ML20035G211
| ML20035G211 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1993 |
| From: | Mate J NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Lanham D NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20034D458 | List: |
| References | |
| FRN-58FR15303, RULE-PR-50 AE55-1-001, AE55-1-1, NUDOCS 9304270005 | |
| Download: ML20035G211 (3) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION g
WASHINGTON, D.C. 20555-0001
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MEMORANDUM FOR:
Donald H. Lanham Apg y g1993 Nuclear Document System (NUDOCS), Mail Stop Pl-37 Office of Information Resource Management FROM:
Joseph J. Mate Regulation Development Branch
~
Division of Regulatory Application' Office of Nuclear Regulatory Resears
SUBJECT:
REGULATORY HISTORY INDEX FOR 10 CFR 50.65 - PROPOSED RULE,
" MONITORING THE EFFECTIVENESS OF' MAINTENANCE AT NUCLEAR POWER PLANTS" Enclosed for your processing are the regulatory documents, comprising the regulatory history of the Notice of Proposed Rulemaking entitled, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants", which amends 10 CFR Part 50. This notice was published in the Federal Register on Monday, March 22, 1993 (58 FR 15303).
If you have any questions er we can be of further assistance, please call me at 492-3795.
J s ph. Mate R
lations Deve opment Branch Division of Regulatory Applications Office of Nuclear Regulatory Research
Enclosures:
1.
Regulatory History Index 2.
Regulatory History Documents cc: M. Lesar M. Rothchild, DGC l
- s 9304270005 930415 50 58 R15303 PDR
REGULATORY HISTORY INDEX 1.
Memorandum from Richard P. Correia, NRC Coordinator for NRC/NUMARC Maintenance Interactions (NRR) to Gary G. Zech, Chief Performance and Quality Evaluation Branch (NRR) dated March 6, 1992 and subject, MEETING
SUMMARY
FEBRUARY 26, 1992 NRC/NUMARC PUBLIC MEETING ON THE DEVELOPMENT OF GUIDANCE DOCUMENTS FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE (10 CFR 50.65) 2.
Memorandum from Richard P. Correia, NRC Coordinator for NRC/NUMARC Maintenance Interactions (NRR) to Gary G. Zech, Chief Performance and Quality Evaluation Branch (NRR) dated April 30, 1992 and subject, MEETING
SUMMARY
APRIL 22, 1992 NRC\\NUMARC PUBLIC MEETING ON THE DEVELOPMENT OF GUIDANCE DOCUMENTS FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE (10 CFR 50.65) 3.
Memorandum from James M. Taylor, Executive Director for Operations, to the Commission dated July 30, 1992 and subject, IMPLEMENTING GUIDANCE FOR 10 CFR PART 50.65 (THE MAINTENANCE RULE) 4.
Federal Register Notice, Nuclear Regulatory Commission, Final Rule, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants (56 FR 31306).
5.
Memorandum from Samuel J. Chilk, Secretary, to James M. Taylor, Executive Director for Operations, dated February 17, 1993 and subject, STAFF REQUIREMENTS - BRIEFING ON IMPLEMENTING GUIDANCE FOR THE MAINTENANCE RULE AND INDUSTRY VERIFICATION AND VALIDATION EFFORT, 10:00 A.M.,
- FRIDAY, JANUARY 29, 1993, COMMISSIONER'S CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND, (OPEN TO PUBLIC ATTENDANCE).
6.
Memorandum from Eric S. Beckjord, Director RES, to Edward L. Jordan, Director AE00, Thomas E. Murley, Director NRR, James Lieberman, Director OE, Patricia G. Norry, Director Admin, Gerald F. Cranford, Director IRM, and Martin G. Malsch, Deputy General Counsel, dated March 3,1993, and subject REVISION OF THE MAINTENANCE RULE (10 CFR 50.65).
7.
Memorandum from Patricia G. Norry, Director Administration, to Eric S.
Becksord, Director RES, dated March 8, 1993 and subject 0FFICE CONCURRENCE ON PROPOSED RULE ENTITLED "NONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS".
8.
0GC markup of the Eric S. Beckjord Memorardum of March 3,1993, subject REVISION OF THE MAINTENANCE RULE (10 CFR 50.6E1 9.
Memorandum from Eric S. Beckjord, Director RES, to James M. Taylor, Executive Director for Operations, dated March 12, 1993 and subject, REVISION OF THE MAINTENANCE RULE (10 CFR 50.65).
- 10. Memorandum from Mark Au, Information Management Coordinator, RES, to Brenda J. Shelton, Chief of Records and Reports Management Branch, IRM dated March 12, 1993, and subject, TRANSMITTAL OF OMB CLEARANCE PACKAGE: 10 CFR 50.65, " MONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS".
I
- 11. Memorandum from Sher Bahadur, Chief Regulation Development, RES, to Michael Lesar, Acting Chief, Rules Review and Directives, Admin dated March 17, 1993 and subject, IMPLEMENTATION OF ED0 ACTION: PROPOSED 10 CFR PART 50,
" MONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS".
12.
Federal Register Notice, Nuclear Regulatory Commission, Proposed Rule, Monitoring the Effectiveness of Maintenance at nuclear power plants.
