ML20042E188
| ML20042E188 | |
| Person / Time | |
|---|---|
| Issue date: | 04/13/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-PINV, TASK-SE SECY-90-137, NUDOCS 9004200363 | |
| Download: ML20042E188 (5) | |
Text
-
L
/ " '%4.!
RELEASED TO THE PDR e
el:
4h/A ek
\\,,,,,/i....?f.........T....i April 13, 1990 SECY-90-137 (Notation Vote)
For:
The Comissioners i
From:
James M. Taylor i
Executive Director for Operations i
Subiect:
PROPOSED CRITERIA TO BE USED IN DETERMINING WHEN INDUSTRY FROGRESS IN THE AREA 0F MAINTENANCE WOULD BE SUFFICIENT TO ODVIATE A NEED FOR RULEMAKING
Purpose:
To recomend to the Commission proposed criteria to be used by the staff in determining when industry progress in the area of maintenance Would be sufficient tu obviate a need for rule-making.
Background:
In SECY-89-143, dated April 28, 1989, the staff forwarded for
~~
Commission approval a final rule on the mainten6nce of nuclear power plants.
On June 26, 1989, the Comission announced its dtcision to hold the fir:61 rule in abeyance for an 18-month period while the NRC st6f f closely monitored the industry's progress in the area of maintenance.
At the end of the 18-mienth period, the staff w65 cirected to report back to the Comission on the progress that the industry made in improving maintenance and to provice recommendations or, the need, if any, for additional regulatory action.
4 On September 15, 1969, the Comission was briefed by the staff on the ' tatus of maintenance initiatives for nuclear power plants and the schedule for con'pletion cf the staff's 6ctivities.
Following this briefing, & staff requirements memorantum, dated September 29, 1989, requested that the staff recomend proposed criteria to be used in determining when l
industry progress is sufficient to obvi6te a need for i
rulemaking.
D_iscussion:
Significant f actor s to be considered iri this ottermination 1
cre (1) the pro the industry has mace in improving n.ainten6nce, (2) gress comitment the industry hbs made to the implementing bn accept 6ble maintenance standard, and (3) the commitment the industry has made to sustaining performance in the m61ntenance.rea.
NOTE:
TO BE MADE PUBLICLY AVAILABLE WHEN THE FINAL SRM IS }1ADE CONTACT:
AVAILABLE T. Foley, NRR 3
492-1036 T
nemkw J
3 -
The Commissioners 2-Assessment of the need for rulemaking will be based on several inputs, including (1) (2) ysis of current maintenance team anal inspection findings, reinspection of facilities with identified maintenance weaknesses. (3) analysis of performance indicators and their trends, (4) analysis of systematic 1
assessment of licensee performance ($ ALP) evaluations, and 1
(5) evaluation of industry's performance by NRC senior managers.
The staff has developed general criteria that will be considered in the determination of a need for a maintenance rulemaking.
These are described below:
J Criterion 1 - Licensees have effectively implemented. an ade-quate maintenance program or are committed to and proceeoing toward this goal.
Criterion 2 - Licensees exhibit a favorable trend in perform-ence re16ted to maintenance.
Criterion 3 - Licensees are committed to the implementation of a maintenance performance standard acceptable to the NRC.
Criterion 4 - Licensees have in place or are comitted to an evaluation program for ensuring sustained performance in the maintenance ereo.
Criteria Application:
in the event the staff concludes that all but a few licensees i
meet the criteria (e.g., not more than 10 percent fail to meet one or more of the criteria), the staff would-likely recomeno
]
a.
inst rulemaking.
For those few licensees who do not meet tae criteria, other regulatory action would be considered.
If fewer than 80 percent of the licensees meet the criteria (e.g., if there is not e satisfactory commitment from NUMARC) the staff would likely recomend - rulen.aking.
In the event that the results of the staff assessment are between these two
- examples, the staff would use its judgment in making a recomendation. The staff expects to be in a position to pro-vide the Commission with its recommendation by April 1,1991.
