ML18041A183

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Informs Commission of Options That Staff Is Considering for Discussion at 880711-13 Workshop on Proposed Rulemaking for Maint of Nuclear Power Plant & Provide Draft Rule for Preferred Option for Commission Consideration
ML18041A183
Person / Time
Issue date: 06/27/1988
From: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Carr, Roberts, Zech
NRC COMMISSION (OCM)
References
CON-IIT07-776-91, CON-IIT7-776-91, FRN-53FR25169, FRN-53FR47822, FRN-53FR9430 AD-1-11, AD00-1-11, NUREG-1455, NUDOCS 8807120551
Download: ML18041A183 (36)


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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 JUN 27 ]g88 MEMORANDUM FOR:

FROM:

SUBJECT:

Chairman Zech Comissioner Roberts Commissioner Carr CoIImIissioner Rogers Victor Stello, Jr., Executive Director for Operations PROPOSED RULEHAKING FOR THE MAINTENANCE OF NUCLEAR POWER PLANTS The purpose of this memorandum is to (1) inform the Commission of the options that the staff is considering for discussion at the July 11-13, 1988 workshop on the proposed rulemaking for the maintenance of nuclear power plants, (2) provide a draft rule for the preferred option for Commission consideration and (3) summarize the changes in our plans (as reported in SECY-88-142) to meet the Commission's desired schedule for the rulemaking effort.

Backcaround On May 23, 1988, the staff submitted to the Commission its proposed "Staff Plan and Schedule for Proposed Rulemaking for the Maintenance of Nuclear Power Plants" in SECY-88-142.

The plan and schedule was developed in response to the Commission's direction (in memorandum Chi 1k to Stello, dated 2/25/88, M880107) for the staff to develop a proposed rulemaking on the subject.

The Commission disapproved (in memorandum Chi 1k to Stello, dated 6/17/88, H8800281) the staff's schedule to prepare a proposed rule and indicated that some of the activities presently scheduled as "front-end" could be treated as confirmatory "back-end" activities, thereby reducing the schedule.

A Notice of Proposed Rulemaking was requested by October 3, 1988.

The staff received further Commission direction (in memorandum Chilk to Stello, dated 6/17/88, COMKC-88-03) to develop a preferred maintenance rulemaking option (requiring licensee's to track certain maintenance performance indicators) which should be the focus of the NRC Public Workshop for Maintenance Rulemaking on July 11-13, 1988.

This paper describes the rulemaking options being considered by the staff, including a "Strawman" maintenance rule for the preferred option, and responds to the Commission's direction to accelerate the schedule.

Discussion The staff has developed five rulemaking options within the general framework of the Final Commission Policy Statement on Maintenance of Nuclear Power Plants for the purpose of discussion at the July 11-13, 1988 workshop on the maintenance rulemaking.

Chairman Zech and Commissioners 2

These options fall into two main categories.

The objective of the options in the first category is to emphasize reporting measures of the effectiveness of maintenance

programs, whereas the options in the second category provide more detailed requirements on the content of a maintenance
program, as well as addressing measures of effectiveness.

A process highlighting key decisions that lead to the five options is presented along with a description of the options and a qualitative assessment of the impact they would have on NRC and industry resources and on industry initiatives.

Based on results of assessments to date in the rulemaking effort, a set of factors the staff considers important in selecting the desired option are presented.

A "Strawman" rule for the preferred Commission option is also presented and it is our intent to emphasize and focus detailed discussion on this option 'at the workshop.

Rul ema kin 0 tions The enclosed "Decision Chart for Determining Rulemaking Options" (Enclosure 1) shows the key decisions and the resulting rulemaking options.

In addition, there are other considerations required for determining the exact nature of the options.

These are discussed later and are not included in the Chart, which shows for clarity only the key decisions.

The enclosed "Table on Characteristics of Yiaintenance Rulemaking Options" (Enclosure

2) indicates the relationship of a rule, Reg.

Guide or industry standard in the various rulemaking options, the mechanism for verifying compliance and a qualitative assessment of the costs to the licensee and the NRC.

The options are summarized below.

They vary in scope and in the degree of prescription.

In general, the scope and the degree of prescription increases from Option 1 to Option 5.

I)

Performance Based 0 tions Performance based rulemaking options are based on a decision to address, only in a general fashion, the implementation of a maintenance program with specific emphasis in the rule on reporting the measures of the effectiveness of the program.