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'o UNITED STATES
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~t WASHINGTON, D. C. 20555 March 6, 1992 MEMORANDUM FOR:
Gary G.
Zech, Chief Performance and Quality Evaluation Branch Division of Licensee Performance and Quality Evaluation FROM:
Richard P. Correia, NRC Coordinator for NRC/NUMARC Maintenance Interactions Performance and Quality Evaluation Branch Division of Licensee Performance and Quality Evaluation
SUBJECT:
MEETING
SUMMARY
-- FEBRUARY 26, 1992 NRC/lGMARC PUBLIC MEETING ON THE DEVELOPMENT OF GUIDANCE DOCUMENTS FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE (10 CFR 50.65)
The subject meeting was held at,the NRC Headquarters Offices in OWFN.
This was the fifth public meeting of the NRC and NUMARC Steering Groups on the subject guidance document development efforts.
The meeting notice is provided as enclosure 1 and the list of attendees as enclosure 2.
The principal purpose of the meeting was to continue discussions between the NRC and NUMARC Steering Groups regarding the parallel IW and industry efforts to develop guidance to be used to implement the Maintenance Rule (10 CFR 50.65).
Specific items discussed, listed on the meeting agenda (enclosure 3) were as follows:
NUMARC Comments on the Draft Maintenance Recolatory Guide (dated January 8, 1992)
In general, the IMMARC Steering Group stated that the Draft Regulatory Guide was well structured and the approach taken by the staff paralleled their efforts in developing the Industry Guidance document.
The more specific NUMARC comments were as follows:
ICMARC believes that maintenance performed on Emergency Offsite Facility (EOF) equipment does not need to be within the scope of the Maintenance Rule.
NUMARC feels that current maintenance practices are sufficient to assure proper EOF equipment performance.
The NRC Steering group agreed with the NUMARC approach to this issue.
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Gary G. Zech G NUMARC stated that the scope of structures, systems and components (SSC) used in Emergency Operating Procedures (EOP) that are to be included within the scope of the Maintenance Rule needs to be better defined.
The NRC Steering Group commented that this issue would need further development and that formulating generic guidance would be challenging since the structure and content of EOPs for the different reactor types vary.
Both steering groups agreed after some discussion that the NRC and NUMARC working groups would meet to discuss and consider possible approaches for resolution of the issue.
A tentative meeting time would be scheduled for the near future to support ongoing guidance document developmental efforts and schedules.
The NUMARC Steering Group expressed a concern that the data collection and documentation guidelines described in the draft Regulatory Guide are excessive and would have a revere impact on a licensee's technical resources.
The NRC Steering Group stated that the items in the data collection and documentation section of the draft regulatory guide were intended to be those items that licensees need to assure themselves that the results of their maintenance programs have been effective.
The NRC Steering Group also stated that the wording of the draft regulatory guide would be revised to better reflect this intention.
Regarding the annual evaluation requirement specified in part (a) (3) of the Maintenance Rule, NUMARC feels there would be instfricient data available on an annual basis for meaningful evaluations.
The NUMARC preference would be based on refueling cycles.
The rationale given by the NUMARC Steering Group was that the evaluation process would be time consuming, the data collected during a full fuel cycle would be more meaningful, some important data can only be obtained from surveillance tests performed with the reactor shutdown, and adjustments to maintenance activities that may be made after such an evaluation would be typically performed after a refueling outage.
In addition, NUMARC stated that annual evaluations would be difficult for facilities with multiple units having' common or shared equipment.
The NRC Steering Group noted that such a proposal would require amending the Maintenance Rule and expressed concerns with the NUMARC proposal for tho 1 plants that could have extended fuel cycles because of problems encountered during operations which result iniforced shutdowns.
These circumstances could result in evaluations being performed after years of operation rather than annually.
The NRC Steering Group stated that the NUMARC proposal would be considered.
4 Ga ry G. Zech NUMARC would prefer limiting the scope of SSCs needed to support safety systems to those that "directly support" safety systems.
They believed that this approach would be consistent with license renewal regulations.
The NRC Steering Group stated that all SSCs needed to " maintain safety system function" must be considered under the scope of the Maintenance Rule.
NUMARC stated that the root cause analysis information in the draft regulatory guide would not be necessary because information was available in the form of NRC and industry root cause guidance documents.
A reference to such documents in the regulatory guide would be sufficient.
The NRC Steering Group noted that the appendix to the draft regulatory guide which contained the root cause analysis information clearly stated that it was provided for information only and was not part of the regulatory guide.
The NRC Steering Group stated that NUMARC's comments would be considered during the next revision to the draft regulatory guide.
Maintenance Preventable Failures During the December 18, 1991 NRC/NUMARC maintenance guidance meeting, NUMARC agreed to provide examples of maintenance preventable failures (MPF) to the NRC Steering Group for consideration and discussion at the next scheduled meeting. contains the MPF examples provided by NUMARC.
The NRC Steering Group stated that there were concerns with two of the examples that NUMARC considered not maintenance preventable.
