ML20045H108
| ML20045H108 | |
| Person / Time | |
|---|---|
| Issue date: | 06/01/1993 |
| From: | Newsome J NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Mate J NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20045H096 | List: |
| References | |
| FRN-58FR33993, RULE-PR-50 AE55-2-005, AE55-2-5, NUDOCS 9307190069 | |
| Download: ML20045H108 (8) | |
Text
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s RE.OS q
?DR June 1, 1993' NOTE TO:
Joseph Mate, R.
FROM:
Hampton Newsom.
GC
SUBJECT:
COMMENTS ON MAINTENANCE RULE AMENDMENT FINAL PACKAGE I have enclosed my comments (as marked) on the final rule package.
If you have any questions or concerns, please call me (504-1623).
Thank you, i
L 9307190069 930701 PDR PR 50 5BFR33993 PDR
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4 from the refueling activities could be factored into the evaluation. The refueling cycle has also been adopted as the basis for FSAR updates.
It is recognized that those licensees who refuel more frequently will have to conduct these activities more frequently than others.
In the view of the Commission, this is neither an undue burden nor one that is outside the control of the licensee to impact by reducing the frequency of refuelings.
2.
Comment.
As a result of the verification and validation program to test the proposed industry guidelines, it was determined that several systems are neither risk-significant nor able to be monitored for performance by currently known plant level performance criteria. Since these systems have no public health or safety significance, they should be excluded from the scope of the rule and the rule modified accordingly.
Response. The suggestion to change the scope of the rule to exclude those systems that have no public health or safety significance or that have no current performance level criteria is clearly beyond the scope of the proposed amendments to the rule and cannot be considered at this time.
K m._ -
s However,^as a result of further verification and validation programs conducted atfacilities,[f7changestotheruleorregulatoryguidancearewarranted, the NRC will consider such changes at that time.
3.
Comment. One of the commenters stated, "one of the clear lessons learned from the recently completed verification and validation program is that the major expense of the rule's implementation will be the detailed documentation (for NRC audit purposes) of performance monitoring".....
Response. The purpose of this rule is not to address the level of documentation required for NRC audit purposes.
It is merely to provide more l
flexibility in the timing of fiaintenance Program evaluations.
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One of the commenters stated that 4he NRC is mesmerized by (LEqf Ml 4.
Comment.
pVp the Nuclear Management and Resources Council -(NW,ARpf suggs:4 hn to extend the annual assessment of plant maintenance from an annual schedule to a refueling J
outge schedule.#The commenter further states that the extension does not provide an improvement in safety and may help hide maintenance which was improperly deferred.
f Response.
As stated earlier, the NRC decided to make the proposed change in the assessment requirement for the following reasons:
(1) Evaluation of data collected over the period of a refueling cycle will provide a substantially better basis for detecting problems in degraded performance of structures, systems, and components (SSC's) and weakness in maintenance practices, (2) Evaluations conducted on a refueling cycle basis would also consider and integrate data available only during refueling outages with the data available during operations; under the existing requirements this may not occur depending on whether the annual assessment coincides with the refueling outage, and (3) Evaluation of data accumulated over the period of a refueling cycle, as opposed to the shorter annual period required by the rule, will provide a more meaningful basis for the recognition and interpretation of trends.
In addition, adjustments to maintenance activities that may be made after such a review and evaluation would be typically performed after a refueling outage.
Periodic evaluations of maintenance activities is a time consuming process and with limited data available, the annual evaluations not conducted in conjunction with a refueling would not provide for as meaningful a result. The NRC's rationale, in this respect, differs from that advocated by HUMARC. Therefore, the commenter incorrectly 7
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Section (a)(1) of 10 CFR 50.65, which is not being changed, requires licensees to monitor the performance or conditions of structures, systems, or j
components, ahAinst licensee-established goals, in a manner sufficient to N
provide reasonable ass'urance that these structures, systems, and components are capable of fulfilling thdir intended functions.
It also requires appropriate corrective action to be aken when the performance of the structure, system, or component does not meet established goals. The only thing that is being changed is the frequ\\ency of the periodic evaluation of the maintenance program. The NRC does care abo'ut safety and it does not agree
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with the commenter that changing the evaluation cycle sends the wrong message
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l to the industry. The NRC believes that this ad'ditional flexibility will not
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result in any increase in risk to public health a'd safety, and in fact, pTL anwhe n
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erIb zd % f should result in a more effective maintenance and i roved plant safety.
