judge the
adequacy of reliability, performance criteria or goals, and
what role does the licensee's PRA play in setting the goals?
MR. CORREIA: Typically the inspector would ask,
what is the basis for this particular value you've chosen?
In most cases for high safety significant SSCs, there is a
link back to the assumption in the PSA, and based on that
assumption or some sensitivity analysis that they've chosen
to do, the inspectors determine whether or not this
performance criteria is acceptable.
For example, if they chose 95 percent reliability
for their emergency use generators, you would expect to see
a reliability criteria that was equal to that, or if it was
. 33
different, some basis for why that difference was
acceptable. And it may be some type of sensitivity analysis
to show that perhaps 90 percent is acceptable and -- for
particular reasons.
MR. THADANI: If I may, assessing underlying
reliability for any given component requires a fair amount
of data, demand information, and one can use estimators
rather than regular statistical assessments because then the
need for data goes up quite significantly.
So like diesel generators, there may be enough
information on -- that includes testing and actual demands.
It would be difficult if the expected reliability is much
better than what we demand for emergency diesel generators.
For example, if it's a passive structure, one
would demand fairly high reliability. It wouldn't be very
-- one can establish numerical criterion, but it doesn't
really mean very much. So one has to then go back to
something else to assess.
For example, structure may depend on, is it
anchored properly, are the bolts in place, are some of them
loose, et cetera, is there a lock-down necessary?
So I think all these facets sort of have to be
considered as one goes forward in these inspections,
particularly when one looks at reliability performance
against what was assumed in the probabilistic safety
. 34
assessment.
I think it's going to continually be an issue we
have to watch, see how well it works.
MR. CORREIA: Another area that the inspections
have focused on is scoping. Certain SSCs were not included
in the scope of the rule, and one example we found fairly
commonly are non-safety-related SSCs that are relied upon to
mitigate accidents or transients or use the EOPs, such as
emergency lighting and communication systems.
And one could say, well, they do not perform a
mitigating function, but I think history tells us that these
systems are very important to the -- to assure that the
mitigation functions are achieved for use in EOPs.
CHAIRMAN JACKSON: Was that an issue where the
guidance was not clear enough?
MR. CORREIA: I believe it was discussed during
the pilot programs. I think we probably didn't make it a
big issue at that time. It certainly was covered during all
the pilots, but it is important and it is in our regulatory
guide now.
A similar issue we've seen recently in the
baselines is a reluctance to identify maintenance
preventable functional failures. I'm not quite sure why.
It may be something similar to why there was reluctance to
put things in (a)(1) during the pilot programs. It may be
. 35
seen as an indication of poor maintenance programs. We
don't view it as that. It's an indication that there's a
problem that needs attention and corrective actions, and
there's certainly no penalty on our part.
Structural monitoring. As we recognized during
the pilot program, structures cannot be monitored using
performance criteria as active systems. They need more of a
condition monitoring approach.
We all agreed, though, with industry that more
guidance was necessary. NUMARC NEI did add guidance to 93-
01, and we have added additional guidance in our reg guide
also to address this issue.
And the main problem we've seen during the
baselines is that licensees have established criteria that
would move something from the (a)(2) category to the (a)(1)
category after a failure. I think for a structure, that's
unacceptable, something -- the problem needs to be
identified as a -- if left alone, would result in a failure;
at that time moved to the (a)(1) category for corrective
action.
The (a)(3) safety assessments we have discussed
somewhat already. All licensees are doing something. They
vary from using a fixed deterministic blend with PRA matrix
of combinations of systems that cannot be taken out of
service simultaneously.
. 36
Some licensees have an on-line safety monitor or
risk monitor that they use to determine what configurations
are acceptable or not. As Ashok said, they are all treating
the "should" in the regulation like a "shall." They are all
doing something. The question comes up is, are these
weaknesses we are seeing in their methods such that we need
to change the rule? We don't believe we do at this time.
COMMISSIONER McGAFFIGAN: Could I follow up on
that? You don't believe you need to at this time, but on
page 17, I think, of the paper, you say you're going to
continue to assess that. And what you just said, they're
treating the "should" as a "shall" is -- at a briefing last
week -- you were present -- I didn't hear that then. They
are doing something. They aren't doing as much, was my
impression, as if the word "shall" was there rather than
"should."
And it strikes me, in the PRA implementation plan,
we're talking about in-service inspection and in-service
testing, at some point being able to do this configuration
control is going to be important and have consequences in
other areas. Isn't that the case?
When will we or when should we get you guys to
come back to us and tell us whether we need to change
"should" to "shall"? What's the proper time period in which
to get that assessment out of you?
. 37
MR. THADANI: Let me comment on that. I think the
concern is real. The issue of configuration control, on-
line maintenance, I think is a safety significant matter.
We have to deal with it very carefully.
As Rich mentioned, we have identified problems,
weaknesses is what we call them, and what we're finding is
that the licensees are listening to our concerns and would
like to take a crack and see as feedback, are they actually
taking advice and comment they're getting and implementing
changes. We would like to be able to get that information
before coming with a proposal to change the regulation or
not.