The NRC Steering Group questioned the intent of the example which stated that " Failures that...are economically inappropriate to preclude..."
NUMARC stated that the intent was to show that in some instances an SSC would be allowed to fail because it would not have an adverse impact on risk and could not be repaired in a timely fashion because of the lead time needed to procure replacement parts or maintenance would be deferred to a planned outage.
The NRC Steering Group noted that such instances failures would not be considered maintenance preventable but the licensees would be expected to take compensatory actions in the interin to assure safe plant operations.
The NRC Steering Group questioned the example which stated that
" Failures due to operations personnel errors."
The NUMARC Steering Group agreed with the NRC Steering Group that failures due to operational errors (and not operations personnel errors) would not be considered maintenance preventable.
Gary G. Zech
-4 NUMARC Approach to Maintenance Rule Implementation The NUMARC Steering Group presented their Maintenance Rule Logic Diagram and supporting text (enclosure 5) which described the approach used in the development of the Industry Guidelines for the implementation of the Maintenance Rule.
After some discussion, the NRC Steering Group agreed in principal with the NUMARC concept.
NUMARC stated that the logic diagram would be reevaluated as a result of the NRC Steering Group comments and gyestions.
NUMARC Draft Terms and Definitions At the December 18, 1991 NRC/NUMARC meeting, a set of draft terms and definitions were presented to the NRC Steering Group for consideration.
The NRC provided comments on the draft terms and definition to NUMARC by letter dated February 11, 1992.
The NRC Steering Group asked NUMARC if there were any comments or questions regarding the NRC comments.
NUMARC responded that the NRC comments were understood and had no questions.
Status of NRC and NUMARC Guidance Documents The current status of the.NRC Regulatory Guide and the NUMARC Industry Guidance Document were presented and were as follows:
The Regulatory Guide is being revised and is expected to be made publicly available the week of March 27, 1992.
Included with the next version of the Regulatory Guide will be a for information only, draft regulatory analysis or cost / benefit statement.
NUMARC expects to forward a draft Industry Guidance Document to the NRC by March 27, 1992 and to the industry by March 31, 1992.
Next Scheduled Meetina NUMARC proposed that a meeting be held to discuss the draft Industry Document on March 27, 1992.
The NRC Steering Group recommended that time should be allowed for each group to review each others documents and then con'vene a meeting for discussions.
I
Gary G. Zech NUMARC agreed with the proposal.
The next meeting between the Steering Groups is tentatively scheduled for April 14, 1992.
Original signed by:
Richard P. Correia, NRC Coordinator for NRC/NUMARC Maintenance Interactions Performance and Quality Evaluation Branch Division of Licensee Performance and Quality Evaluation
Enclosures:
As stated cc:
J. Sniezek J. Colvin (NUMARC)
W. Russell T. Tipton (NUMARC)
J. Helte=es C. McNeill (PECo)
R. Baer DISTRIBUTION:
Central Files A. Vietti-Cook PDR D. Trimble LPEB Reading File J. Scarborough NRC meeting participants E. McKenna NUMARC meeting participants E. Doolittle J. Kopeck OFFICIAL RECORD COPY:
NUMARC15.JP
NRC/NUMARC MAINTENANCE RULE GUIDANCE DOCUMENT MEETING February 26, 1992 NAME ORGANIZATION TELEPHONE NO.
Richard Correia NRC/NRR./
(301)504-1009 J. Sniezek NRC/EDO (301)504-1705 Owen Rothberg NRC/RES/
(301)492-3924 Jack Roe NRC/NRR' (301)504-1004 W.T. Russell NRC/NRR (301)504-1274 J. Heltenes NRC/RES (301)492-3720 Robert Baer NRC/RES (301)492-3930 Gary Zech NRC/NRR.
(301)504-1017 Frank Cherny NRC/RES/
(301)492-3945 Warren Hall NUMARC (202)872-128.0 Joe F. Colvin NUMARC (202)872-1280 Corbin A. McNeill PECo (215)841-4221 Tom Tipton NUMARC (202)872-1280 Walt Smith NUMARC (202)872-1280 Dan Rains NUMARC (202)872-1280 NRC/RES',[-
Carl Johnson (301)492-3548 Patrick O'Reilly NRC/AEOD (301)492-8858 Geoffrey Grant NRC/EDO -
(301)504-1726 Dave Trimble NRC/OCM/JC (301)504-1882 Marc Huber NRC/OCM/JC-(301)504-1875 Charles Petrone NRC/NRR ~
(301)504-1029 Cynthia Pederson NRC/EDO-(301)504-1733 Tom Fo1ey NRC/NRR-(301)504-1036 Alan Madison NRC/AEOD.'
(301)492-9428 Gilbert Zigler Science & Engineering Assoc.
(505)884-2300 Tom Ippolito science & Engineering Assoc.
(505)849-8884 Tricia Heroux EPRI (703)S36-0459 Lloyd Zerr STS (301)652-2500 Carter Rogers Arizona Public Service Co.