6.
Comment. Oneofthecommentersstatedthatpnts-en-a-24: month reftteNy cycle-would-not-meet themax-imum-time-period-of44-months.gfatherc._
the Standard Technical Specification, Revision 0, retains the option for l
performance of strveillance requirements withinLJ p n utw cx 2.y < wnA cM?q Cth(
.25 times the 'nterval l
cmd h cld specifiedgAThtowould extend the refueling outage interva@y upwards of
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6 months.AAnothercommenterstatedthatthisrulecouldbefurtherimproved q
by the elimination of the requirement for a specific time interval.
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Response.
The Commission believes thatAis necessary to assure that maintenance effectiveness is periodically assessed and that this period is not unacceptably long nor indefinite. Thus, a balance was necessary between
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obtaining the improved reviews associated with assessments conducted during refueling outages and the extended or indefinite periods associated with plants with extended plant cycles or experiencing extended plant shutdown or GCbm h^M R h^b N 4 /kcard
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In weighing this balance, the Commission established an upper limit of 24 months between maintenance evaluations in o er to obtain improved evaluations for the majority of the plants having4 frequency of refueling cycle from 15 to 18 months, and yet not allow maintenance effectiveness to continue without being assessed for periods in excess of 2 years. The NRC does not agree that the rule could be improved further by elimination of the requirement of a specific time interval.
Finding of No Significant Environmental Impact:
The Commission has determined that, under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Subpart A of 10 CFR Part 51, that this rule, if adopted, would not be a major Federal action that significantly affects the quality of the human environment and therefore an environmental impact statement is not required.
The final amendment does not require any change to nuclear power plant design or require any modifications to a plant. Nor does the rule change the scope of the maintenance rule or affect the nature of the activities to be performed, e.g., monitoring, corrective action, and assessments of compliance.
The final rule change would only extend the time period for performing evaluations of the effectiveness of licensees' maintenance program from at least once a year to at least once every refueling cycle, not to exceed 24 months. The extension should not result in any significant or discernible reduction in the effectiveness of a licensee's maintenance program; rather the change would increase the meaningfulness and quality of the maintenance evaluations.
For these reasons, the Commission finds that the final amendment 10
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[7590-01)
NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 RIN 3150 - AESS Monitoring the Effectiveness of Maintenance at Nuclear Power Plants AGENCY: Nuclear Regulatory Comission.
og ACTION:
Final rule.
m g
SUMMARY
- The Nuclear Regulatory Commission (NRC) is amending its regulations for monitoring the effectiveness of maintenance programs at comercial nuclear power plants. The current regulations require that nuclear power plant licensees evaluate performance and condition monitoring activities and associated goals and preventive maintenance activities at least annually.
This amendment changes the time interval for conducting evaluations from a mandatory once every year to at least once every refueling cycle, but not to exceed 24 months.
$ h,
+h )date of publication 4 EFFECTIVE DATE:
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966 sosex+
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will not result in any significant increase in either the probability of occurrence of an accident or the consequences of an accident and therefore i
concludes that there will be no significant effect on the environment as a l
result of the amendment.
The environmental assessment is available for inspection at the NRC Public Document Room, 2120 L Street NW. (Lower lovel), Washington, DC.
i.f Single copies of the environmental assessment are available from f
r' Joseph J. Mate, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory j'-
Commission, Washingter., DC 20555, telephone: (301) 492-3795.
I I
I Paperwork Reduction Act Statement i
This final rule amends the information collection requirements that are 1980 (44 U.S.C. 3501 et seq.). % s subject to the Paperwork Reduction Act of
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Office of Management and BudgeW-r"ev ewand.
al o'f h'e pa'pe'rwork requirements.
(J Because the rule W44 rela existin, requirements related to the c-co/kW the4 urden for this erHvity of assessment of maintenance activities b
information is expected to be reduced by 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> per licensee. This reduction includes the time required for reviewing instructions, searching existing data sources, gathering and maintaining the data needed and completing and reviewing the collection of information. Send comments regarding the estimated burden reduction or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (MNBB-7714), U. S. Nuclear Regulatory Commission, Washington, DC, 20555; and to the Desk Officer, Office 11 I
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