ML17058B632
| ML17058B632 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/19/1988 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML17056C371 | List:
|
| References | |
| CON-IIT07-776-91, CON-IIT7-776-91 NUREG-1455, NUDOCS 9305070244 | |
| Download: ML17058B632 (14) | |
Text
N 0 T A T I 0 N
VOTE
RESPONSE
SHEET cc:
Stel 1 o Taylor FYI:
FROM:
SAMUEL J, CH I L Ki SECRETARY OF THE COMMISSION COMMISSIONER
- CARP, TRehm
SUBJECT:
SECY-87-3 1 tI -
INTERIM POL I CY STATEMENT ON MAINTENANCE OF NUCLEAR POKER PLANTS
~ 4>
APPROVED~
c <~Hsmp D I SAPPROVED NOT PARTICIPATING ABSTAIN REQUEST D I SCUSS ION CONYiENTS: C~n~on+D) 9305070244 9ii03i PDR noaCX OS0004iO PD,R YES NO DATE S IGNATURE
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Ceanissioner Carr's conments on SECY-8 -314 2.
3.
4 ~
6.
I approve staff's recommendations to issue a Policy Statement on Maintenance.
However, I would modify the staff's proposal as reflected in the attached draft Polic Sta me t.
I propose we issue this Policy Statement as a final, not interim, Policy.
I, for one, do not see the need for public cerement on the issuance of this Policy, but would welcome it during subsequent rulemaking.
My proposed Policy deletes any reference to a two year trial period to assess industry initiatives.
I beIieve a rule is necessary in this important area regardless of industry initiatives in place at present.
I am confident that a rule can be developed that spells out this agency's expectations in maintenance within the framework of the attached Policy, yet sti11 encourages industry initiatives to achieve excellence.
I propose we direct staff to develop a notice of proposed ru1emaking for Comaission review no later than August I, 1988.
In doing so, staff should work closely with NUNRC, should consider maintenance approaches in other countries, and should review practices in other industries and regulatory bodies in this country that place a heavy reliance on equipment reliability and availability.
Mhile I value the advice of the ACRS, in this instance I would not delay issuance of the Policy for their formal review, estimated to be in mid-February.
Instead, staff should periodically brief the ACRS and seek their input during the development of the rule.
Additionally, I would ask SECY to work closely with the EDO and the ACRS staff in scheduling Comnission review of major issues such as this so that sufficient time is available for ACRS input.
The attached proposed Policy is silent on the subject of s
at ff maintenance inspections.
awhile I continue to.believe that inspections over the next two years of maintenance programs in place t 75 p rcent of the utilities is unnecessary, staff should nonetheless continue to assign inspection resources to those plants nee g
p din hei in this area.
Additionally, I would encourage staff to conduct other
- visits, as necessary, to gain information for development of the rule.
Finally, it was mentioned at the meeting that serious consideration was being given to the use of LER cause codes as a maintenance performance indicator.
I do not believe this indicator would be useful since it is subjective and subject to data manipulation.
I would urge staff to continue their efforts to develop maintenance indicators that are more quantifiable and meaningful.
POLICY
Background
The Ccemission has a program to continu y
nuall evaluate the operational 1 nts.
Analysis of operational events has performance of nuclear power p an s.
shown that, n som h
i some cases nuclear power 'plant eq pm ui ent is not being maintained at a leve w
c e
1 hi h ensures, with a high degree of reliability, that the equipment w>
per orm t
ll perform its intended function when required.
A limited NRC examlna on o
ti f nuclear power plant maintenance programs has found a wide variation n
e e f
th ffectiveness of these programs.
Inadequate maintenance at some p an s
as 1 t h
been a significant contributor to plant reliability problems
- and, hence, is of safe y afet concern.
The Comission believes there is a nee o
mpr d t i rove safety by improving the effectiveness of maintenance pr ograms roug th hout the nuclear industry.
The Coamission is procee ng w>
di th rulemaking consistent with this belief.
This pol icy his time to provide guidance to the industry statement is being issued at t s
me while the rulemaking proceeds.
'olicy Statement It is the obqec ve o bq ti of the Conmission that all components, systems and structures of nuc ear powe f
1 power plants be maintained so that plant equipment to accomplish will perform its n en e
u i t d d f nction when required.
In order t
this objective, eac h licensee should develop and implement a maintenance program which provi es or e
d f
th availability, periodic evaluation, and prompt repair o p an f
1 t components,
- systems, and structures.
Definition of Maintenance f those functions The Commission defines maintenance as the aggregate of t aimed at preserving or restoring safety, relia y,
bilft and availability of s.
As such, maintenance includes plant structures,
- systems, and components.
not only ac v
e ti ities traditionally associated with identifying and correcting actual or po en 1
t tial degraded conditions, i.e., repair, surveillance, diagnostic examinations, and preventi e
n ive measures; but extends to include all supporting functions for the conduct nduct of these activities.
These activities and unc ons r
f ti are developed below under "Activities Mh'>ch Form the Basis of a Maintenance Program".
Maintenance Programs Each commercial nuclear power plant should develop and implement a
activities well-defined an e
ec d ff tive program to assure that maintenance are conducted to preserve or restore the availabili yt and reliability of plant structures,
- systems, and components.
p g
The ro ram should clearly define the components and activities include d
as well as the requirements
0 0
t 1 those activities.
Further, the program of the program used to con ro o
effectiveness and a method to should include provisions to evaluate e
rrective action.
feedback the results o
a pr f th t rogram to ensure effective corre Activities c
o Mhi h Form the Basis of a Maintenance Program An adequate program should consider:
o Technology in the areas of corrective maintenance, preventive maintenance, predictive maintenance, surveillance; Engineering support and plant modifications; equality assurance and quality control; Equipment history and trending; Maintenance records; Management of parts, tools, and facilities; o
Procedures; Post-maintenance tes ing t'n and return-to-service activities;
o Maintenance management and organizatio n in the areas of
- planning, scheduling,
- staffing, shift coverage, resource allocation; Control of contracted maintenance services; Radiological exposure control
{ALARA);
Personnel qualification and training; Interface w>
p an th 1
t operations and plant support groups; and Interface with plant and corporate management.
Maintenance recoaeendations or requirement s of individual vendors should receive appropriate attention in the deve pm elo ent of the maintenance program.
Future Coamission Action The Coamission nten s
i d
th s policy statement to provide interim for their power guidance to the in us ry d t in improving maintenance programs fo Th Coamission will continue to enforce existing reactor facil'ities.
e oamiss requirements a
a th t ddress maintenance practices and will take whatever action that may e necess b
cessary to protect health and safety.
blish a Notice of Proposed Rulemaking The Commission expects to pu is a
ablish basic requirements for plant in the near future that would esta s
a e believe that the contents and bounds of the maintenance programs.
Me e
eve ithin the general framework describe
'bed in this proposed rule will fall wit n
e po the industry and other interested persons policy statement.
Me encourage e
n this important subject to the Coneission, even to provide their views on is in rocess.
Any notice of proposed at this early stage of the rulemak ng pr e
a eriod for public rulemaking that is published will provide, of course, p
convent on its contents.