Information Notice 1997-18, Problems Identified During Maintenance Rule Baseline Inspections

Problems Identified During Maintenance Rule Baseline Inspections

ML031050349
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	04/14/1997
From:	Martin T Office of Nuclear Reactor Regulation
To:
References
IN-97-018, NUDOCS 9704110050
Download: ML031050349 (11)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 April 14, 1997 NRC INFORMATION NOTICE 97-18: PROBLEMS IDENTIFIED DURING MAINTENANCE

RULE BASELINE INSPECTIONS

Addressees

All holders of operating licenses, construction permits, and decommissioning-stage licenses

for nuclear power reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert

addressees to the problems identified during the 10 CFR 50.65 (maintenance rule) baseline

inspections performed from July 1996 through February 1997. It is expected that recipients

will review the information for applicability to their facilities and consider actions, as

appropriate, to avoid similar problems. In addition, recipients are reminded that they are

required to take industry-wide operating experience (including NRC Information Notices) into

consideration, where practical, when setting goals and performing periodic evaluations under

the maintenance rule. Since suggestions contained in this information notice are not NRC

requirements, no specific action (other than those required by the maintenance rule) or

written response is required.

Background

The NRC published the maintenance rule on July 10, 1991, as Section 50.65, "Requirements

for monitoring the effectiveness of maintenance at nuclear power plants," of 10 CFR Part 50.

The rule became effective, after a five year implementation period, on July 10, 1996. The

rule requires licensees to monitor the effectiveness of maintenance activities for safety- significant plant equipment in order to minimize the likelihood of failures and other events

caused by lack of effective maintenance.

The nuclear industry developed a guideline for implementing the maintenance rule, formerly

Nuclear Management and Resources Council now known as Nuclear Energy Institute

(NUMARC) 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at

Nuclear Power Plants (May 1993)." Revision 2 to NUMARC 93-01 was issued in April 1996 to address lessons learned from pilot inspections performed at nine nuclear power plants. In

March 1997, the NRC issued Revision 2 to Regulatory Guide (RG) 1.160, "Monitoring the

Effectiveness of Maintenance at Nuclear Power Plants," which endorsed, with clarifications, NUMARC 93-01, Revision 2, as providing methods acceptable for complying with the

provisions of the rule.

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IN 97-18 April 14,1997

Description of Circumstances

To ensure the effective implementation of the maintenance rule, the NRC staff is in the

process of performing a baseline inspection at each licensed facility. These inspections

began in July 1996 and are expected to be completed In July 1998. Inspection findings from

the first 20 baseline inspections are discussed below; a list of the inspection reports that have

been issued to date Is provided In Attachment 1.

1. Failure To Include Emergency Lighting and Communications Systems In the Scope

of Rule

In 10 CFR 50.65(b) the regulations require that the scope of the maintenance rule include

nonsafety-related structures, systems, and components (SSCs) that are relied upon to

mitigate accidents or transients or that are used in plant emergency operating

procedures. On the basis of interviews of licensed plant operators at many sites, the

NRC staff determined that operators typically rely on various types of communications

systems (e.g., radios, telephones, public announcement equipment) when performing their

duties during an accident or transient. In addition, operators rely on the emergency

lighting system(s) to provide lighting to perform their accident or transient mitigation duties

on a loss of normal plant lighting. Despite this reliance, a number of licensees had

excluded emergency lighting and communications systems from the scope of the rule.

The NRC staff has Issued notices of violation to licensees for failing to include

communications system(s) equipment and emergency lighting system(s) within the scope

of the maintenance rule without adequate justification to show why the system(s) are not

relied upon during accident or transient conditions.

2. Failure To Establish Appropriate Reliability and Availability Goals and Performance

Criteria

Section 50.65(a)(1) requires that goals be established commensurate with safety.

