ML20042D052
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May 23, 1988 RULEMAKING ISSUE srcy-88-m I
(Notation Vote)
For:
The Comissioners From:
Victor Stello, Jr., Executive Director for Operations
Subject:
STAFF PLAN AND SCHEDULE FOR PROPOSED RULEMAXING FOR THE MAINTENANCE OF NUCLEAR POWER PLANTS
Purpose:
To inform the Commission of the plan and schedule for the proposed rulemaking for the maintenance of nuclear power plants. This letter responds to the Comission's direction (in memorandum Chilk to Stello, dated 2/25/88, M880107) for the staff to develop a proposed rulemaking on this subject.
Background:
On January 7,1988, the Commission was briefed by the l
staff on its proposed " Interim Policy Statement on Maintenance of Nuclear Power Plants" as contained in l p) g SECY-87-314. The staff proposed a two year trial period l
V to assess industry initiatives prior to initiating l
rulema king. The Commission, however, has directed the H
staff to develop a notice of proposed rulemaking by August 1, 1988, spelling out NRC's expectations in the area of maintenance.
In the process of developing the proposed rule, the staff was also asked to consider industry initiatives, conduct a workshop and review maintenance practices in other countries. Accordingly, the staff has developed an action plan in response to the Comission's directive. This paper describes the staff action plan and provides an opportunity for Comission review and comment on whether the plan meets the intent of and is consistent with the Commission directive.
Discussion:
Plan As directed by the Commission, the staff will develop a general rule that specifies requirements for the maintenance of nuclear power plants and allows industry initiatives to develop the details of maintenance programs to meet such requirements. The scope of maintenance activities addressed in the rule will be within the framework of the Commission's Policy O
CONTACT.:
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/g#Id Moni Dey, RES i
492-3730 I
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The Commissioners 2
i Statement on Maintenance of Nuclear Power Plants; however,
. the specific form and content of the rule is still under consideration. Consistent with the Policy Statement, the rule will apply to all components, systems and structures of nuclear power plants; however, specific requirements may vary commensurate with their safety significance.
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addition, the rule will be applicable to existing ana future plants and will require each licensee to develop, implement and raintain a mainterance program, to fccmally commit to folltu the progran and to oeveicp a process to measure and maintain its effectiveness.
Ir. support of the proposed rule, the staff will develop a Regulatory Guide that will provide guidance regardir.g ways to ccet i
the requirements in the rule.
Also, in support of the proposed rule but as a separate effort, the staff will continue its priority efforts to develop and validate maintenance performance indicators.
This activity is being corducteo as part of. the performance indicator program. However, in view of the integral l
coupling of this activity with the proposed maintenance rulemaking, the staff plans for performance indicators to f
monitor maintenance effectiveness will be provided in
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background discussion accompanying the proposed and final rulemaking pacicages for Commission and industry informatior.
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The status and plans for maintenance performance indicators will also be discussed in workshops with industry.
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As directed by the Commission, the staff, in developing
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the rule, will consider maintenance practices in other i
countries (Japan, France and FRG), and other industries (aviation) in this country in which human performance, maintenance and equipment reliability plays ar. important role in the safety of operations. These cer:siderations will be documented in a supporting NUREG report aions with other factors considered irrportant to document the development of the rule ana Reg. Guide.
Initial efforts wili be directed toward development of the notice of proposed rulemaking and will include draf ting the proposed rule and Reg. Guide, developing an outline of the supportine NUREG and developir.g the regulatory analysis.
As part of this initial effort, the staff will ccrduct a workshop witt, industry and the m
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V public on July 11-13, 1988 to solicit information and comments and will make contacts with other industries and foreign countries to gain any benefit of their experience.
Follow-on efforts, beyond development of the notice of proposed rulemaking package, will be to revise the proposed rulemaking in consideration of comments received, complete the Reg. Guide, regulatory analysis und supporting NUREG. This will then lead to a l
l tinal rulemaking package to be submitted for Commission approval. The ACRS shall be periodically briefed to obtain their input on the development of the proposed rule, Reg. Guide and HUREG.
A working group has been formed to carry out the staff effort for developing the proposeo rule.
