Information Notice 1997-18, Problems Identified During Maintenance Rule Baseline Inspections
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
April 14,1997 LIST OF MAINTENANCE
PLANT
Palo Verde Units
1,2 & 3
Cooper Station
Peach Bottom
Units 2 & 3 St. Lucie
Units 1 & 2 D.C. Cook
Units 1 & 2 Hatch Units 1 & 2 Sequoyah I & 2
Prairie Island Units
1 &2
Nine Mile Point
Unit 1
Perry Unit I
Nuclear Project 2
Indian Point 3 Surry Units I & 2
BASELINE INSPECTION REPORTS
REPORT NO.
DATE ISSUED
50-528/96-09
08121196
50-529/96-09
50-330/96-09
50-298/96-12
10107/96
50-277/96-07
10/09196
50-278/96-07
50-335196-13
10/16/96
50-389/96-13
50-315/96-09
11/14/96
50-316/96-09
50-321/96-12
11/22/96
50-366/96-12
50-327/96-12
01/02/97
50-328/96-12
50-282/96-12
01/10/97
50-306/96-12
50-220/96-12
01/15/97
50-440/96-14
01/29/97
50-397/96-18
01/29197
50-286/96-80
02/14197
50-280/97-01
02/20197
50-281/97-01 ACCESSION NO.
9608260100
9610150125
9610210114
9610310141
9611220150
9612020162
9701170016
9701140119
9701240126
9702050111
9702030185
9702210210
9702250357(ltr)
9702250362(rpt)
K>
LIST OF MAINTENANCE BASELINE
[
REPORT NO.
Besse Unit 1
50-346/97-02
Attachment 1
IN 97-18 April 14, 1997 INSPECTION REPORTS (CONT.)
DATE ISSUED
ACCESSION NO.
03/06/97
9703110189 PLAN'
Davis-l
Catawba Units 1 &
2
Waterford Unit 3
50-413/97-01
50-414197-01
50-382/97-01
03/20/97
03/21197
- not available
- 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
April 14, 1997 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
97-17
Cracking of Vertical
Welds in the Core
Shroud and Degraded
Repair
04/04/97
All holders of OLs
or CPs for boiling- water reactors
97-16
Preconditioning of
Plant Structures,
Systems, and Components
Before ASME Code Inservice
Testing or Technical
Specification Surveillance
Testing
04/04/97
All holders of OLs
or CPs for nuclear
power reactors
97-15
97-14
97-13
97-12
Reporting of Errors
and Changes in Large- Break Loss-of-Coolant
Accident Evaluation
Models of Fuel Vendors
and Compliance with
Assessment of Spent
Fuel Pool Cooling
Deficient Conditions
Associated with Pro- tective Coatings at
Nuclear Power Plants
Potential Armature
Binding in General
Electric Type HGA
Relays
04/04/97
03/28/97
03/24/97
03/24/97
All holders of OLs
or CPs for nuclear
power reactors and
all reactor fuel
vendors
All holders of OLs
or CPs for nuclear
power reactors
All holders of OLs
or CPs for nuclear
power reactors
All holders of OLs
or CPs for nuclear
power reactors
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*
flAChaffee
TM rti
CPetrone*
i
1 RCorreia*
_
DATE
03/18/97
03/18/97
03/27/97
0417197
IN>
IN97-xx
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
(310) 415-8472 E-mail: drt@nrc.gov
Charles D. Petrone
(310) 415-1027 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 Teh ontacts
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
(310) 415-8472 E-mail: drtenrc.gov
Charles D. Petrone
(310) 415-1027 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.