As far as other activities are concerned, as you
know, we've been working and using risk insights in
technical specification activities. South Texas is an
example, have come to us and proposed changes to their
technical specifications, to high-pressure safety injection
and on-site AC power source.
We have made it a practice basically to make sure
that for those cases, at least that configuration control
becomes part of the technical specification changes, that
is, while you can grant longer outage time for some
components, that is not allowed if another component that
might appear in a sequence is also out for preventive or
corrective maintenance. So that concept we're applying in
. 38
other areas makes sure that that's built in. But that's
sort of ad hoc.
CHAIRMAN JACKSON: So if it's ad hoc, it begs the
answer to his question.
MR. THADANI: Absolutely. What I was getting to
was, in the pilot studies, we're certainly looking at that
element. What I was saying was that even within the
maintenance rule itself, we need to get some level of
confidence that the utilities are actually paying close
attention to on-line maintenance even though the rule itself
says "should." That relates to enforcement activities.
CHAIRMAN JACKSON: Well, but on page 17 -- now I'm
going to play Commissioner McGaffigan -- it says that
because -- this is under the conclusions, "Because the
provision in paragraph (a)(3) that states that licensees
should assess the impact on safety when removing equipment
from service is not a requirement, this provision is
unenforceable. But at this time the Staff doesn't believe a
rule change is necessary."
MR. COLLINS: Chairman, I think perhaps this is
just a matter of a level of expectations, and I think there
is probably some history that goes with this wording that it
might behoove us to understand better.
But in any case, clearly, if we are going out and
inspecting with the premonition that we want this done and
. 39
we're satisfied because licensees are doing it, but at the
same time the licensees have the option perhaps not to do
it, and we need to reevaluate whether we need to change the
rule.
And I believe, based on the inspections that we
have, we should be able to derive a fairly good database of,
is this provision necessary for us to have confidence in the
overall implementation of the rule? And if it is, then we
need to be willing to make a recommendation to the
Commission on whether the word should be changed.
CHAIRMAN JACKSON: Commissioner McGaffigan.
COMMISSIONER McGAFFIGAN: I don't want to keep
beating a dead horse here, but the South Texas example is
one where it's sort of unique. They have an extra train or
an extra half a train or whatever that allows you somewhat
more flexibility to get a spec change there, but even there
you're sort of, through the back door, requiring
configuration control. I think it's going to come out, I'll
bet, in an in-service inspection and several of the other
initiatives that are underway.
So all I'm urging is that you continue to think
about being up front about it rather than having it come in
the back door. If you all think it is necessary, let's put
it in through the front door.
CHAIRMAN JACKSON: When do you anticipate having
. 40
all of your inspections done?
MR. CORREIA: The goal is July 1998, two years to
do all sites.
COMMISSIONER ROGERS: Just before we leave this
dead horse, I think it's important to understand why they're
not doing this if they're not doing it.
It seems to me -- it's very puzzling to me. It
seems to me this is so fundamental that we better understand
why they're not just accepting this without any question in
doing it because it's -- you know, it's as plain as the nose
on your face how important it is.
So if they're not doing it, I think we ought to
really understand what the reasons are that they are
apparently not doing it, because I think they're going to be
as important as making the change in the rule, understanding
what the underlying problem is, if there is a problem.
MR. THADANI: I hope we're not leaving you with
the impression that the licensees are not doing it. I think
the issue is how good an evaluation are they conducting,
have they got the right scope when they look at, for
example, a matrix. Let's say they cannot take certain --
two trains out simultaneously, one from system A and one
from system B.
COMMISSIONER ROGERS: I don't want to go on with
this, but if it's -- for this purpose, if it's an incomplete
. 41
and inadequate job, it might as well not be done at all. I
mean, you've got to do it right, and so I think that the
notion that something less than an adequate job is even
contemplatable is troublesome to me. I think that somehow
we have to get at that.
COMMISSIONER DIAZ: If I could beat on the dead
horse --
CHAIRMAN JACKSON: Well --
COMMISSIONER ROGERS: Put a saddle on it and ride
it.
COMMISSIONER DIAZ: I understood from the comments
that, you know -- and I -- obviously it is true, that the
issue of reliability is more complex and requires much more
data, and obviously that's true.
However, the issue of availability should be
simpler and therefore more enforceable, and I think that
definitely should give us the line saying we will not
require you to start looking at reliability up to the last
significant place, but we do require that you maintain a
configuration that operates under conditions.
Is that correct?
MR. THADANI: Yes.
CHAIRMAN JACKSON: Do you know any of the "why's"?
COMMISSIONER McGAFFIGAN: Why the "shall" and the
"should"?
. 42
CHAIRMAN JACKSON: No.
COMMISSIONER ROGERS: No. Why an inadequate job.