RES has the lead for managing the efforts of the working group which consists of members from NRR, AE0D and RES. Consultation with regions and other headquarters offices, such as 0GC, i
that have an interest will also be sought during rule l
development. Coordination with other related rule development efforts underway will be maintained.
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! Q Schedule The enclosed schedule shows the steps for development of the proposed rule and for activities' leading to the final rule. A proposed rule will be submitted for Commission review by December 1, 1988. This represents a four month extension from the August 1, 1988 due date for a i
notice of proposed rulemaking requested in the 2/25/88 Chilk to Stello memorandum.
However, in consideration of the steps which need to be taken to comply with the Commission's direction (as outlined on the enclosed schedules, this appears to be the earliest date possible. The final rule is projected for submittal to the Commission by December 1989.
It should be noted that as part of developing the rot'ce of proposed rulemaking, the staff plans to keep the Cownission informed of progress and solicit feedback at key. decision
. points.
Specifically, the staff plans to provide the l.
Commission with information describing the options being i.
considered for the rule and Reg. Guide (this will be provided prior to the wcrkshop) and subsequent to the workshop will brief the Commission on the results of the workshop and the staff's recommended option for rulemaking.
It is expected that such interaction will, in the long m
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run, accelerate this rulemaking by having the benefit of the Commission's views prior to submitnng a propo nc notice of rulemal.ing for Conmissior. review.
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The Commissioners 4
Recommendation: The Commission endorse the above plan and scheoule for the rulemaking activity on maintenance. The staff has already initiated activities consistent with the above.
, [, 3s-:h:
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Victor Stello, Jr.
Executive Director for Operations
Enclosure:
Maintenance Rulemaking-Proposed Schedule Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Wednesday, June 8, 1988.
Cmmmission Staff Office comments, if any, should be submitted to the Commissioners NLT Thursday, June 2, 1988, with an infor-matioc copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical
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review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
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23350 jroposed Rules ra-i +
Vol. 53. No.109 Tuesday. June 7.1988 This section of the FEDERAL REGISTER
-What approach should NRC take in (14) Others contains notices to the pubhc of the developing a rulemaking on Working Group C: Maintenance i
i proposed issuance of rules and maintenance:
Monitoring. Assessment, and regulations. The purpose of these notices
- Prescriptive?
Effectiveness is to gue oterested persons an e GeneralGoals?
(1) Equipment history and trending i
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- Standardize Maintenance Practices?
(2) Surveillance P
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- PerformanceIndicators?
(3) Predictive maintenance rules'
-Ifow should the rule address the (4)Information feed-back loop various maintenance activities listed in (5) Measures of overall maintenance
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NUCLEAR REGUI.ATORY the Policy Statement?
program effectiveness l
CCMWSSION
-What defines a good maintenance (6) Effective communications structure
?
pr dustry/NRC data base a
10 CFR Part 50 aa d
g an effective Pub!!c Workshop for NRC Rulemaking Working Group D: Effective p
rgasational Communicadons q
on Maintenance of Nuclear Power
- How should the effectiveness of a i
(1) Communications between g
Plants maintenance program be measured /
mamtenance and:(a) Operations; h
monitoredf AG ENCY: Nuclear Regulatory (b) Corporate:(c) Corporate I:
Presentor's are also welcome t Commission.
engineering and desis:n.
9 address other areas related to the Action: Notice of workshop.
(2) Incorporation of vendor I
maintenance recommendations l
SUPAMARY: On March 23.1988. the 5 ues ion P riod.
l Commission published a final Policy Day 2: Working Group Sessions (9 (3) Engineering support and Statement on Maintenance of Nuclear am-5 pm).
modifications (e.g., cooperation, y
P The activities listed in the coordination, and support between f'ower Plants. In the Policy Statement.
e Commission stated it expected to Commission Policy Statement on mamtenance group and the
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blish a Notice of Proposed Maintenance of Nuclear Power Plants "ngineering/ design group),
l slemaking in the near future, and has have been grouped into four major (4) Interface and commumcations with contract maintenance serv ces directed the staff to develop such a areas. There will be parallel sessions of 4b Notice of Proposed Rulemaking. In order four Working Groups in each of these Note,'
to solicit information and comment from areas to discuss how they could be D
the public and regulated industry early addressed in a rule, regulatory guide All four working groups would be g
in the formulation of the proposed rule, and/or industry standard.
asked to focus on the follewing NRC plans to conduct a workshop.