(602)340-4041 David Stellfox McGraw-Hill (202)463-1600
February 26, 1992 NRC/NUMARC Maintenance Guidance Development Meeting Tentative Agenda NUMARC overview comments regarding the NRC draft Regulatory Guide dated January 8, 1992 Discussion of NUMARC examples of maintenance preventable failures NUMARC approach to an Industry Guidelines Document Current status of Regulatory Guide and Industry Guidelines Proposed next meeting date: Week of April 15, 1992 (NRC)
Friday, March 27, 1992 (NUMARC)
Discussion on NRC comnents on NUMARC draft definitions and terms (dated 12/18/91) i
Examples of Haiatenanes preventable Fuaetional Failures Note that " functional" has been added to provide amphasis on assuring safety functional perforcance rather than a deficiency that does not affect a safety function.
o Failures due to the implementation of incorrect maintenance procedures.
o Failures due to incorrect implementation of correct maintenance procedures.
o failures due to incorrect implementation of maintenance performed without procedures considered within the skili of the craft.
o failures due to lack of implementatio'i of appropriate vendor recomendations relative to maintaining the equipment.
Failures that occur subsequent to a vendor's recommendation that have been technically dispositioned as unnecessary are not considered raintenance preventable, at the first instance of failure.
o failures occurring at a licenses of the same kind that have occurred in industry as defined in SERs SOERs, and IEBs that could have been precluded by an appropriate and timely maintenance activity.
o Failures that occur due to the failure to perform maintenance activities that are normal and appropriate to the equipment function and importance..Exarples include failure to lubricate with the appropriate materials at appropriate frequencies, failure
, to rotate equipeent that is in a standby mode for long periods.
Extmples of Fun' tional Failures That Are 1101 Mainten;nce Preventable e
o Initial failures due to original equipment manufacturer (OEM) design inadequacies, e
Initial failures due to design inadequacies in selecting or applying comercial or "off the shelf' designed equipment.
4
'o Failures that occur that could be prevented by a maintenance activity but are economically inappropriate to preclude and do not upon failure contribute to significant risk.
o Initial failures due to inherent material defects, o
Failures due to operations personnel errors.
i O L 21. 9 2 I2:li NE 'PC2 '
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DRAFT
- KEY POINTS USED IN DEVELOPING A PROCESS TO MEET THE MAINTENANCE RULE. 10CFR50.65 o
The first step is to review plant structures, systems, and components (SSCs) against specific criteria to determine if they are within the scope of 10CFR50.65 (Figure 2).
For those SSCs not within the scope of the rule, the licensee would continue the applicable maintenance programs.
o For that subset of SSCs within the scope of 10CFR50.65, the second step
. is to determine if goals and associated monitoring applies (50.65(a)(1))
or a preventive mairitenance prog;am (50.65(r)(2)) applies.
Figure 3.
This determination is made ccnsidering risk. significance and performance.
The process addressing (a)(1)-includes establishing overall plant level o
goals (e.g., scram due to maintenance preventable failure), goals for key risk significant SSCs, and goals for SSCs that have not demonstrated acceptable performance.
It should be noted that the key parameter is performance - anticipated or actual.
o Those SSCs that are in (a)(1) include:
Risk significant SSCs. identified using PRA, critical safety functions (e.g., inventory) or other processes. For example, there are systems that are in a standby mode but whose function, when called upon to perform a safety function, are required to be available and reliable (e.g., high pressure coolant injection).
The systems that support these primary systems (e.g., essential service water) may be in (a)(2) recognizing that the performance
.pf the support systems may have a direct impact on the primary system's goal (e.g., availability).
SSCs with unacceptable performance - an SSC may be included in this category because it caused an overall plant level goal to be missed (e.g., scram due to a maintenance preventable failure in a Balance of Plant system), or its past performance was not acceptable.
e As indicated on Figure 3. flow arrows go to both (a)(1) and (a)(2) from the decision block if it is determined that goals should be set. This is due to the fact that, although goals are set and monitored as part of (a)(1), the preventive maintenance and condition monitoring activities are part cf (a)(2) and apply to the entire subset of SSCs that are within the scope of the Maintenance Rule.
o Once the SSCs have been initially selected and segregated into (a)(1) or (a)(2), a process is established to monitor, periodically evaluate and adjust, when and where necessary, specific plant and SSC goals.
The process also includes a decision process for deciding when to transfer an SSC from (a)(1) to (a)(2) or vice versa.
Figure 4.
As used in Figure 4, availability refers to being able to perform the o
specific function. This recognizes redundancy and diversity to be able to demonstrate that the function is available (e.g.. maintaining i
inventory).
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NgureT Maintenance Rule Loolc Diagram i
Overall plant Plant specific goals SSCs V
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Is Con-goal No tinue Are N
Continue i
related to maint.
to SSCs within No applicable Performance?
monitor scope of maintenance separ-rule?
programs atelv
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Yes y
i if e
Are SSCs Are No No Yes SSCs risk performance significant?
acceptable?
c Yes V
xr(a)(2)
(a)(1) y v
(a)(1) y Plant Set goals for Set goals for SSCs in level risk significant SSCs with preventive goal SSCs unacceptable maintenance performance and condition monitoring A
program V
Yes No Are SSCs performance cceptable?