The following actions will be accomplished to assess whether the criteria to obviate a need for rulemaking have been met:
1.
Ev61uations:
The staff will complete its evaluations of the implementa-1 tion of the licensets' m61nten6nce programs through the maintenance team inspections.
1
The Consnissioners,
The staff will also evaluate inspection findings to determine the overall status of licensee programs and to identify common wecknesses (criteria 1, 2).
2.
Reinspections:
The staff will reinspect those facilities whose mainte-nance programs were previously assessed as being in need of significant improvement in the key elements of a maintenance process such as overall plant performance related to maintenance, management support, including engineering support of maintenance, and maintenance iniplementation.
These reinspections will examine licensee corrective action on previously identified weeknesses.
Licensees previously found to have good programs with good impla1nentation will be inspected as part of the engoing regional inspection program to ensure that performance has not deteriorated (criteria 1, 2, 4).
3.
Trends:
The staff will assess performance trenas, as follows:
a.
Review current SAlp evaluations related to maintenance and compare them with previous SALP evaluations (criterion 2),
j b.
Review curreat performance information utilizing the performance indicators for operating commercial nuclear reactors related to events involving mainten-ence.
Licensee event report cause codes in the niain-tenance area will also - be reviewea (criterion 2).
c.
Review tquipment performance data (e.g.
Proposed Maintenance Effectiveness indicator data) (criterion 2).
4.
Senior Management Evaluation:
The staff will obtain the evaluations of senior NRC management regarding the conduct of maintenance at nucle 6r power plants based on inspections, plant and equipment i
performance, and the status of licensee programs.
Each Regions 1 Administrator will provide the status of l-licensee maintenance performance at nuclear power plants in their region (criteria 1, 2, 4).
5.
Inoustry Programs:
The staff plans to closely follow industry efforts detciled in che NUMARC " industry Action Plan for Continued J ' :- -
I l
i 0
The Commissioners
-4 Improvement in haintenance of Nucisar Power Plants," dated Fearuary 16, 1990.
In particular:
a.
The Institute of Nuclear Power Operations is currently developing an Industry Maintenance Program Document to provide a basis for an industry standard.
The staff will review this document for its technical content and acceptability in identifying the essential ele-mentsofeffectivemaintenanceprograms(criterion 3).
b.
The staff will eyeluate the extent of incustry's efforts to iniprove, sustain, and verify adequate maintenance performence.
This includes the industry's progrcm to develop objective and quantifiable equip-ment performance sieasures that infer overall' maintenance effectiveness.
The staff will examine progress made in keeping with any commitment made to implen.ent a stancard.
The staff will assess methods that may be proposed by the industry for verifying the use and implementation of the Industry Maintenance Program Document or other standard and will evaluate the industry's processes for utilizing feedback from the program, and changes resulting from feedback mechanisms (programcriteria 3, 4).
Recommendation: The staff recommends that the Commission approve the above l
criterie and approach to assessing and determining when industry progress in the area of maintenance would be sufficient to obviate a need for rulemaking.
Courdination:
OGC has no legal objection to this recommendation.
Sw
./
mes M. Tay1 ecutive Di ector for Operations l
l
7 t
e e
e.
3
(
i
-s-4 F
f Commissioners' comments or consent should be provided directly l
to the Office of the Secretary by COB Monday, April 30, 1990.
p' Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Monday, April 23, 1990, with an.infor-mation copy to the Office of the Secretary.
If the paper is
. of such a nature that it requires additional time for analytical r
review and comment, the Commissioners and:the Secretariat should i
be. apprised of when comments may be expected.
t" DISTRIBUTION:
Commissioners OGC
~;
OIG LSS GPA REGIONAL OFFICES EDO ACRS ACNW ASLBP ASLAP SECY m
i
'k, 14 V
F l
l-1 l
._.