Working Group A: Maintenance biectives:
CATES: July 11-13,1988.
Techno/Ogy (1) Discuss the important issues for an ADDRcSS:The Mayflower Hotel.1127 (1) Corrective maintenance effective maintenance program and tne Connecticut Avenue NW, Washington.
(2) Preventive maintenance approach for addressing these issues in DC 238.
[3] Predictive maintenance tu emagng.
3 (4) Surveillance (2) Provide information regarding t
(5) Post-maintenance testing acceptable ways to adequately address i
FOR FURTNErt INFORMATION CONTACT:.
Moni Dey. Office of Nuclear Regulatory (0) Others these issues and acceptance criteria that C
t Research. U.S. Nuclear Regulatory Working Group B: Afaintenance could be included in a rule, regulatory s
Commission. Washington. DC 20555.
Afanagement. Planning, and guide or industry standard.
Telephone (301) 492-3730.
Oganizat/on (3) Provida information regarding
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SUPf%EMENTARY LNFORMATION* The (1) Procedures industry's initiatives as they relate to s
following is the a;;cnda for the (2) Planning each one of these issues and areas.
I workshop.
(3) Scheduling (4) Prepare a brief report summarizing c,
Day & General Session (9 am4 pm).
(4) Staffing highlights of their discussion (to be c!
- 1. Introduction and opening remarks (5) Shift coverage prepared by the working group a!
by the Workshop Chairman.
(6) Allocation of resources chairman).
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- 2. Remarks by NRC Commissioner.
(7) Personnel qualification and Each working group will be asked to 3I 3.NRC Approach Schedule and training address a specific set of questions f
Options for Maintenance Rulemaking.
(B) Record keeping related to its topic area.
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- 4. Presentations by the Public and (9) Management of contract Day 3: Final Session (9 am-12 noon).
- Industry, maintenance services
- 1. liighlights of Working Group A:
Statements and comments by the (10) Management of spare parts, tools.
Working Group A Chairman.
public and industry on items pertaining facilities, and equipment
- 2. Highlights of Working Group B:
f%o the rulemaking are requested.These qualifications W;rking Group B Chairman.
)iy be of a general or specific nature.
(11) QA/QC
- 3. Hjhlights of Workin; Group C:
O t
(/ rhe following are specific questions (12) ALARA considerations Working Group C Chairman.
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.d topics which are ofinterest and (occupational exporu cs)
- 4. liighlights of Working Group D:
j which the NRC desires to have input on:
(13) Reporting requirem ents Working Group D Chairman.
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Federal Register / Vol. 53. No.109 / Tuesday. June 7,1988 / Proposed Rules 20857
- 5. Cencral Comment Period.
FOR FURTHER INFORMATION CONTACT:
While export trading incorporates S
Chairman.
ti Concluding remarks by Workshop Robert N. Rev. Economist. Size elements of both wholesahng and Standards ' Staff. (202) 6534373.
certain business services. like market Those members of the public who Sheryl J. Swed. Director. Office of research, product design. insurance, wish to attend the workshop should International Trade. (202) 653 779t freight forwarding. etc. SBA beheves it notify the contact listed above. In.
is sufhciently unique, and other possible addition, those members of the public SUPPLEMENTARY INFORM ATION:6ince th" size standards so inappropriate, that the who wish to make a presentation'on enactment of the " Export Trading ETC/EMC activity warrants its own sue Day 1. or who wish to be a member of Company Act" in 1982. Pub. L.97-270.
standard. Compared to cons en4ional any of the Working Groups on Day 2 of there has been interest in the formation dome.stic wholesalers. ITTCs perform the Workshop should indicate their of such companies.SBA has attempted many functions beyond wholesal.ng. p t preference to the contact listed above so to encourage exportingby small typicaily do not handle the s olumes of that they can be added to the agenda.
businesses, including but not limited to.
most wholesalers. They also provide Early notification is recommended since ETCs/EMCs. through a variety of more than export-related business requests wdl be processed as they are programs. such as:
services in that they often ti.ke title to '
received.
goods and provide storage facilitis.