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Initial @ election of SSCO that are Within the Scope of 50.65 1
Plant SSCs i
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re a ed Sbs No re a d SS s Safety-No Nonsafe4 No Nonsafety No
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related SSC related SSCs in prevent SR SSC cause scram or related SSCs?
MNating a EOPs?
y'[I'h7 actuation of SRS?
Yes 3r y es 3(Yes Yes Yes Y
if if if Y
1f Subset of systems Subset of systems, structures, and structures, and components that are within the scope components not of the Maintbnance Rule within scope of the Maintenance Rule C
if p
Continue applicable gq maintenance n,
programs on 8
these SSCs 5
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DRAFT SN Enclosure I
initial Separation of SSCs Figure 3 Within Scope of Maintenance Rule ito Goal Settino and Preventive Maintenance j
Subset of SSCs j
that are within scope of the
-Maintenance Rule
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Set goals y
for SSCs Are Are SSCs past Yes SSCs risk N
Yes pedormance l
significant?
acceptable?
l No V
(a)(1) V (a)(1) y (a)(2) y y y SSCs that Set goals Set goals require Continue Set goals preventive for risk h
forthe maintenance maintenance i
significant na p ble SSCs Programs and condition SSCs Pedormance on SSCs monitoring
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Detailed Logic Diagram of Goal S;tting
- ()(1)I %.65(I)(2) 3 I
and Preventive Mnintenance Process _
i SScs b prenntin SSCs with 1
an an Risk significant Plantlevel unacceptable performance SSCs goals (e.g., serams)
I program I
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Perform appropriate 1f Establish goals 3->
maintenance on SSCs Establish goals at system, structure, I
evaluate performance Monitor and 4
or component level periodically evaluate (e.g., availability) i 1
if
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)(
i Monitor and Monitor and periodically Yes
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evaluate against gods l
f Do No y
periodically evaluate erformance against goals acceptable 7 A
g goals need to i
e changed?
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y Yes
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IS if is Na No O
Are Yes Yes i failure performance Make any goals need t goals being acceptable?
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necessary be changed?
met?
modifications I
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No Yes I
Root if if Yes cause identified /
II Root cause PFF corrected?
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Rootcause analysis and g
m Modify anafysis corrective action i
bT goals.
and cortectf i
No O
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MEMORANDUM FOR: Gary G. Zech, Chief Perforr,ance and Quality Evaluation Branch ME /
Division of Licensee Perforn,ance go 3 and Quality Evaluation FROM:
Richard P. Correia, Chief Perforn.ance and Quality Evaluation Section 8 Perfora,ance and Quality Evaluation Branch Division of Licensee Performance and Quality Evaluation
SUBJECT:
- NOTICE OF REVISED DATE OF PUBLIC MEETIhG WITH NUMRC TO DISCUSS REGULATORY GUIDE ON PONITORING OF MAIN 1EhANCE IN 1
~
NUCLEAR POWER PLANTS Date and Tia,e Wednesday, February 26,19?2,1:00 to 3:00 p.en.
(Previously scheduled for February 13,1992)
Location:
One White Flint North, Room 1F7/9
Purpose:
To exchange infont.ation on current and planned.NRC staff actions and Nuclear Industry. plan > regarding guidance on the Maintenance Rule, 10 CFR 50.65.
~
Participants:
NRC hUMRC J. Sniezek J. Colvin W. Russell T. Tipton C. Heltemes C. McNeill (PEco)
R. Baer Origfnalsigned by:
- Rii:hard P. Correia_, Chief Performance and Quality Evaluation Section B Perfora.ance and Quality Evaluation Branch Division of Licensee Perfor.ance and Quality Evaluation cc: J. Sniezek W. Russell C. Heltes,es R. Beer J.Colvin(NUMRC)
T.Tipton(NUMRC)
C.McNeill(PECo)
DISTRIBUTION Central file E. BeckforJ W. Sinith (huMRC)
PDR T. Murley G. Mizuno P. Baranowsky LPEB Reading File E. Jordon e
LPEB Staff K. Connaughton J. Roe D. Trimble O. Rothberg M. Slosson C. Petrone E. Doolittle T. Foley J. Scarborough G. Grant C. Ader P. O'Reilly C. Johnson (RES)
R. Dennig F. Cherny GPA P. O' Dell 0FFICIAL RECORD COPY Docua.ent Naine MTG NOTICE f20 Y
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WASHINGTON. D.C. 20565 oyvs 3
APR 3 01992 i
MEMORANDUM FOR:
Gary G.
Zech, Chief Performance and Quality Evaluation Branch Division of Licensee Performance and Quality Evaluation Office Of Nuclear Reactor Regulation FROM:
Richard P. Corre'ia, NRC Coordinator for NRC/NUMARC Maintenance Interactions i
Performance and Quality Evaluation Branch Division of Licensee Performance l
and Quality Evaluation Office of Nuclear Reactor Regulation l
SUBJECT:
MEETING
SUMMARY
-- April 22, 1992 NRC/NUMARC PUBLIC MEETING ON THE DEVELOPMENT OF GUIDANCE DOCUMENTS FOR THE IMPLEMENTATION OF THE MAINTENANCE RULE (10 CFR 50.65)
The subject meeting was held at the NRC Headquarters Offices in OWFN.