0 tion 1-General Performance Based Rule Option 1 consists of a general rule which would require each licensee to have an effective and documented maintenance program, to establish measures to evaluate and improve the effectiveness of his maintenance program and to report periodically on its effectiveness.

A Reg.

Guide would provide guidance on acceptable methods for measuring the effectiveness of maintenance programs;

however, each licensee could establish a measuring and reporting program he considers acceptable.

Based on review of the information provided by licensees, inspections could be conducted on plants that are judged to be performing poor ly.

Since the measures of performance are provided in a Reg.

Guide as guidance, there may b'e a large variation in the type of data reported to the NRC.

p II

Chairman Zech and Commissioners 3

The Commission has indicated (in memorandum from Chi 1k to Stello, dated 6/17/88, CONKC-88-03) preference for a rule which would require licensees to track certain defined maintenance performance indicators and directed the staff to focus the July 11-13, 1988 Public Workshop on the preferred rulemaking option.

The staff believes that Option 1 is the best choice to satisfy the Commission'.s desire for a preferred option.

A "Strawman" rule for Option 1 is provided in Enclosure 3, along with a set of maintenance performance indicators (HPIs) and definitions which could form the basis for a Reg.

Guide.

The set of NPIs provides a starting point for discussions at the public workshop to determine the adequacy of the indicators and to delete or add other NPIs to the set.

However, validation of the HPIs is needed prior to issuing the final Reg. Guide.

0 tion 2-Prescri tive Performance Based Rule Option 2 is similar to Option 1, except that it would specifically list the measures of effectiveness of a maintenance program to be reported to NRC. It would not specify numerical thresholds that have to be met but, similar to Option 1, would require a licensee to have as part of his program a means to feed back results to improve maintenance, where appropriate.

Similar to that for Option 1, inspections could be conducted at plants that report data indicating poor performance.

The prescriptive nature of the rule would assure uniformity in the measures reported to the NRC.

However, since the measures would be codified into regulation, changes in reporting would require a change to the rule.

II)

Pro ram Element Based 0 tions The Policy Statement on the Haintenance of Nuclear Power Plants lists various activities which the Commission views as being necessary in a plant maintenance program.

The following options could address some or all of these activities.

The degree of prescription of the details of the maintenance activities increases from Option 3 to Option 5.

0 tion 3-General Rule/Industr Standard In this option, a general rule would require a utility to establish, document and implement a maintenance program.

The activities listed in the Policy Statement would be mentioned in the rule in a general sense as items which the maintenance program should address, but would not prescribe by regulation the manner and the extent to which these activities are conducted.

In this option, a Reg.

Guide would be developed to provide guidance to industry for the timely development of an industry standard which the Commission would review and endorse.

This approach is simi lar to the one adopted by the Federal Aviation Administration (FAA) and would provide some degree of standardization to utility maintenance practices.

This could be attractive in light of the Commission's emphasis on standardization.

The FAA certifies a maintenance program for each type of aircraft.

Chairman Zech and Commissioners 4

The licensee maintenance program developed in accordance with the regulation and industry standard would not be made part of the FSAR or operating license but rather would only be required to be available for inspection by the Regions.

0 tion 4-General Rule/Re

. Guide The regulatory approach in this option is similar to that for Option 3, except no industry standard would be required.

Each licensee would be responsible for developing its own maintenance program using the Reg.

Guide, as appropriate.

The Reg.

Guide would be developed to provide the scope and methods for the conduct of the maintenance activities.

The results of research in the Nuclear Power Plant Aging Research program could p'rovide some information towards the development of the Reg.

Guide.

As for Option 3, the licensee maintenance program developed in accordance with the rule and Reg.

Guide would not be made part of the FSAR or operating license but rather would only be required to be available for inspection by the Regions.

0 tion 5-Prescri tive Rule This option would prescribe, via a detai led rule, the objectives and requirements for the conduct of the maintenance activities listed in the Policy Statement.

The Japanese follow a similar approach (mandatory annual scheduled outages);

however, their regulatory environment permits industry initiatives and flexibility in the conduct of the maintenance activities.

The scope and level of prescription in the rule in this option could vary.

Specifically, the rule could be applicable to each licensee individually or could require the standardization of maintenance activities across the industry, including the establishment of a central organization to facilitate uniformity in the conduct, quality and feedback of maintenance information. This latter approach would most closely parallel that used by the U.S.

Navy.