MR. SHACKELFORD: I don't think we've found any
that are inadequate at this point. We found a wide variety
of what I should call weaknesses. As I said, they go from
-- risk monitor for a licensee is really an endeavor to
monitor their entire plant on a real-time basis right down
to what you might call business as usual.
I think licensees have always assessed the impact
of taking equipment out for maintenance. The control room
SRO, that's part of his job description, but we don't
necessarily think that that's probably the most
comprehensive way to do it, given the tools that they may
have now. So we are looking harder at that than we may have
in the past.
The maintenance rule requires them to look at all
equipment out of maintenance, not just safety significant,
frontline systems, and those are the types of weaknesses
that we're pointing out, that while you still have to keep
track of the tech spec outages, you also need to look at
these other systems that may challenge your plant.
And those are really the issues we're talking
about here. And I think the industry has been receptive to
that. They haven't necessarily been happy to hear our
comments, but I don't think we've had a disagreement that
. 43
those are important issues to address.
CHAIRMAN JACKSON: In saying that you don't hear
disagreement that these are important issues to address,
does that mean, then, that you see a change?
MR. SHACKELFORD: As I said, I don't think you'd
find a single utility who would say we're not going to do
assessments before we take the equipment out of service. I
think they will all tell you they've always done it and they
will continue to do so.
The exact nature by which they do them and the
level of specificity I think is what the issue is, and
that's where the weaknesses which we have identified are
coming into play.
CHAIRMAN JACKSON: Why don't you go on.
MR. CORREIA: Slide 8, please.
[Slide.]
MR. CORREIA: I mentioned earlier enforcement on
11 of the 20 inspections are complete. Two had no
violations at all. One had a Severity Level III but no
civil penalty, and eight had one or multiple Severity Level
IV violations, and the remaining inspection findings are
still under Staff evaluation.
CHAIRMAN JACKSON: Let me ask you a question.
Have any of the violations or enforcement actions been
related to what you might call the performance aspect of the
. 44
rule?
MR. CORREIA: I would say not as many as more of
the programmatic problems that we've seen.
CHAIRMAN JACKSON: Let me ask you this second
question. Can we make a statement yet as to whether
maintenance, in fact, or equipment performance has improved
since the implementation of the rule? Because in the end,
that's what we want, right?
MR. CORREIA: Right. I think several plants have
told me -- managers have told me that they're much more
aware of equipment performance now than they were
previously.
CHAIRMAN JACKSON: Well, I guess I'm asking a
different question.
Do we have an inspection program that does, in
fact, look at maintenance, and it looks at various things in
terms of equipment failures, whatever? Have we done a
marriage to know, or just in general, do we see any
improvement in equipment performance?
MR. CORREIA: I think the latest data from AEOD
still shows a high number of reactor scrams initiated from a
balance of plant, which is one of the main reasons that the
Commission wrote the rule. So in that aspect, I guess we
have not seen a change.
CHAIRMAN JACKSON: So in the end, performance is
. 45
as performance does, my favorite phraseology. And the
question is, if we still don't see any change, what are we
getting?
MS. BLACK: I think one of the benefits we're
getting is the understanding of unavailability that wasn't
there before, either in non-tech spec systems or tech spec
systems that the licensees were in and out of, but never
tracked total unavailability throughout the year.
MR. THADANI: Also, I might note that it's
probably going to take quite some time before we can get
objective information to see if there is a big difference.
How we can send out the awareness is the issue.
CHAIRMAN JACKSON: So the awareness has increased
but we don't know yet?
MR. THADANI: And I think it will take quite some
time before we will know with objective information.
CHAIRMAN JACKSON: All right.
MR. CORREIA: Slide 9, please.
[Slide.]
MR. CORREIA: Slides 9 and 10 contain the
clarifications we've made to regulatory guide 1.160. The
ones I have listed on the slide are the ones we feel are the
more significant ones, and I'd like to review those. And
then if the Commission would like to talk about any on slide
10, we can do that also, if that's acceptable.
. 46
Regulatory guide -- Rev. 2 to regulatory guide
1.160 endorses NUMARC 93-01, Rev. 2, with clarifications.
For example, one of the clarifications we have
made are those non-safety-related SSCs whose failure could
cause a scram. We've tried to clarify when one of those
systems should be in the scope of the rule, to say that if
it has failed at a particular site and caused the scram,
obviously it's in the scope.
Then, if it has caused a problem at a similarly
configured plant, the licensee should seriously look at
whether or not that system in his plant or her plant should
be within the scope of the rule.
Or if there's an existing analysis that said, if
this system fails, it will result in a scram, that would
place that within the scope of the rule.
I talked earlier about certain SSCs that are used
in EOPs and they're used to mitigate accidents and
transients, such as emergency lighting and communications
are very important, even though they directly are not used
to mitigate the action functions.
We talked before about MPFFs as a reliability
indicator. We have now concluded on a regulatory guide that
this is acceptable provided that there is a sound technical
basis for whatever number of MPFFs the licensee chooses as a
means of monitoring reliability.