This was the seventh public meeting of NRC and NUMARC on the subject guidance document development effort;s. The list of attendees is provided as enclosure 1 and the tentative meeting agenda as. enclosure 2.
The purpose of the meeting was to continue discussions between the NRC and NUMARC Steering Groups regarding the parallel NRC and industry efforts to develop guidance to be used to implement the Maintenance Rule (10 CFR 50.65).
The following is a summary the major topics discussed at the meeting.
NRC STEERING GROUP COMMENTS ON THE INDUSTRY GUIDELINE (Ref.
NUMARC 93-01, Draft Revision 1, dated March 30, 1992)
Overall Persoective:
NRC Steering Group (NRC) was disappointed in the overall approach and content of the; Industry Guideline.
It appeared to the NRC that the document emphasized what actions need not be taken and offered only limited guidance regarding proper implementation of the rule.
NRC urged NUMARC to demonstrate leadership in the industry by taking a more positive, proactive, approach in the development of guidelines for the implementation of the maintenance rule.
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Gary G.
Zech l The NUMARC Steering Group (NUMARC) responded that they are concerned about the eventual enforcement of the rule.
They wish to avoid having individual inspectors second guessing each of the many individual decisions each utility will have to make regarding methods used to implement the rule.
They indicated that their document was intended to better define i
the scope and other requirements of the rule, not to try to avoid those requirements.
The intent was not to be very i
prescriptive since some decisions are best left to the individual utilities.
They stated emphatically that they did not intend to issue a guideline that was so prescriptive that a utility that minimally met the letter of the guideline would necessarily be in compliance with the maintenance rule.
NRC explained that NUMARC should not be concerned about the eventual inspection and enforcement of the maintenance rule.
separate inspection procedures will be developed and training will be provided to ensure that NRC inspectors have a good understanding of the maintenance rule.
The NRC will also hold public workshops to educate the industry and the public on how the inspection program will be implemented and enforced.
NUMARC agreed to review the text of the Industry Guideline for its philosophical approach and make changes that would
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make it clear to the NRC that the industry would approach the implementation of the maintenance in a positive proactive manner.
Maintenance Rule Paracraoh (a) (1) verses (a) (2) :
The approdth taken by NUMARC for placing structures, systems, and components (SSCs) under the requirements of paragraph (a)(1) or (a)(2) of the rule differs from that reflected in the statement of consideration for the rule.
The Industry Guideline initially assumes that all SSCs are under paragraph (a) (2) of the rule where they would be maintained under the normal preventive maintenance (PM) program and monitored against licensee established performance criteria.
If those criteria are not met, and the SSC in question is risk significant, then the criteria not met would be reflected a's a goal under (a) (1).
The approach taken by the NRC in the draft regulatory guide differs in that initially all SSCs are assumed to be under paragraph (a)(1) of the rule and then moved under (a)(2) if the SSC proves to be effectively maintained or of low risk significance.
However, the NRC and NUMARC agreed that initially placing all SSCs in (a)(1) vice (a) (2) should not matter in the long run if the criteria for transferring SSCs
l Gary G.
Zech from (a) (1) to (a) (2) and from (a) (2) to (a) (1) were equivalent in the industry and NRC documents.
Either way the appropriate SSCs should end up in the correct category after several review and evaluation cycles.
The NRC emphasized that utilities would be expected to have the appropriate SSCs in (a)(1) when the rule takes effect on July 10, 1996.
That would require licer. sees to implement their programs sufficiently in advan.ce sf that date in order to allow the necessary time ~for the appropriate SSCs to be transferred from (a) (2) to (a) (1).
Documentation:
The NRC stated that the documentation recommendations contained in the Industry Guideline seem inadequate.
It appears that the only recommendations are to document the (a) (1) goals not met and the resulting corrective actions, the revision of goals, and root cause analyses.
The NRC believes that appropriate documentation would include goals and performance criteria established and their basis, SSCs placed in (a) (1) and (a)(2) and their basis, and the monitoring results.
NRC noted that NUMARC needed to clearly define the documentation for all activities associated with the rule.
NUMARC stated their concern that documentation could become a excessive and unnecessary burden if they were to record and preserve all actions associated with the maintenance rule.
For example they don't consider it necessary to document incipient failures or unacceptable degradations or to trend fallvies.
In general their intent was to document exceptions (actual failures, problems, etc.) rather than successes or normal function.
However. they agreed to review their Industry Guideline in view of the NRC comments and clarify their position on documentation.
Annual Assessments:
The Industry Guideline appears to indicate that the annual assessment required by paragraph (a) (3) of the rule addresses only (a) (1) goals and scope.
The NRC stated that the annual assessment needs,to address the entire scope of
.-- the rule.
NUMARC agreed to consider clarifying this issue in their Industry Guideline.
In previous meetings NUMARC stated its position that the annual assessments required by paragraph (a) (3) of the rule would be more meaningful if they were performed on a
Gary G.
Zech
-4 refueling cycle interval sinco many of the major surveillances are performed during refueling outages.