Im act of 0 tions on NRC and Industr Resources The resources required (both NRC and industry) for developing and implementing the rules and supporting documents will generally increase in going from Option 1 to Option 5.

The performance based rules (Options 1 and 2) will require only limited NRC and industry resources as a result of the 1imited scope of the rules.

These rules will require licensees to report data for NRC review.

NRC inspection of licensee maintenance programs would be carried out based on the review of the data provided by the licensees.

The rules in Options 3, 4, and 5 will be more specific on the content of a maintenance program and, therefore, could demand more resources than Option 1

or 2.

Among the program element based options, Option 3 will require the least amount of NRC resources.

Option 3 will require industry resources to develop an industry standard.

However, since the effort for developing an industry standard will be distributed among industry organizations, the impact on each individual organization could be small.

Chairman Zech and Commissioners 5

I Im act of Rulemakin 0 tions on Industr Initiatives 4

Industry initiatives could continue no matter which approach is taken by the NRC.

However, past experience has shown that the initiatives may decrease with the degree of prescription in NRC regulations.

Thus impact on industry initiatives would most likely increase in going from Option 1 to Option 5.

The performance based rules (Option 1 and 2) should have the least impact on industry initiatives.

However, care must be taken to ensure that NRC specified performance indicators do not cause industry initiatives or licensee maintenance programs to be manipulated for the purpose of optimizing the information to be reported.

Industry initiatives could be steered towards an industry standard for Option 3.

Options 4 and 5, which prescribe the conduct of maintenance activities or provide more detailed NRC guidance, could affect the initiatives taken by the industry to improve plant maintenance.

Factors Im ortant in the Selection of a Maintenance Rulemakin 0 tion From the work done to date in reviewing industry initiatives, reviewing maintenance practices in other industries and countries and developing the above options, certain factors have stood out as important considerations which the staff believes should be used to help guide the decision process in selecting a final option.

Specifically, the factors which the staff believes the option should meet are:

'hould not divert or hinder good industry initiatives directed toward improving maintenance:

- maintain/promote industry responsibility (ownership) for problem identification, resolution and monitoring

- state objectives, not prescribe solutions.

'hould not require submission of documents or information that NRC does not plan to review.

'hould have provision to measure overall program effectiveness and ensure feedback of results to improve the program.

The preferred option satisfies the above factors.

Schedule In the memorandum Chi 1k to Stello, dated 6/17/88, (M880281), the Commission directed the staff to provide a Notice of Proposed Rulemaking to the Commission

Chairman Zech and Commissioners 6

by October 3, 1988.

In order to do this, certain items planned for completion prior to providing the Notice of Proposed Rulemaking have been rescheduled to be completed in parallel with completion of the final rule.

Chief among these are:

1) final reports on aviation and foreign country maintenance programs and practices, 2) all work on a supporting NUREG documenting development of the rule, 3) completion of a final draft of the Reg.

Guide to accompany the rule (however, sufficient information will be provided along with the proposed rule to provide the basis for developing a Reg.

Guide) and 4) final validation of any MPIs.

As requested, the Notice of Proposed Rulemaking package to be provided by October 3, 1988, will discuss the schedule to complete the rulemaking.

In conclusion, the staff is currently evaluating the above rulemaking options.

The options and "Strawman" Rule for Option 1 described herein are being provided to the Commission for information and feedback (on an individual basis) prior to our conducting the Maintenance Rule Workshop on July 11-13, 1988.

The workshop will concentrate on soliciting discussion and feedback on the preferred option, but will present the other options as well.

Subsequent to the workshop, I plan to provide you with a briefing on the comments received from the public and regulated industry on the preferred rulemaking option and the other options discussed at the workshop.

To facilitate discussion at the workshop, this memorandum is being placed in the PDR to be available for participants prior to the workshop.

Enclosures:

1.

Decision Chart for Maintenance Rulemaking Options 2.

Characteristics of Maintenance Rulemaking Options 3.

"Strawman" Rule for the Maintenance of Nuclear Power Plants ctor Ste

'o, Jr.

Executive Director for Operations

E irman Zech and Commissioners r

by October 3, 1988.

In order to do this, certain items planned for completion prior to providing the Notice of Proposed Rulemaking have been rescheduled to be completed in parallel with completion of the final rule.

Chief among these are:

1) final reports on aviation and foreign country maintenance programs and practices, 2) all work on a supporting NUREG documenting development of the rule, 3) completion of a final draft of the Reg.