- Export Revolving Lines of Credit t Thus the uniqueness of this actaitv and Dated in Rockvdie. Maryland. this lu day guarantee loans made by private lenders the special attention accorded it ur$ der te o lunt tw of up to $500.000. and in conjunction For the Nuclear Regulatory Commisuon-with the Export-!mport' Bank, of loans up fg]..
." m *P[..h}"[
g Muni Dey.
to S1.000.000.
amh TasA Manager. AdrancedReactors e Generic
. Other regular business loans of up Whe$n researching an industry for sin issues Branch. Division of Regulatory to $500.000 through the SBNs 7(a) Loan Mplicatwr:s. Office of Nuclear Regulatory Guarantee Program' Rc.*urd generally accepted published statistiul
= Business Development assistance sources 'such the Census Bureau.
if.R Doc. 8&lr84 i,ded 0468. B 45 aml tailored to meet the needs of exporters Internal Revenue Service. SUNS Sm.dl sumo coes 7590 *"
through counseling by volunteers Business Data Base, and simihir son'en
- (SCORE / ACEL. Small Dw.iness for a desenption of the economic SMALL BUSINESS ADMINISTRATION Dese opment Centers.
do not comprise an indastry in the sensa 13 CFR Part 121
- Legal consultation including free of be ng recognized in the " Standard initial wnsultations provided through an Industnal Classif cation Manual." the Eize Standard for Export Trading agreement between the Federal Bar typical statistical sources do not col let t
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g Companies and Export Management Association's International Law Council data on the structure of this activity.
t Companies and SBA.
Normally, data on the number of firms.
\\f Export training. international trade average firm size by sales and ActNCY:Small Dusiness Administration ISDA)~
missions, publications, and other employees, distribution and range of services provided by SDA.
firm sizes, and primary line of business ACTRON: Proposed rule.
This assistance is not limited to firms are essentialin formulating a size
$UMMARY:SBA is proposing to establish f rmally organized or certified as ETCs standard (see 13 CFR 121.1).
1 a size standard of $10 million for under the " Export Trading Company As a substitute for these data. SDA Act" i1982.1t applies to any small firm has obtained information from
" Export Trading Companies and Export Management Companies (ETCs/EMCs/
which exports or intends to export. For secondary sources. These include: A
)." Currently. SDA has no small business purposes of this rule. the terms "EMC 1980 survey by the National Association j
definition for such firms. Because of the and ETC" are used interchangeablu of Export Companies (NEXCO), a trade increased interest in exporting and the ETCs usually purchase goods frua <.
group; a survey conducted in 1983 by
't uniqueness of these types of firms. SBA manufacturer, take title, and sell abu Coopers and Lybrand, an accounting S me. however. do not take title, but firm: and "The Export Company wishes to establish a size standard to clarify the size status of ETCs/EMCs.
w rk on a commission and/or fee basis.
Guidebook" on ETCs prepared in 1984 The intent of this rule is to determine ETCs act as the export arm for small by Price Waterhouse and the Council for which firms would be eligible for SDA's and medium sized manufacturers. Such Export Trading Companies for the financial assistance and other programs. manufacturers are generally too small to Commerce Department's International 1
DATE: Comments must be submitted on set up their own export activities and Trade Administration.
or before August 8.1988.
I ok to ETCs to market their products First, the NEXCO survey obtained
"' U ADDRESS: SEND AU. COMMENTS TO:.Cary mtermediaries to facilitate the exports members. NEXCO found that the M. Jackson. Director. Size Standards of small business. It is for this reason average volume of export sales ranged b'
Small Du ne s from 58 million to $17 million per firm that SDA is interested in fostering ETCs gd i R e R %' @ m E M ~
and in devel ping a size standard for with the 5b10 million size category.
these types of businesses.
containing 19 firms, as the mode.
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