The NRC staff agreed that a refueling cycle interval, not to exceed 24 months, was a reasonable assessment cycle and agreed to consider requesting a change to the rule.
Risk Sionificance:
The Industry Guideline indicates that risk significance is the loss of a safety function at the system level and thus failures of components or trains where there is redundancy vould not be risk significant.
The NRC believes that risk significance should be based on Individual Plant Examination /Probabilistic Risk Assessment (IPE/PRA) core damage probabilities.
NUMARC indicated that there were several methodologies that could be used for risk significance determinations, including consideration of IPE/PRA probabilities and other appropriate methods.
They agreed to consider revising their Industry Guidelines to clarify their intent.
4 Goal Settino:
The Industry Guideline allows but does not recommend or require the use of IPE/PRA results for performance criteria or goal setting.
The NRC believes the maintenance results i
should be used to confirm performance and conditions (including component and train availability and reliability) in available IPE/PRA and other safety analysis results.
NUMARC stated that their intent was make use of all i
available information for goal setting, including IPE/PRA results.
They pointed out some of the limitations of the IPE/PRA results: they are not living documents and are not i
riecessarily updated on a routine basis, and the results contained in them may be based on generic data rather than
' plant specific data.
NUMARC agreed to consider changing the Industry Guideline to encourage the use of IPE/PRA results during goal setting.
The Industry Guideline indicates that no train level goals need to be established.
Thetstaff disagrees with this approach.
Setting goals at the system level rather that at the train level could obscure single train failures.
The NRC believes the Industry Guidelines should encourage licensees to consider goals at the plant, system, train and component levels and select those that are most appropriate.
s Gary G.
Zech NUMARC agreed to revise the Industry Guidelines to add goal setting for individual trains where appropriate.
The Industry Guideline does not require SSC failure evaluations, tracking and trending except for the annual assessment of SSCs handled in accordance with paragraph (a) (1) of the rule.
The NRC believes it is also important to evaluate, track and trend data obtained during performance monitoring and surveillance of SSCs performance with paragraph (a) (2) of the rule.
The NRC noted during the Maintenance Team Inspections that there was a weakness in the area of maintenance trending.
It was observed that routine surveillance data, which could have predicted a failure if it were trended, was ignored or was obscured by recording a pass / fail result rather than the actual quantitative data.
NUMARC responded that they are concerned that requiring evaluations, tracking, and trending for all SSC performance within the scope of the rule would be an excessive burden.
They noted that as many as 30,000 surveillances are performed each year at a typical plant.
They agreed to consider revising the Industry Guideline to provide criteria for selecting appropriate SSCs in (a) (2) whose failure should be recorded and trended.
The Industry Guideline Document indicates that two conditions are necessary before a goal must be established; the performance must be unacceptable and the failure must result in the loss of safety system function.
The NRC believes these criteria are non-conservative.
In the case of a system with redundant trains that has a failure of one train, the safety system function would not have been lost, but using the above criteria, the establishment of a goal would not be required.
The NRC believes a goal would be appropriate under these or similar circumstances.
NUMARC agreed to consider revising the Industry Guideline to
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clarify the criteria for goal setting.
NUMARC COMMENTS ON NRC DRAFT REGULATORY GUIDE DATED 3/24/92 l
The NUMARC staff presented their summary comments on the NRC Draft Regulatory Guide to the NRC staff; they are as follows:
Scope Too Broad:
NUMARC is concerned that the NRC Regulatory Guide lacks specificity in some areas and therefore leaves too much interpretation to the NRC inspector.
They mentioned this e
y w
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Gary G.
Zech concern in conjunction with several specific comments such as:
a.
The use of the term " unacceptable degradation" would require them to establish a program for monitoring the degradation of many SSCs which have never been monitored in the past.
Some SSCs, like piping, can be monitored for erosion or corrosion which is a measure of degradation.
However, other SSCs, like electrical components, cannot practically be monitored for degradation.
Typically they fail without warning.
They have the same concerns regarding the use of the term
" trends of degradation or incipient failure."
They believe it is just not possible to identify most incipient failures.
b.
The use of the phrase "... failures... of like or
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similar SSCs" is too broad.
They recommend defining like or similar failures of SSCs as:
1.
Those that are within the specific utilities own experience because adequate information on specific SSC failures at other utilities is not generally available (except for 11 and iii.
below).
ii.
Those that are reported in accordance with 10 CFR Part 21.
Typically these reports do have the necessary information on exact component type and failure cause.
iii. Those reported in a national database (i.e.,
NPRDS) that h' ave adequate information on the exact component type and failure cause.
- "' 4 Maintenance Rule Paracraoh (a) (1) verses (a) (2 ) ;
The criteria in the draft regulatory guide for initial application of (a) (1) or (a)(2) states (page 10, para c.3) that SSCs are to be considered under the scope of (a) (1) initially and may be transferred to (a)(2) if they are of low risk significance or if "A history of effective maintenance exists for a period of at least three surveillance cycles or one evaluation cycle (per (a)(3) of the rule), whichever is longer."
NUMARC believes that it is more appropriate to initially place all SSCs in (a) (2), and then transfer them to (a) (1) if they prove unreliable and
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are risk significant.