NUMARC 93-01 provides methods acceptable to the NRC for meeting 10 CFR 50.65 (a)(1) and (a)(2) requirements. Using the NUMARC 93-01 guidance, performance criteria

that are used to demonstrate effective preventive maintenance for high safety signifi.cant

SSCs should be established to ensure that reliability and availability assumptions used in

plant-specific safety analyses are maintained or adjusted. Several licensees failed to

demonstrate that goals and performance criteria requirements were established

commensurate with safety. For example, several licensees established a single

performance criterion for reliability (e.g., number of maintenance preventable functional

failures [#MPFFs]/2 years) without an adequate technical basis. In some cases, when

compared to the number of demands, the number of MPFFs allowed would be indicative

of much lower reliability than the licensee assumed In its risk analysis. More specifically, licensees failed to demonstrate that the criterion preserved the assumptions defined by

plant-specific probabilistic risk assessments, individual plant examinations, or other risk

determining analyses. Also, several licensees failed to establish an availability

performance criterion for certain high safety significant SSCs.

IN 97-18 April 14,1997 Section 50.65(a)(3) requires balancing the reliability achieved through preventative

maintenance against the objective of minimizing unavailability. When establishing goals

and performance criteria under 10 CFR 50.65 (a)(1) and (a)(2) of the rule, some

licensees could not adequately perform that balancing because the reliability performance

criteria for some SSCs were inadequate or SSC availability performance criteria were not

established.

3. Failure To Adequately Assess Risk Prior to Taking SSCs Out of Service for

Monitoring or Preventive Maintenance

Section 50.65(a)(3) states, In part, that In performing monitoring and preventive

maintenance activities, an assessment of the total plant equipment that is out of service

should be taken Into account to determine the overall effect on performance of safety

functions. Several licensees' processes and programs were found to be weak in

assessing the safety Impact of removing equipment from service for maintenance or

monitoring.

a. At one facility several examples were Identified where the licensee underestimated the

risk associated with plant configurations established for performing on-line preventive

maintenance. For this facility, one unit was operating for extended periods with a

power operated relief valve block valve shut and a pressurizer spray valve out of

service. The licensee did not recognize that this configuration contributed to plant

risk. As a result, on several occasions, the increase in core damage frequency

associated with taking additional plant equipment out of service for maintenance was

significantly underestimated.

b. At other facilities, the licensees' processes for assessing safety Impact were weak.

Risk matrices and other risk assessment tools used by some licensee's for assessing

the acceptability of taking combinations of equipment out of service were too limited in

scope and in some instances, failed to include risk significant systems. Procedures

for using these risk assessment tools did not always provide sufficient guidance on

their limitations. In addition, personnel responsible for making these assessments

were not always knowledgeable of the limitations of these tools.

4. Failure to Include Decommissioning Stage Reactor SSCs Within the Scope of the

Maintenance Rule

As stated In Section 50.65(a)(1), the maintenance rule applies to "Each holder of a

license to operate a nuclear power plant under Sections 50.21(b) or 50.22." During the

Dresden Independent Safety Inspection 50-237/96-201; 50-249196-201 (Accession

Number 9612270052) the NRC inspectors identified that the licensee had Incorrectly

excluded from the scope of the rule certain Unit I SSCs that are required to ensure the

spent fuel is maintained in a safe condition. Although the licensee had established

appropriate surveillance activities for these SSCs, they had not established goals or

performance criteria as required by the rule. They believed that Unit I was no longer

considered an operating plant because it had been defueled and therefore did not come

under the scope of the rule. However, the NRC Inspectors confirmed that even though

IN 97-18 April 14, 1997 the Unit I license had been amended for possession only, i remained an operating

license under Section 104 of the Atomic Energy Act, as described in 10 CFR 50.21(b)

and, therefore; should have been included within the scope of the maintenance rule. The

failure to include certain Unit 1 SSCs within the scope of the rule was identified as a

deficiency.

The maintenance rule was amended effective on August 28, 1996 to clarify the

requirements for nuclear power plants that had decided to terminate their license.