. 47
Structures, we touched on earlier. We've added
some additional guidance in our reg guide, in addition to
what changes were made to 93-01, to say that structures
should be monitored differently than active mechanical and
electrical systems and that condition is a better process or
method of monitoring the condition of structures, and that
actions need to be taken to correct the problem before
failure occurs, if there should be an indication of a
problem, corrective action taken and placed in (a)(1) with
goals in monitoring before a failure.
COMMISSIONER DIAZ: Excuse me. Could you give me
an example of a non-safety-related SSC that is relied upon
to mitigate accidents?
MR. CORREIA: That could be -- feedwater systems
or condensate systems typically are non-safety related.
They could be used as a core cooling system. I think the
condensate system was the non-safety system at Saint Brown's
Ferry when they had their fire. That's one example that
comes to mind.
COMMISSIONER DIAZ: And we classify them as a non-
safety system because it's not in the Q list? Is that --
MR. CORREIA: It doesn't meet the definition of
50.65 for safety related, yes.
COMMISSIONER DIAZ: Is that the clear interface?
Is it in the Q list or it's not?
. 48
MR. CORREIA: Quite often, Q lists contain more
than just safety-related SSCs. Most licensees are fairly
conservative with the Q lists.
Normally operating SSCs of low safety
significance, the clarifications to the reg guide.
Typically these systems are monitored at the plant level,
again, such things as plant scrams. Some licensees are only
monitoring against automatic scrams. We wanted to clarify
that unplanned manual scrams are just as important also and
should be monitored for these types of systems.
Are there any particular items on slide 10?
COMMISSIONER DIAZ: Number one.
MR. CORREIA: Number one, safety-significance
categorization process. The only point we wanted to make
here is that the process used to implement the maintenance
rule, to categorize SSCs, is either high or low safety
significance. It's specific to the maintenance rule and
doesn't necessarily -- or cannot necessarily be used in
other applications, for example, greater QA or ISI or IST
approaches.
We do recognize, though, that we are doing a lot
of work in this area and if at a future time there is
information that is developed in the SRPs or the reg guides
for the PRA implementation plan that could be beneficial, we
would again revise the reg guide to reflect that.
. 49
COMMISSIONER ROGERS: It's really not a question,
but it's an observation, that is that in this definition of
maintenance, we are focusing very much on what we regard as
related. I don't want to use the terminology incorrectly,
but it has some connection with safety. Let's put it that
way.
And I wonder whether you've seen any effect or you
think there might be any effect as the plant focuses its
resources this way, on plant housekeeping, whether, for
example, the place starts to look worn out, even though the
important equipment is in good shape. I'm not going to
comment on whether that's good or bad.
I think it may relate somewhat to a general state
of attitude and safety culture, but I wonder if that is
something that one might expect to happen in the future as a
result of our move in this direction and the economic
stresses that are coming to bear on licensees.
MR. CORREIA: Certainly material condition is one
of the items that all baseline inspections cover, and I
think, to date, generally the reports are fairly good, that
material condition is generally good, that I think there
have been certain cases that on a certain particular piece
of equipment, that it may be less than desirable. But it
may be for a very good reason. Perhaps they just finished a
major overhaul and haven't had a chance to bring it back up
. 50
to some specification.
I really don't know if we will see changes in that
area because of the stresses you mentioned.
COMMISSIONER ROGERS: I wouldn't be surprised. I
think we may have to decide what our position is in that
case, if any.
CHAIRMAN JACKSON: How do we deal with the issue
of living PRAs and their effect on categorization of systems
and performance requirements? You know what I mean when I
say living PRAs?
MR. THADANI: Yes, yes. That is one of the
elements in the various pilots that we're working on, and
the concern we have -- first of all, as one makes changes,
one needs to keep track of those changes and needs to know
on a real-time basis the plant as is versus reflection of
the study itself.
So we are looking at finding ways for those
licensees who want to use these techniques to make changes
or seek relief in some areas, that they do need to keep
track of those changes, that that would basically be a
living PRA, so that at any given time, we know the PRA does
reflect the plant as is rather than what it might have been
like six years earlier.
So that's the path we're on as part of the PRA
implementation plan.
. 51
In this case, they have to make an assessment -- I
believe it's every two years -- to see what the plant
performance was and, in fact, whether it might change their
initial judgments. They have to revise their earlier
decisions. They do have to make an overall assessment, I
believe, every two years for the program.
CHAIRMAN JACKSON: And that includes looking at an
updated risk profile?
MR. SHACKELFORD: We have been looking at that
issue in the inspections. We've asked that question. Those
licensees are using the PRA to derive performance criteria
or ranking.
We typically ask them questions about their plans
to update and go even further about how their current PRA,
what's the time frame of the data in the model that they're
using for that.
In those situations where we find problems, we
certainly document them. We're not enforcing a living PRA
requirement on anyone, of course, but I think the biggest
issue in that area we've seen are a lot of licensees may be
using what you might call outdated data as opposed to
outdated models.