Guide to accompany the rule (however, sufficient information will be provided along with the proposed rule to provide the basis for developing a Reg.

Guide) and 4) final validation of any MPIs.

As requested, the Notice of Proposed Rulemaki'ng package to be provided by October 3, 1988, will discuss the schedule to complete the rulemaking.

In conclusion, the staff is currently evaluating the above rulemaking options.

The options and "Strawman" Rule.for Option 1 described herein are being provided o the Commission for information and feedback (on an individual basis) prior our conducting the Maintenance Rule Horkshop on July 11-13, 1988.

The workshop ll concentrate on soliciting discussion and feedback on the preferred option,

~t will present the other options as well.

Subsequent to the workshop, I plan to provide you with a briefing on the comments received from the public and regulated industry on the preferred rulemaking option and the other options discussed at the workshop.

To facilitate discussion at the workshop, this memorandum is being placed in the PDR to be available for participants prior to the workshop.

Enclosures:

1.

Decision Chart for Maintenance Rulemaking Options 2.

Characteristi cs of Maintenance Rulema king Options 3.

"Strawman" Rule for the Maintenance oa8s~<<<~'"'ictor Stello, Jr.

Executive Director for Operations of Nuclear Power Plants See attached a

e for Distributio

  • See attached sheet for previous concurrences.

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Decision Chart for Haintenance Rulemakin 0 tions Ho Define measures in Reg.

Guide 0 tion I Genera er ormance Based Rule Heasures of overall program effectiveness Should the rule prescribe the measures?

~gtion 2

Prescriptive Performance Based Rule What activities listed in Policy Statement should be addressed in the rule?

.Yes Yes Yes Should a Reg.

Guide only provide guidance for an industry standard?

No

~gtion 3

General Rule/Industry Standard (FAA approach)

All activities Should the rule only functionally group and list the activities?

No Develop rule defining requirements for activities Oevelop Reg.~

~gtion 4

Gui de( s)

General Rule/Reg.

Guide

~tion 5

Prescriptive Rule (Japanese/Navy approach)

Characteristid intenance Rulemakixg Options F E2 Rule R~e.

Guide Compliance Yerification romote Potentia I Standardized Impact on Industry Haint. Pract.

Initiatives Cost to Licensee Cost to NRC Comnents Option I (HPI)

General Yes-guidance on acceptable HP I s.

Report info.

to NRC.

NRC

audit, as needed No small (if right indicators) chosen) sma I I small Each licensee could select approp.

HPIs Option 2 (HP I)

Prescriptive Yes-guidance on how to calculate MP Is Report info.

to NRC.

NRC

audit, as needed No small (if right indicators chosen) small small Promotes standardized reporting Option 3 (Ind Std)

General Yes-general guidance on content of industry std.

NRC audit, as needed Yes sma I I (uses industry standard) moderate variable Similar to FAA approach.

Promotes standardized industry practices.

Option 4 (Reg. Guide)

General Yes-detailed guidance NCR audit, as needed No sma I I moderate variable Each licensee would have flexibility to develop his own program.

Option 5 (Rule)

Prescriptive No NRC audit, as needed Yes large large variable Similar to Japanese and U.S.

Navy approach.

Navy approach would result in maximum standardization of maintenance practices across industry

(7590-01)

Enclosure "3"

Proposed Amendment

'f 10 CFR 50.75 "Strawman" Rule for the Haintenance of Nuclear Power Plants Enclosure

(7590-01)

NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Improvement of the Effectiveness of Maintenance Programs for Nuclear Power Plants AGENCY:

Nuclear Regulatory Commission ACTION:

Draft proposed rule

SUMMARY

The Commission is proposing to amend its regulations to require strengthening of the maintenance activities in nuclear power plants to reduce the likelihood of failures and events caused by the lack of effective maintenance.

The Commission believes safety can be enhanced by improving the effectiveness of maintenance programs throughout the nuclear industry.

The draft proposed rule requires the implementation of an effective and documented maintenance

program, including reporting of information on measures and indicators of the effectiveness of the program, and feedback of results to ensure improvement, where appropriate.

Guidance on acceptable measures and indicators of effectiveness of maintenance programs will be provided via a Reg.

Guide.

EFFECTIVE DATE:

FOR FURTHER INFORMATION CONTACT:

Moni Dey, Office of Nuclear Regulatory

Research, U.S. Nuclear Regulatory Commission, Mashington, D.C.
20555, (301) 492-3730..