Section 50.65(a)(1) now states that for a nuclear power plant for which the licensee has

submitted the certifications specified in Section 50.82(a)(1), this section shall apply only to

the extent that the licensee shall monitor the performance or condition of all SSCs

associated with the storage, control, and maintenance of spent fuel in a safe condition, in

a manner sufficient to provide reasonable assurance that such SSCs are capable of

performing their intended functions. These requirements include setting goals or

performance criteria for any SSCs required to maintain the spent fuel in a safe condition;

monitoring against those goals or performance criteria, and taking appropriate corrective

action when those goals are not met.

Discussion

In order to ensure industry-wide understanding, the staff has clarified these issues and others

In Revision 2 to RG 1.160. In addition, as part of its efforts to maintain effective

communication with the Industry and the public regarding the maintenance rule, the NRC

staff has developed a "Home Page" for the World Wide Web. The

Intent

of the home page is

to provide a comprehensive, up to date, resource of maintenance rule-related regulatory

documents, guidance documents, Inspection procedures, and inspection reports in a

searchable format. The NRC staff will make the Home Page publicly accessible after

prototype testing is complete.

This information notice requires no specific action or written response. If you have any

questions about the information In this notice, please contact one of the technical contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Thoma Mrtin, Director

Division of Reactor Program Marnagement

Office of Nuclear Reactor Regulation

Technical contacts: Donald R. Taylor, NRR Charles D. Petrone, NRR

(301) 416-8472 (301) 415-1027 E-mail: drt@nrc.gov E-mail: cdp@nrc.gov

Attachments:

1. List of Maintenance Baseline Inspection Reports

2. List of Recently Issued NRC Information Notices

A'c4~t Fied C4j1

Attachment 1 IN 97-18 April 14,1997 LIST OF MAINTENANCE BASELINE INSPECTION REPORTS

PLANT REPORT NO. DATE ISSUED ACCESSION NO.

Palo Verde Units 50-528/96-09 08121196 9608260100

1,2 & 3 50-529/96-09

50-330/96-09 Cooper Station 50-298/96-12 10107/96 9610150125 Peach Bottom 50-277/96-07 10/09196 9610210114 Units 2 & 3 50-278/96-07 St. Lucie 50-335196-13 10/16/96 9610310141 Units 1 & 2 50-389/96-13 D.C. Cook 50-315/96-09 11/14/96 9611220150

Units 1 & 2 50-316/96-09 Hatch Units 1 & 2 50-321/96-12 11/22/96 9612020162

50-366/96-12 Sequoyah I & 2 50-327/96-12 01/02/97 9701170016

50-328/96-12 Prairie Island Units 50-282/96-12 01/10/97 9701140119

1 &2 50-306/96-12 Nine Mile Point 50-220/96-12 01/15/97 9701240126 Unit 1 Perry Unit I 50-440/96-14 01/29/97 9702050111 Washington 50-397/96-18 01/29197 9702030185 Nuclear Project 2 Indian Point 3 50-286/96-80 02/14197 9702210210

Surry Units I & 2 50-280/97-01 02/20197 9702250357(ltr)

50-281/97-01 9702250362(rpt)

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Attachment 1 IN 97-18 April 14, 1997 LIST OF MAINTENANCE BASELINE INSPECTION REPORTS (CONT.)

PLAN' [ REPORT NO. DATE ISSUED ACCESSION NO.

Davis-l Besse Unit 1 50-346/97-02 03/06/97 9703110189 Catawba Units 1 &

2

50-413/97-01 03/20/97

• not available

Waterford Unit 3 50-414197-01

50-382/97-01 03/21197

• not available

• As of the date of this information notice, the inspection report had not been entered into the

NRC NUDOCS system.

I .