I mean, they pretty much reflect the configuration
of the plant, but they may be using generic data or data
that hasn't been updated in several years.
. 52
In those cases, on a case-by-case basis, where we
think there might be a problem, we'll make challenges on a
specific point, but that is part of the inspection process.
MR. THADANI: We would expect, as, for example, if
new information comes out -- and it could be NRC issues
generic communication because we learn something new --
clearly those factors have to be considered by the utility
in the assessment of its program.
CHAIRMAN JACKSON: You were asking about page 10.
Tell me about MPPFs related to the design deficiencies.
What do you mean by this? Can you give an example?
MR. CORREIA: As a point of clarification, that
should have been MPFF. I apologize.
The issue came up during the pilots, I believe,
where licensees, for economic reasons, had decided not to
change the design that was -- of a piece of equipment that
was giving them performance problems.
Understanding that, we said our expectation was,
you should enhance your preventive maintenance program as
much as reasonable to assure that future failures don't
occur, increased frequency of tests or surveillances or
changes to consumables or whatever, but just to live with a
bad design and walk away with it without some type of change
to the maintenance program we didn't think was acceptable.
We just wanted to clarify that point in the regulatory
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guide.
COMMISSIONER DIAZ: Number of SSCs in category
(a)(1)?
MR. CORREIA: That's what Suzie mentioned earlier.
During the pilots, for some reason, some licensees felt that
(a)(1) was a penalty box. It might trigger some huge NRC
inspection if they had too many SSCs in (a)(1). We just
want to make sure everyone understands that that is not the
case, (a)(1) is a requirement. As long as they meet the
requirements, there's no problem.
Any others?
Slide 11, please.
[Slide.]
MR. CORREIA: I believe we've touched on all of
these items. Certainly Ashok did. We mentioned
communications was very critical during the developing
phases, and we still believe it is today. We continue to
believe that open and effective communications with the
industry and the public is essential to the success of
implementing the rule.
Pilot programs, we believe, are very important.
We learned an awful lot, and it was also easier to do during
a non-enforceable environment. It was easy to discuss
issues openly with licensees.
Ashok mentioned that guidance was developed
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through the iterative process. The industry developed 93-
01. We discussed it over a two-year period. We did the
pilot programs; it changed somewhat again. We revised our
regulatory guide twice since then, all through information
that we gathered during each phase of the implementation of
the rule.
Ashok mentioned training. Also, we've trained in
varying degrees over 900 people in the NRC on the
maintenance rule.
COMMISSIONER DIAZ: Is that -- do you have a
breakdown whether that's regions or quarters?
MR. CORREIA: By regions, I don't. By far, most
of the inspectors are in the regions. I think we've trained
over 130 inspectors that do the baseline inspections, close
to 400 other inspectors that may have some involvement with
the rule, like resident inspectors, though I have to admit,
Region IV did have every resident -- or one resident at
every site take the full three-day course, and the rest are
NRR Staff that may have some dealing with the maintenance
rule.
Ashok mentioned earlier that we believe the rule
can be consistently inspected and enforced through the
communications that we've had with the regions and licensees
and to the enforcement panel that's established.
Resource requirements have been high through the
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iterative process of developing guidance, inspection
procedures, meetings with the public, workshops, and what
we're doing on the baselines to maintain oversight.
CHAIRMAN JACKSON: Do you expect that to continue
at that level?
MR. CORREIA: I believe until the baseline --
baselines are complete, it will. They will.
MR. COLLINS: Madam Chairman, I think it's
important to note here that we're dealing with history also.
This is one of the first inspections of this type. We're
taking 30 to 40 years of agency momentum as far as types of
inspections, qualification of inspectors, enforcement
approach, and we're trying to turn the corner with the
initial inspection here, and it takes some time.
It takes some orientation; it takes some
recalibration and sorting through the results and
understanding where we are, and adjustments, as indicated by
the revisions to the guidance.
So I would anticipate, if we continue on this type
of track, that the initial resources as far as the
development might be somewhat the same, maybe even a little
less, but the actual practitioner application and the
thought process that it takes to shift gears from
deterministic to performance-based will be easier as to
generations of inspections continue on.
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There will always be, in our mind, initially a
programmatic inspection for the application of the rule, and
any more performance-based routine follow-up, typically by
the residents. In the maintenance rule here, it is more
event driven than it is programmatic.
The real insights to the maintenance rule, I
believe, will be forthcoming as a result of challenges to
the plant that result from component malfunctions, and using
the programmatic inspections, we'll go out and take that cut
and look back into the rule based on a malfunction and
determine whether the rule is being applied appropriately.
That will be the real insights into the long-term
application of the rule.
COMMISSIONER ROGERS: Well, it also may be that
you want to look and see what the effect is on the license
renewal activities that we get into, that this may be partly
an investment in a sense, unrecognized at this point, but as
licensees come forward with applications for license
renewal, it may be that this investment will pay off in that
area.