Enclosure

(7590-01)

SUPPLEMENTARY INFORMATION:

On March 23,

1988, the Commission published a final Policy Statement on Maintenance of Nuclear Power Plants.

In the Policy Statement, the Commission stated that it expected to publish a

Notice of Proposed Rulemaking in the near future and provided the general framework for the proposed rule.

The Commission has a program to continually evaluate the operational performance of nuclear power plants.

Analysis of operational events has shown that, in some cases, nuclear power plant equipment is not being maintained at a level which it could be to ensure that the equipment will perform, with a high degree of reliability, its intended function when required.

A limited NRC examination of nuclear power plant maintenance programs has found a wide variation in the effectiveness of these programs.

At some plants maintenance has been a significant contributor to plant reliability problems and hence, is of. safety concern.

The Commission believes safety can be enhanced by strengthening the effectiveness of maintenance programs throughout the nuclear industry and, accordingly, this is the objective of this proposed rule.

It is the objective of the Commission that all components, systems and structures of nuclear power plants be effectively maintained so that plant equjpment will perform its intended function when required.

To accomplish this objective, each commercial nuclear power plant should develop and implement a well-defined and effective program to assure that maintenance activities are conducted to preserve or restore, with prompt

repair, the availability, performance and reliability of plant structures,
systems, and components.

The program should clearly define the components and activities included, as well as the management systems used to control those activities.

Further, the program should include feedback of specific results to ensure corrective actions, provisions for overall program evaluation, and the identification of possible component or system design problems.

Finally, the program should include indicators related to measuring effective maintenance.

A set of candidate maintenance performance indicators (MPIs) has been included as an appendix.

The set of MPIs is Enclosure

jl

(7590-01) expected to be modified as experience is gained.

The staff expects to issue a Regulatory Guide to provide guidance to the industry as an acceptable way of satisfying the rule.

PART 50 - DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES 1.

The Authority citation for Part 50 continues to read as follows:

Authority:

Secs. 103.

104, 161,
182, 183,
186, 189, 68 Stat.
936, 837, 948, 953, 954, 955,
956, as
amended, Secs.
234, 83 Stat.
1244, as amended (42 U.S.C.
2133, 2134,
2201, 2232,
2233, 2236,
2239, 2282); Secs.
201, 202, 206, 88 Stat.
1242, 1246, as amended (42 U.S.C.)
5841, 5842, 5846), unless otherwise noted.

Section 50.7 also issued under Pub. L.:

95-601, Sec.

10, 92 Stat.

2951 (42 U.S.C.

5851).

Sections 50.58, 50.91 and 50.92 also issued under Pub.

L.97-415, 96 Stat.

2073 (42 U.S.C. 2239).

Section 50.78 also issued under Sec.

122, 68 Stat.

939 (42 U.S.C. 2152).

Sections 50.80-50.81 also issued under Sec.

184, 68 Stat.
954, as amended (42 U.S.C.

2234).

Sections 50.100-50.102 also issued under Sec.

186, 68 Stat.

955 (42 U.S.C. 2236).

For the purposes of Sec.

223, 68 Stat.
958, as amended (42 U.S.C.

2273);

5 50.10(a), (b), and (c) 50.44, 50.46, 50.48 and 50.80(a) are issued under Sec.

161b, 68 Stat.
948, as amended (42 U.S.C.

2201(b));

55 50.10(b) and (c) and 50.54 are issued under Sec.

161i, 68, stat.
949, as amended (42 U.S.C. 2201(i)); and 55 50.55(e),

50.59(b),

50.70, 50.71, 50.72, and 50.78 are issued under Sec.

161o, 68 Stat.
950, as amended (42 U.S.C. 2201(o)).

2.

A new 5 50.75 is added to read as follows:

5 50.75 Requirements for improving the effectiveness of maintenance programs for nuclear power plants.

Enclosure

(7590-01)

A~li bill Th 0 i f

I i i

pptg nuclear power plants.

(b)

Definition.

For the purpose of this section, the Commission defines maintenance as the aggregate of those functions required to preserve and promptly restore safety, reliability, and availability of plant structures,

systems, and components.

Maintenance includes not only activities traditionally associated with identifying and correcting actual or potential degraded conditions. i.e., repair, surveillance, diagnosti c examinations, and preventive measures; but extends to all supporting functions for the conduct of these activities.

