ML19353B224

Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Endorses NUMARC Comments

ML19353B224
Person / Time
Site:	Waterford
Issue date:	12/01/1989
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-54FR33983, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-DG1001, TASK-RE 54FR33983-00022, 54FR33983-22, W3P89-1982, NUDOCS 8912130507
Download: ML19353B224 (5)

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a December 1,1989 -

I JU.S. Nuclear.Regul'atory Commission TOffice of Administration -g

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Subject:

Waterford 3.SES Docket No. 50-382.

License No. NPF-38 Comments on Draft Regulatory Guide, DG-1001,

" Maintenance Programs for Nuclear Power Plants" t

' Gentlemen Louisiana Power and Light haa reviewed the. subject draft regulatory guide on

. maintenance of. nuclear. power plants, and LP&L is pleased to provide comments. l

The. successful implementation cf maintenance at nuclear power plants may very well prove to be the most iirpm tant challenge for the nuclear industry. Excellence in maintenanca is of vital importance in assuring safe, reliable,:and economical nuclear power. Maintenance :t Waterford 3 receives the utmost attention and actutiny of executive management and Waterford 3 personnel. The regulatory guide is believed to be an important document.

? :which-will-set:the tone and direction for future guidance in maintenance.

LP&L has interfaced with NUMARC and reviewed .he commeats generated by

NUMARC. LP&L endorses the NUMARC comments. LP&L has provi.ded in the attachment to this letter Waterford ? specific comments or comments addressed p by NUMARC which require emphasis for Waterford 3. We hope these comments

) will be beneficial in the development of a regulatory guide on maintenance.

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.i .a Attachment to-ELP&L Letter W3P89-1982-Comments on Draft Regulatory Guide, DG-1001 .

'" Maintenance Programs for Nuclear Power Plants"

1. . NRC Maintenance inspections

, The benefite of the NRC Maintenance inspections do not appear to have been utilized in the development of the regulatory guide. The Federal Register notice'of August 17 -1989 neither makes reference.to.nor discusses how the

. maintenance-inspections were considered in the development of the ,

regulatory guide. The regulatory guide only makes reference to maintenance

. inspections in the context that maintenance inspections indicated a wide  !

variation in the ecope, depth, implementation, and effectiveness of. l licenece maintenance programs.  !

The NRC-maintenance: inspections expended significant NRC and Utility resources. The maintenance inspections evaluated virtually every aspect of

-maintenance.. Various levels of utility-personnel were interviewed f rom i senior: managers to craft pe:aonnel. Detailed criteria, for example .l TI-1515/97-01, were used in evaluating programs and actual maintenance.  !

-There is no question that the maintenance inspections have been broad in i scope, detailed in evaluation, and effective. The maintenance inspections  : l

. provide an invaluable resource of information for enhancing.the regulatory

guide.

A'first step could be for the NRC inspectors who were involved in the L inspections to hold detailed workshop type discussions with the NRC writers

.of the reguletory guide. LP&L emphasizes that the regulatory gui'e.could be best embe111shed if the maintenance inspections are used from the perspective ot incorporating guidance in the regulatory guide which reflects good practices observed in maintenance inspections.

l l2.- Policy Statements il 1 ~

The regulatory guide incorporates various statements which are in fact policy statements which are or appropriately should be addressed in the  ;

policy statement. Examples of such policy statements are: regulatory position C.1, paragraph 3, on an effective maintenance program; regulstory .j

-position C.2, on overall maintenance policy; regulatory position C.4.3.5, on management of parts; and regulatory position C.4.5, on planning and '

l scheduling. The foregoing guidance is broadly stated philosophy.

incorporating such text in the regulatory guide will not provide useful standards for maintenance activities.

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/3. Idealistic Precepts

- Various standards are stated as idealistic precepts which do not account for s the' practical aspects of maintenance. The following regulatory positions are examplest Regulatory position C.1,-paragraph one, states that the maintenance program a should describeLthose structures, systems, aad components covered; the

- maintenance applicable to each; and the process, procedures, and'_

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responsibilities to be used to conduct an effective maintenance' program. A l plant contains,between 30,000 and 150,000 components depending on the design 1 of;the plant and the definition of a component. Titerally interpreted, the'

-regulatory position could be interpreted to mean'that for each component a matrix process of some_ form should exist that describes in detail the maintenance, procedures,. responsibilities, etc. From a practical standpoint, the-individual utility-should have the flexibility to estab31ch the systems,. j structures, and_ components and the maintenance method.

Regulatory position C.I.1, first paragraph, states that the maintenance program shculd define objectives and.that quantitative goals for components 1

-related=to these objectives-ahould be established as one means to measure- H the progress of the maintenance program. .LP&L agreen with NUMARC that a l data base or criterion dees not exist that vould allow a utility to set component quantitative goals. .LP&L acknowledges that although idealistically. achievable, establishing goals and objectives on all, most, or many' components is not achievable without an extensive dilution of engineering resourer.s for an indeterminate gain. . Root cause analyses and' 1 1ong term corrective actions are appropriate and effective alternatives. ,

Regulatory position C.4.6.1, first paragraph, states that a-documented basis for planned preventative maintenance-should be provided. LP&L agrees with-NUMARC that the regulatory position could not be-implemen*ed since there '

would be'a monumental dilution of engineering resources-and a morass of paper. -The guidance for documentation should be flexib?e to account for the collective integration of many factors which determine preventative-maintenance. In certain cases, such factors like design requirements,

, engineering judgment, and vendor recommendations, are not necessarily l documented and~ explained in detail relative to the selected preventative

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maintenance.

Regulatory Position C.4.o.2 states that an analysis should be performed to '

determine the root cause or causes of failure and corrective action should be taken, including feedback into the preventive and predictiva maintenance

' programs and maintenance training and qualification programs. The

- regulatory position implies an in-depth or " root cause" analysis should be performed for every failure. The emphasis of the regulatory position should be that the cause of degraded important equipment be determined and the equfpment repaired to eliminate adverse consequences.

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Regulatory position C.4.3.2, second paragraph, states that sufficient

• engineering' justification should be provided when . vendor recommendations 1

-are not followed. The nature of vendor recommendations vary in significance from enhancements to critical recommendations which-address deficiencies which could compromiue the integrity or operation of. equipment. Additionally,

some' vendor. recommendations are made for nonsafety related or BOP applications which would'not adversely affect plant operations. The regulatory position should,be restated to allow utilities to apply engineering resources P commensurate with the safety significance of the deficiency'and' application.

0' Regulatory position C.4.7, second-paragraph, states that post maintenance ~

should document _and; verify that the equipment is capable of performing its design functions. Equipment has many design functions,. including inherent

, design functions like resisting mechanical stress and fatigue, thermal protection,.etc. _Also, the maintenance performed may not affect _a-significant portioncof_the equipment. The emphasis of post maintenance should be to provide ascurance the maintenance.was properly performed

.and that appropriate _ portions of surveillance or operability testing will be successful.

The:regu.atory guide should be' carefully scrutinized to assure there is an overriding need for each standard, the standard can'be literally imple-mented, and the standard accounts for the practical aspects of maintenance, for.; example, safety significance and finite resources.

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