MR. THADANI: Absolutely. In fact, for past
structures and so on, this becomes critical for license
renewal activities, and that's why the procedures that Rich
mentioned earlier in terms of guidance, we have tried to
make sure that the guidance we're using here would be
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sufficient even when we get to license renewal activities so
we don't have to come up with yet different guidance to look
at the same structures.
So you are quite right, and our internal
activities we have integrated that way.
COMMISSIONER DICUS: Mr. Collins may have -- may
have answered this question, but it is on the resource
commitments. I want to pose the question in terms of future
resource commitments, particularly in light of the fact that
we may well continue down this road of looking at
regulations that are risk-informed, performance-based and
new kinds of regulations that may be written.
And in the lessons learned here, and particularly
-- and it's referenced a bit I think in the paper itself,
are we to assume that future regulations of this nature
might also be very resource intensive, certainly on the
front end of those regulations, or are there lessons learned
that perhaps future regulations might not have to be so
resource intensive on the front end of the regulation?
I raise the issue in terms of long-term budgetary
planning, because if this is a course that the Commission
may well be going down, we have to continue -- concern
ourselves with the year '99 and 2000 and so forth budgets,
are we going to need to consider these things as well?
CHAIRMAN JACKSON: Before you answer it, I'd like
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for you to answer it in the context of what kind of resource
requirements go into our initial implementation of any new
rule that's of significance.
MR. THADANI: I'll give you a judgment. It seems
to me that the maintenance rule is quite broad. It's our
first -- by and large, it's our first truly performance-
based rule, and therefore, probably we have had to expend
more resources than we might have for future changes in the
regulations.
But I think the real issue is the degree of
increase in resources is going to depend on the type of rule
we have in front of us. This affects the whole plant and
it's pretty complex. If it's a fairly simple rule, I don't
know that there would be much impact.
But if we were to, let's say, revamp fire
protection radically to go to performance-based, I would
anticipate that, again, the initial resource commitments
could be pretty high, because the idea behind these
approaches is: let's agree on what kind of a program makes
sense up front and then we'll walk away.
The agency basically would say, okay, we will not
get involved unless there are some signal indicators that
there may be a problem, and then we will react to that.
CHAIRMAN JACKSON: You don't really mean we're
going to walk away?
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MR. COLLINS: No, we don't.
MR. THADANI: What I meant was, we have placed our
residence in other people watching. When I say walk away, a
significant intervention on our part would come if we have
reason to believe that there may be a problem.
It seems to me that it is very important that the
ground rules be agreed to up front and both sides need to
understand, and because there is so much -- because the
whole idea is to provide flexibility, one should have some
agreement on what does that really mean up front.
So it seems to me that one would have to do early
performance -- for performance-based rules, programmatic
inspections very likely would have to be done.
And if I use this experience, then that says you
probably have to spend more resources. How much more, I
think, is going to be determined by the scope and range of
activity we're talking about.
But I think it does mean, up front, an increased
resource commitment.
CHAIRMAN JACKSON: But isn't it also a function of
the expertise of the Staff going in?
MR. THADANI: Definitely. And because the
concepts utilized are pretty multidisciplinary -- and that
means you have to get all those resources together and go
take a look, and it's -- quite frankly, it's been very tough
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on us to support these inspections.
The gentleman sitting to my left can tell you how
often we called him, because the PRA resources are tight.
There's no question. We have a lot of activities that are
going on, and we had to beg, borrow, and do everything we
could to support these inspections, and I anticipate similar
challenges if we have major rules that are revised.
MR. COLLINS: Really, I think the most efficient
way is very similar to the way the maintenance rule was
handled in that there's a performance-based, fairly brief
rule with stated goals -- we can argue about the one, and
that's our last bullet -- that the industry provides some
measure of input as far as the guidelines for application.
And that's recognized by the staff and in fact
endorsed by the Staff, and that's a fairly clear-cut process
which I think in the future we should continue to embrace
whenever it's appropriate.
The resources, to my mind, come in when you're
trying to inspect a performance-based rule at each site,
where each site has options for implementation, have perhaps
very different structures and resources available to them,
so you cannot go out and do the same inspection on each
site.
So to gain confidence that the performance-based
rule does have enough of a platform for us to then turn to
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measure only performance of that rule, we have to do a very
in-depth, very focused inspection on each site, and that's
difficult.
I don't see that changing very much. I think we
still have to do those types of inspections on the
performance-based rule.
The payback, hopefully, is on the back end of the
process where we free up our on-site resources to look at
other issues or to redirect them in other areas, and then we
allow the licensees in their performance-based realm to
focus on what they believe is important, not what the agency
--
CHAIRMAN JACKSON: -- has agreed with them is
important?
MR. COLLINS: Right.
CHAIRMAN JACKSON: So how do you measure those?
MR. COLLINS: I think that's a good question.
It's a fair question that was stated, Madam Chairman, and I
wrote it down. We have to be able over a period of time to
measure that this rule has met the mutual goals that warrant
the type of investment that was made. And we owe you that
answer.