Attachment 2 IN 97-18 April 14, 1997 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

97-17 Cracking of Vertical 04/04/97 All holders of OLs

Welds in the Core or CPs for boiling- Shroud and Degraded water reactors

Repair

97-16 Preconditioning of 04/04/97 All holders of OLs

Plant Structures, or CPs for nuclear

Systems, and Components power reactors

Before ASME Code Inservice

Testing or Technical

Specification Surveillance

Testing

97-15 Reporting of Errors 04/04/97 All holders of OLs

and Changes in Large- or CPs for nuclear

Break Loss-of-Coolant power reactors and

Accident Evaluation all reactor fuel

Models of Fuel Vendors vendors

and Compliance with

10 CFR 50.46(a)(3)

97-14 Assessment of Spent 03/28/97 All holders of OLs

Fuel Pool Cooling or CPs for nuclear

power reactors

97-13 Deficient Conditions 03/24/97 All holders of OLs

Associated with Pro- or CPs for nuclear

tective Coatings at power reactors

Nuclear Power Plants

97-12 Potential Armature 03/24/97 All holders of OLs

Binding in General or CPs for nuclear

Electric Type HGA power reactors

Relays

OL - Operating License

CP = Construction Permit

_- IN 97-18 April 14, 1997 the Unit I license had been amended for possession only, it remained an operating

license under Section 104 of the Atomic Energy Act, as described in 10 CFR 50.21(b)

and, therefore; should have been included within the scope of the maintenance rule. The

failure to include certain Unit 1 SSCs within the scope of the rule was identified as a

deficiency.

The maintenance rule was amended effective on August 28, 1996 to clarify the

requirements for nuclear power plants that had decided to terminate their license.

Section 50.65(a)(1) now states that for a nuclear power plant for which the licensee has

submitted the certifications specified in Section 50.82(a)(1), this section shall apply only to

the extent that the licensee shall monitor the performance or condition of all SSCs

associated with the storage, control, and maintenance of spent fuel in a safe condition, In

a manner sufficient to provide reasonable assurance that such SSCs are capable of

performing their intended functions. These requirements include setting goals or

performance criteria for any SSCs required to maintain the spent fuel in a safe condition;

monitoring against those goals or performance criteria, and taking appropriate corrective

action when those goals are not met.

Discussion

In order to ensure industry-wide understanding, the staff has clarified these issues and others

in Revision 2 to RG 1.160. In addition, as part of its efforts to maintain effective

communication with the industry and the public regarding the maintenance rule, the NRC

staff has developed a "Home Page" for the World Wide Web. The intent of the home page is

to provide a comprehensive, up to date, resource of maintenance rule-related regulatory

documents, guidance documents, inspection procedures, and inspection reports in a

searchable format. The NRC staff will make the Home Page publicly accessible after

prototype testing is complete.

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact one of the technical contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

original signed by M.M. Slosson

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Donald R. Taylor, NRR Charles D. Petrone, NRR

(301) 415-8472 (301) 415-1027 E-mail: drt@nrc.gov E-mail: cdp@nrc.gov

Attachments:

1. List of Maintenance Baseline Inspection Reports

2. List of Recently Issued NRC Information Notices

DOCUMENT NAME: MR-IN.003 Tech Editor has reviewed & concurred on 03/18/97

• See previous concurrence OFFICIAL RECORD COPY

To receive a copy of this document, Indicate In the box: "C" = Copy without enclosures "E" = Copy with

enclosures "N" = No copy

OFFICE Tech Contacts I E HQMB/DRCH C:PECB:DRPM D:DRPM

NAME DTaylor* TM rti flAChaffee

CPetrone* i 1 RCorreia* _

DATE 03/18/97 03/18/97 03/27/97 0417197

IN97-xx

IN>

April , 1997 the Unit I license had been amended for possession only, it remained an operating

license under Section 104 of the Atomic Energy Act, as described in 10 CFR 50.21(b)

and, therefore; should have been included within the scope of the maintenance rule. The

failure to include certain Unit 1 SSCs within the scope of the rule was identified as a

deficiency.