NUMARC also believes that the criteria of "at least three surveillance cycles or, one
Gary G.
Zech evaluation cycle, whichever is longer" should be changed to
... whichever is shorter" for SSCs that have surveillance cycles which are six months or less.
They believe that for SSCs with daily, weekly, monthly, semi-annual surveillance
- cycles, a sufficient amount of information would be available without waiting a full surveillance cycle.
For SSCs with surveillance cycles greater than six months they suggest "at least two successive successful surveillance cycles."
Scope of Annual Assessments:
The scope of the required annual assessments is too broad.
It requires licensees to assess their successes of monitoring in relation to meeting established goals (in addition to assessing their failures).
NUMARC would prefer to focus their resources on goals that were not met, i.e'.,
their failures rather than their successes.
Root Cause Analysis:
The paragraph on root cause analysis is not needed.
NUMARC believes that all utilities have developed root cause analysis methods and procedures of their own.
The techniques are well understood within the industry.
Including this paragraph in the regulatory guide would unnecessarily constrain the industry.
Goal Settino:
NUMARC disagrees with the NRC's usage of goal setting.
They believe goal setting should be used to promote improvement when there is unacceptable performance of the SSCs.
NUMARC uses performance criteria for SSCs in (a) (2) to insure a minimum acceptable level of performance.
The NRC responded that they would consider making changes to the Regulatory Guide to address NUMARCs comments.
SUMMARY
OF DISCUSSIONS AND AGREEMENTS The NRC would prefer to endorse an industry document (rather than proceed with a NRC regulatory guide), but only if it could be endorsed with no, or very few, exceptions.
Since the Industry Guideline is not acceptable in its present f.orm, the NRC will proceed with the parallel development of the Regulatory Guide.
NUMARC stated that they will consider the NRC comments and that the Industry Guideline document would be revised.
They plan to i
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complete the necessary changes and forward the revised document to the NRC by June 2, 1992.
NEXT SCHEDULED MEETINS The next meeting between the Steering Groups is scheduled for June 12, 1992.
At that meeting, the NRC will provide its evaluation of the revised Industry Guidance docament and expects j
to discuss plans for proceeding with either the industry document j
or the NRC Regulatory Guide.
i Richard P. Correia, NRC Coordinator for e
NRC/NUMARC Maintenance Interactions Performance and Quality Evaluation Branch Division of Licensee Performance l
and Quality Evaluation j
Office of Nuclear Reactor Regulation j
Enclosures:
As stated cc:
J.Sniezek J.Colvin (NUMARC)
W. Russell T.Tipton (NUMARC)
J.Heltenes C.McNeill (PEco) j R.Baer Distribution:
NRC meeting participants NUMARC meeting participants A.Vietti-Cook D.Trimble J.Scarborough j
Eileen McKenna j
E.Doolittle J. Kopeck PDR Central Files i
LPEB R/F i
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NRC/NUMARC MAINTENANCE RULE GUIDANCE DOCUMENT MEETING l
l' April 22, 1992 NAME ORGANIZATION TELEPHONE NO.
James Curtiss NRC Commissioner (410)SO4-1873 James Sniezek NRC/EDO (301)504-1705 Owen Rothberg NRC/RES (301)492-3924 Jack Roe NRC/NRR (301}504-1004 i
W.T. Russell NRC/NRR (301)SO4-1274 J.Heltemes NRC/RES (301)492-3720 Robert Baer NRC/RES (301)492-3930 Gary G.
Zech NRC/NRR (301)504-1017 Frank Cherny NRC/RES (301)492-3945 Corbin'A. McNeill PECo (215)841-4221 Tom Tipton NUMARC (202)872-1280 Walt Smith NUMARC (202)872-1280 Dan Rains NUMARC (202)872-1280 Carl Johnson NRC/RES (301)492-3548 Patrick O'Reilly NRC/AEOD (301)492-8858 Dave Trimble NRC/OCM/JC (301)504-1882 Charles Petrone NRC/NRR (301)504-1029 Tom Foley NRC/NRR (301)504-1036 Gilbert Zigler Science & Engineering Assoc.
(505)884-2300 Tom Ippolito Science & Engineering Assoc.
(505)849-8884 Tricia Heroux EPRI (703)536-0459 Lloyd Zerr STS (301)652-2500 David Stellfox McGraw-Hill (202)463-1600 F. Lobin General Physics (410)290-2332 Jack Scarborough OCM/Im (301)504-1850 Dennis DeBello BG&E (410)260-3919 David Army NUS (301)258-1817 Charles Willbanks NUS (301)258-1865 Kim Barnett Bechtel (301)417-3083 l
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April 22, 1992 NRC/NUMARC Maintenance Guidance Development Meeting i
Tentative Agenda 1
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o NRC preliminary comments on the Industry Guidelines o
NUMARC preliminary comments on the NRC Draft Regulatory
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o Industry and NRC final comments on the draft NRC and Industry guidance documents scheduled for May 15, 1992 o
Proposed next meeting date June 10, 1992 at 2:00 PM l
o Summary of discussions and agreements f
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