CHAIRMAN JACKSON: Anything else?
MR. CORREIA: The last item I think we've talked
about quite a bit, but from an enforcement perspective, the
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rules must only contain requirements.
The last slide, please, number 12.
CHAIRMAN JACKSON: I'm confused. Is this new
information? You say rules should only contain
requirements.
MR. CORREIA: We're referring to the (a)(3) part
of the rule that says they should do safety assessments
versus shall do safety assessments.
MR. COLLINS: We covered it earlier in the
discussion.
CHAIRMAN JACKSON: Not exhortations but
requirements?
MR. CORREIA: Yes.
MR. THADANI: There's something in the rule, but
the rule itself says should be done, but we're having a hard
time enforcing it, so it's the language in the rule.
CHAIRMAN JACKSON: I think there's a lesson there
in terms of, A, what gets propagated to the Commission in
terms of a proposed rule, and B, the scrutiny the Commission
gives to a rule and what it signs off on or may, in fact,
modify, okay, to make an exhortation as opposed to a
requirement. So I think there's a lesson for all concerned
in that regard.
[Slide.]
MR. CORREIA: Slide 12, status of future
. 63
activities we're working on or planning on working on.
Again, we plan to -- our goal is to complete all baseline
inspections by July 1998.
We have drafted an information notice based on
lessons we've learned from the baseline so far. We expect
that to be issued next month, and, again, communicate to the
industry what we found, what kind of information they should
be considering.
We will now revise our baseline inspection
procedure to reflect changes to our regulatory guide. If we
keep it current, we think we can have that done by this
July.
We are also working on a Home Page to share with
industry, maintenance rule documents and information that
are already publicly available but haven't been easily
accessible through the Internet. Our goal is to have that
completed by this June.
The Office of Enforcement plans to revise the EGM
that we are currently using for the maintenance rule. We
have discussed with them options on how soon that could be
done. We basically feel we have enough experience now with
the baselines to go ahead and clarify some of the guidance
that's in the EGM at this time.
We are also working with the Technical Training
Division at TTC to transfer the training program from NRR
. 64
now to TTD for them to -- for future training. We hope to
have that transition completed by the end of the year.
CHAIRMAN JACKSON: Let me ask you a more mundane
question. What's the typical makeup of the expert panel,
and is there consistency or does it vary from plant to
plant?
MR. CORREIA: Typically, there's representatives
there from plant operations, maintenance, engineering,
certainly the PSA area, and most licensees will bring in the
system engineers for the particular system they may be
evaluating. I think most are pretty consistent with that
makeup. Some involve quality assurance personnel also.
CHAIRMAN JACKSON: Any further comments?
COMMISSIONER DICUS: One last question. We
consider this basically a fairly successful rule. I think
that's a fair statement. Some members of the nuclear power
plant industry have raised some criticisms of the rule and I
would ask if those -- if you believe those criticisms are
fair or reasonable or valid, and if so, what are we doing to
address them.
MR. CORREIA: One of the issues that came up early
on was this issue of using MPFFs as a measure of
reliability. We felt the guidance was clear. It was
discussed during the development stages of the guidance
document in the '91, '92 time frame, and we responded to the
. 65
industry concern that way, what our expectations were in
that area.
Another concern of some licensees is that the
baseline inspections are very programmatic, as Sam
mentioned. We need to do programmatic inspections to gain
the confidence that licensees have established programs that
will effectively monitor the effectiveness of maintenance,
and until such time, I think we need to evaluate very
broadly, horizontally, the programs they've established to
implement the rule.
Once we have confidence that the programs are in
place, it's stable, then I believe we can focus more on
performance issues than the programmatic issues.
CHAIRMAN JACKSON: Okay. Commissioner.
COMMISSIONER ROGERS: Well, just one -- I'm sorry.
COMMISSIONER DIAZ: Go ahead.
COMMISSIONER ROGERS: Just one point, and that is
-- a general observation, and that is that in trying to
develop measures of how successful or not this is, I think
there are both quantitative measures, failures, scrams, so
on and so forth, but there's also the impact on what I'll
call the safety culture of the plant.
Right now, I think it's sort of an article of
faith with me that the more ownership that the plant people
actually feel towards their plant, ultimately the better
. 66
results and the more safe plant you're going to get.
But that's really an article of faith more than
demonstration, and I think that it's something to watch,
that whether this -- this approach of a performance-based
rule which ultimately looks at results -- that's the idea in
the end -- looks at results more than methods, although we
have to go through our programmatic inspection program to
make sure that we have some confidence that they can deliver
what they may -- what their objective -- performance
objectives turn out to be.
Once you get through that, and that will take some
time, whether one then finds that the general attitudes
within the plant are strong with respect to taking
initiatives to do things the best way themselves and to use
their resources in the best way, and that's a subtle
measure, but I think it is something to watch for because,
to me, that's one of the long-term benefits that I would
hope to see come out of this general approach.
CHAIRMAN JACKSON: Commissioner Diaz.