These activities and functions are listed below:

Technology in the areas of Corrective maintenance, Preventive maintenance, Predictive maintenance, Surveillance; Engineering support and plant modifications; guality assurance and quality control; Equipment history and trending; Maintenance records; Management of parts, tools, and facilities; Procedures; Post-Maintenance testing and return-to-service activities; Enclosure

(7590-01)

Measures of overall program effectiveness; Maintenance management and organization in the areas of

Planning, Scheduling,
Staffing, Shift coverage, Resource allocation; Control of contracted maintenance services; Radiological exposure control (ALARA);

Personnel qualification and training; Internal communications between the maintenance organization and plant operations and support groups; Communications between plant and corporate management and the maintenance organization; Maintenance recommendations or requirements of individual vendors.

Each holder of an operating license for a nuclear power plant (licensee) shall (1) maintain and implement an effective and documented maintenance

program, (2) measure the effectiveness of the maintenance program and, based upon this measure, improve maintenance where appropriate, and (3) submit quarterly to the Commission a Maintenance Performance Report (MPR) which shall include data for the indicators of the effectiveness of the maintenance program.

Each licensee shall develop an appropriate Enclosure

I(

k)

(7590-01) set of indicators of effectiveness which address the following functions:

Overall Plant Performance Related to Maintenance (ii)

Management Support of Maintenance (iii)

Maintenance Implementation (dj ~I1 i

y [

d 3

h f

h ff date of the amendmentj each licensee shall certify, by letter to the Director of the Office of Nuclear Reactor Regulation, that an effective, documented maintenance program is being maintained and implemented, which includes measures to monitor and improve the program, where approriate.

In addition, each licensee shall submit to the Director of the Office of Nuclear Reactor Regulation the quarterly Maintenance Performance Report requested in Paragraph (c), including an explanation of the method used to calculate the performance indicators.

Dated at thi s day of 1989 For the Nuclear Regulatory Commission Samuel J. Chilk Secretary of the Commission Enclosure

CANDIDATE MAINTENANCE PERFORMANCE INDICATORS 1.

Ratio of Preventive to Total Maintenance.

The definition of this indicator is identica to t e one use y

t is the ratio of non-outage preventive and surveillance testing man-hours to total non-outage mainte-nance (corrective and preventive maintenance, and surveillance testing) man-hours.

2.

Corrective Maintenance Backlo Greater than Three Months Old.

This indicator used y

N 0 is defined as the percentage o

open corrective maintenance work requests (HWRs), not requiring an outage, that are greater than three months old.

3.

Preventive Maintenance Items Overdue.

This indicator (used by INPO) is e ine

,as t e percentage o

preventive maintenance items in the period that were not completed by the schedule date plus a grace period equal to 25K of the schedule interval.

4.

Maintenance Staff Turnover Rate.

It is the number of vacancies in a unctiona

group,
e. g., mechanical maintenance department, created by voluntary resignation divided by the average number of employees in that group.

Retirement,

death, promotion, termination for cause and part-time employment are not considered in the turnover rate.

5.

Maintenance Rework.

This is defined as the number of MWRs reopened in a period.

6.

Ratio of Deficiencies Discovered Durin Surveillance to those Discovered urin an Demand

i. e.

emand urin urvei ance or vent se

-explanatory 7.

Number and Duration of BOP E ui ment Out of Service.

It is the total number of BOP equipment e.g.,

Instrument Air Compressor) that are out of service in a period.

The out of service duration of each BOP equipment in a period is added to obtain the duration of BOP equipment out service.

t'.

Safet S stem Performance Indicator.

This performance indicator (used by PO is calculated separately for three PWR systems and three BWR systems.

The systems for PWRs are high pressure safety injection, auxiliary feedwater, emergency AC power, and for BWRs are high pressure coolant injection (high pressure core spray or feedwater coolant injection),

and reactor core isolation cooling (or isolation condenser),

residual heat removal, and emergency AC power.

For each system, this indicator is defined as the sum of the unavailabilities of the components in the system during a time period, divided by the number of trains in a system.

9.

Mean Time to Return to Service.

It is defined as the sum of the out of serv>ce durat>ons of equ>pment in a period divided by the number of equipment.

Only major equipment (e. g., those in the NPROS) that are out of service due to failures are considered.

10.

Backlo of En ineerin Chan e Notices (ECNs Related to E ui ment Per-ormance.

t 1s e

oned as the percentage o

s generate y p ant sate S to correct equipment performance problems that were not completed within the schedule plus a grace period equal to 25K of the scheduled completion time.

0