The maintenance rule was amended effective on August 28, 1996 to clarify the

requirements for nuclear power plants that had decided to terminate their license.

Section 50.65(a)(1) now states that for a nuclear power plant for which the licensee has

submitted the certifications specified in Section 50.82(a)(1), this section shall apply only to

the extent that the licensee shall monitor the performance or condition of all SSCs

associated with the storage, control, and maintenance of spent fuel in a safe condition, In

a manner sufficient to provide reasonable assurance that such SSCs are capable of

performing their Intended functions. These requirements include setting goals or

performance criteria for any SSCs required to maintain the spent fuel in a safe condition;

monitoring against those goals or performance criteria, and taking appropriate corrective

action when those goals are not met.

Discussion

In order to ensure industry-wide understanding, the staff has clarified these issues and others

in Revision 2 to RG 1.160. In addition, as part of its efforts to maintain effective

communication with the industry and the public regarding the maintenance rule, the NRC

staff has developed a "Home Page" for the World Wide Web. The intent of the home page is

to provide a comprehensive, up to date, resource of maintenance rule-related regulatory

documents, guidance documents, inspection procedures, and inspection reports in a

searchable format. The NRC staff will make the Home Page publicly accessible after

prototype testing is complete.

This information notice requires no specific action or wntten response. If you have any

questions about the information in this notice, please contact one of the technical contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Donald R. Taylor, NRR Charles D. Petrone, NRR

(301) 415-8472 (301) 415-1027 E-mail: drt~nrc.gov E-mail: cdp~nrc.gov

Attachments:

1. List of Maintenance Baseline Inspection Reports

2. List of Recently Issued NRC Information Notices

DOCUMENT NAME: MR-IN.0OofA

• See previous concurrence

To receive a copy of this document, Indicate In the box: "C" = Copy without enclosures "E" = Copy with

enclosures "N" = No copy

OFFICE Tech Contacts E HQMB/DRCH C:PECB:DRPM D:DRPM l

NAME DTaylor* SBlack* AChaffee* TMartin -

CPetrone*

RCorreia*

DATE 03/18/97 03/18/97 103O27/97 1041 /97 OFFICIAL RECO

K>

IN 97-xx

March xx, 1997 This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact the technical contacts listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Donald R. Taylor, NRR Charles D. Petrone

(310) 415-8472 (310) 415-1027 E-mail: drt@nrc.gov E-mail: cdp@nrc.gov

Attachments:

1. List of Maintenance Baseline Inpection Reports

2. List of Recently Issued Information Notices

DOCUMENT NAME: MR-IN.002

• See previous concurrence

To receive a copy of this document, Indicate In the box: "C" = Copy without enclosures "E" = Copy with

enclosures "N" = No copy

• OFFICE Tehontacts HQMBIDRCH lE IIIIII

NAME DTaylor* SBlack* AChaffee TMartin l

CPetroneQ i , _

l ~~RCorreia* Xl

DATE 03/18197 tjo 03/18/97 I3 L97 03/ /97 OFFICIAL RECORD COPY

• C4 K'

IN 97-xx

March xx, 1997 This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact the technical contacts listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Donald R. Taylor, NRR Charles D. Petrone

(310) 415-8472 (310) 415-1027 E-mail: drtenrc.gov E-mail: cdp@nrc.gov

Attachment: List of Recently Issued Information Notices

DOCUMENT NAME: MR-IN.002 To receive a copy of this document, Indicate In the box: "C" Copy without enclosures "E" = Copy with

enclosures "N" = No copy

OFFICE Tech Contacts 1, HQMB/DRCH E

NAME DTaylor Wr SBlack AChaffee TMartin

CPetronq4'

RCorreia (rt- DATE 0310/97 031i8197 03/ /97 03/ /97 OFFICIAL RECORD COPY

dg -1 elh.