COMMISSIONER DIAZ: Thank you, Madam Chairman.
Although it might not be obvious from my previous
comments, I do love the maintenance rule, and let me tell
you why I love it.
Rather than just looking at the rule and the
language and the problems, I think for the first time, we
. 67
took a risk and went out there with something that was not
completely known, and probably for the first time, in
writing, we went and said, those known safety-related
systems which might be safety related, okay, that we know
about and you know about have to be treated in an equal part
with safety-related systems.
That was a great thing to do, because we have
known they're there. Everybody has known they're there, and
we keep feeling around, as it were, and we say, look, it
doesn't matter what we call it. If they are really, you
know, important to the safety of the plant, they have to be
addressed, and I think that was a major thing.
On the other hand, there are some words in here
that do need to be fixed, and I think you realize that there
is a little bit more specificity that needs to be described,
that the rule actually does apply to all those systems,
structures, and components that are in the plant during not
only the design basis and so forth.
I do think that we have done some great strides in
that availability should be clearly and further, you know,
analyzed and enforced if necessary, while we need to go on
our own learning curve on reliability, but I really commend
you. I think it's just going the right way.
CHAIRMAN JACKSON: Well, thank you. I'd like to
thank the Staff.
. 68
MR. CALLAN: Chairman, I think I'd like to just
make one comment and remind you, Chairman, of the June 1996
senior -- Staff briefing at the senior manager meeting
before the Commission at which time you, in closing, went to
each of the four regional administrators and asked us our
opinion. This is a month before the rule was implemented,
and asked us our opinion, our prognosis of how we thought
the rule -- how we thought it would go.
And as you know, regional administrators are a
tough audience, a skeptical audience, and I think you heard
-- if you remember, you heard a lot of concern from each of
us, a lot of trepidation from each of us.
It was not a scientific survey, but my sense is,
speaking for my colleagues, I think if you were to poll each
of the regional administrators now, I think you'd get a
sense from them that certainly their worst fears weren't
realized and probably that they view the implementation as
one of our more successful endeavors. I think it's gone
quite well.
And one final comment. When you look at resource
expenditure in implementing a rule of this nature, I think
you have to also consider that if those resources weren't
used in implementing the maintenance rule, a lot of
resources would still be poured into maintenance in a
different way, and it wasn't that long ago, how many years
. 69
ago, we expended significant resources doing maintenance
team inspections.
MR. THADANI: Right.
MR. CALLAN: I think the resources we spent doing
maintenance team inspections as an initiative would rival
the resources that we spent implementing this rule, and I
think -- in all candor, I think we would all agree that the
results of the maintenance team inspections were probably a
disappointment, given the resource expenditure.
So maintenance is one-fourth of the process. We
do inspect maintenance, and I think certainly the regions do
not begrudge the resources spent implementing the rule, and
those resources would have been spent doing maintenance
anyway.
So I don't know how you parse that, how you split
that away and just look at the delta resources of overhead
in implementing the rule and not the total resources, and so
that's it.
CHAIRMAN JACKSON: That's the important point.
Well, thank you again and it's been a very
informative briefing. I thank all of you.
I think that considerable progress, in fact, has
been made in implementing the maintenance rule, and, Mr.
Callan, your comments relative to the opinion of the
regional administrators helps to reinforce that perspective.
. 70
And as you've heard, obviously the Staff should
continue to focus on insuring consistency in the
implementation and enforcement across the industry. As many
of us have said, the maintenance rule is often referred to
as an example, maybe the first real one of a risk-informed,
performance-based regulation. That's certainly the way I've
been advertising it.
And because of that, the lessons learned from its
implementation should serve and must serve as a useful guide
to assist NRC in the future development and implementation
of risk-informed, performance-based regulation.
And in that regard, I will bring three things to
your attention. One has to do with this issue of -- and
Commissioner McGaffigan made this point before he left, is
asking you to consider again this question of whether the
category (a)(3) safety assessments, whether there needs to
be some clarification in terms of the language.
What you said about requirements should be in the
rules as opposed to exhortations, and I think you need to
come back to us on as short a time scale as we can work out
here with some more definitive statement in that regard,
because we've had histories in the past of saying, well, we
don't think we need to do anything, and then -- I won't be
here, but 15 years from now, we'll be talking about what we
could have done and should have done.
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And in the meantime, I think you should -- as you
go forward, I'd like to see some sense of how you're going
to track the efficacy of configuration control a la the rule
in our regular inspection program, even as we get
information through these baseline inspections from the
plants that haven't had them so far.
And secondly, I think it is very important that
this issue of being able to measure how efficacious the rule
is in terms of the net effect of the quality of maintenance,
that is, on equipment performance -- and again, I think this
is rooted in a basic inspection program, but it has to be
tied into the judgments we are making on the efficacy of the
rule itself, and then the issue of clarification of language
used is always out there.
So unless there are any further comments,
adjourned. Thank you.
[Whereupon, at 4:27 p.m., the briefing was
adjourned.]
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