ML20045J007
| ML20045J007 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/1993 |
| From: | Correia R Office of Nuclear Reactor Regulation |
| To: | Zech G Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9307220267 | |
| Download: ML20045J007 (22) | |
Text
-
o O
O NAY 17'3993 Memorandum To:
Gary G. Zech, Chief Performance and Quality Evaluation Branch Division of Reactor Inspections and Licensee Performance Office of. Nuclear Reactor Regulation From:
Richard P. Correia, Chief Section B Performance and Quality Evaluation Branch Division of. Reactor Inspections and Licensee Performance
- 1 Office of Nuclear Reactor Regulation
SUBJECT:
PRESENTATION TO EPRI NUCLEAR PLANT PERFORMANCE IMPROVEMENT I
SEMINAR J
Enclosed are the presentation slides that were used by Tom Foley of Section B at the subject seminar on May 10, 1993. A previous memorandum (dated March 22, 1993), regarding the presentation and slides stated that the seminar' I
was to be held on April 10, 1993.
Original signed by:
Richard P. Correia j
i Richard P. Correia, Chief I
Section B Performance and Quality Evaluation Branch 1
Division of Reactor' Inspections and Licensee Performance Office of Nuclear. Reactor Regulation
Enclosure:
Maintenance Rule in the Balance of Plant DISTRIBUTION:
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THE MAINTENANCE RULE IN THE BALANCE OF PLANT o
PRESENTATION TO EPRI NUCLEAR PLANT PERFORMANCE IMPROVEMENT SEMINAR SCOTTSDALE, ARlZONA gn req #
O Thomas Foley 8
Performance and Quality Evaluation Branch XA o.
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Division 1of Reactor Inspection
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and Licensee Performance Office of Nuclear Reactor Regulation
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L DISCUSSION TOPICS o
1 I.
MC'I\\ITO all\\ G THE EFFECTIVENESS C'F MAINTENANCE II. IMPLEMENTATION ACTIVITIES O
Ill.
IMPACT ON THE BALANCE OF PLAl\\T (Slide 1) u.
I. MAINTENANCE RULE BACKGROUND 1
MAINTENANCE RULE 10 CFR 50.65 ISSUED ON O
JULY 10,1991, TO BE EFFECTIVE JULY 10,1996 EMPHASIS ON RESULTS VS. PROCESS
. REQUIRES MONITORING THE EFFECTIVENESS OF MAINTENANCE ACTIVITIES e
SCOPE INCLUDES EQUIPMENT WITHIN THE O
BALANCE OF PLANT (NON-SAFETY-RELATED) AS WELL AS SAFETY RELATED EQUIPMENT-e INTEGRATES CONSIDERATION OF RISK INTO THE MAINTENANCE PROCESS (Slide 2)
9 SCOPE OF THE RULE 1
SCOPE INCLUDES:
ALL SAFETY RELATED SSCs
-e ALL NON-SAFETY RELATED SSCs o
4
.WHOSE FAILURE COULD CAUSE A SCRAM OR ACTUATION OF A SAFETY SYSTEM i
WHOSE FAILURE COULD PREVENT SAFETY-C)
RELATED SSC FROM P.ERFORMING: ITS i
FUNCTION 1
THAT MITIGATE LACCIDENTS OR. TRANSIENTS-OR ARE USED IN EOPS 4
(Slide 3)'
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RESULTS-BASED RULE e. REQUIRES PERFORMANCE GOALS TO BE SET AND MONITORED BY LICENSEE O
e GOALS ARE TO BE COMMENSURATE WITH SAFETY SIGNIFICANCE AND (WHERE PRACTICAL)
INCORPORATE INDUSTRY EXPERIENCE e
OBJECTIVES IMPORTANT SYSTEMS REMAIN FUNCTIONAL O
FACILITY OPER ATION IS WITHIN THE ASSUMPTIONS OF SITE SAFETY ANALYSIS (Slide 4) w r-m-
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. RESULTS-BASED RULE (Cont.)
e PERFORMANCE GOALS / CRITERIA CONSIDER RELIABILITY g
AVAILABILITY PERFORMANCE PARAMETERS CONDITION MONITORING (D
OVERALL PLANT SAFETY 1
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WHAT THE RULE DOES PROVIDES A BASIS FOR LICENSEES AND NRC TO VERIFY EFFECTIVENESS OF M AINTENANCE ACTIVITIES REQUIRES CORRECTIVE ACTIONS TO ADDRESS RESULTS OF MONITORING AND ASSESSMENT BROADENS THE REGULATORY FRAMEWORK FOR ENFORCEMENT OF MAINTENANCE O
PROVIDES REGULATORY ATTENTION TO THOSE
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AREAS IDENTIFIED AS WEAK BY MTis (Slide 6)
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WHAT THE RULE DOES NOT DO e
DOES NOT FOCUS ON ADEQUACY OF PROGRAM, PROCEDURES, OR ADMINISTRATION OF THE PROGRAM DOES NOT PRESCRIBE QU ANTIT ATIVE l
PARAMETERS AS CRITERIA OR REQUIREMENTS D.O E S N O T R E Q U I R E T H E S U C C E S S F U L l
ATTAINMENT OF SET GOALS t
e DOES NOT REQUIRE ANY PARTICULAR METHOD "O
OR PROGRAM.TO BE USED DOESLNOT. MANDATE: REDUNDANT TESTING OR SURVEILLANCE REQUIREMENTS (Slide 7)
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MAINTENANCE RULE PROVISIONS 50.65 (sX1) MONITORING AND GOAL SETTING e
GOALS ARE TO BE ESTABLISHED BY THE LICENSEE O
GOALS ARE TO BE PERFORMANCE ORIENTED (RELI ABILITY / AVAILABILITY)
OR CONDITION ORIENTED (PARAMETERS)
GOALS ARE TO BE COMMENSURATE WITH SAFETY SIGNIFICANCE WHERE PRACTICAL, TAKE INTO ACCOUNT O
INDUSTRY-WIDE OPERATING EXPERIENCE WHEN PERFORMANCE OR CONDITION OF THE SSC DOES NOT MEET THE ESTABLISHED
- GOAL, APPROPRIATE CORRECTIVE ACTION MUST BE TAKEN (Slide 8)
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50.65 (a)(2) PREVENTIVE 1
l MAINTENANCE l
MONITORING (PER (a)(1)) IS NOT REQUIRED FOR:
O SSCs WHOSE PERFORMANCE IS EFFECTIVELY CONTROLLED BY. PREVENTIVE MAINTENANCE 1
ACTIVITIES OR ARE OF LOW-RISK SIGNIFICANCE MAINTENANCE PREVENTABLE FAILURES WOULD INDICATE THE NEED FOR GOAL SETTING AND
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t 50.65 (a)(3) EVALUATION AND ADJUSTMENT ACTIVITIES e
GO ALS, MONITORING, AND PREVENTIVE MAINTENANCE ACTIVITIES TO BE EVALUATED AT O
LEAST ANNUALLY' e
INDUSTRY EXPERIENCE TO BE CONSIDERED CORRECTIVE ACTION TO BE TAKEN IF GOALS ARE 3
NOT MET AN EVALUATION OF THE EFFECT ON PLANT SAFETY SHOULD BE MADE WHENEVER ANY SSC g
IS TAKEN OUT OF SERVICE FOR MAINTENANCE Industry. proposal to amend rule. to every refueling l
cycle not.to exceed 24 months (Slide 10)
(a)(3) ANNUAL ASSESSMENT (cont.)
BALANCE THE PREVENTION OF FAILURES 1
AG AINST UN AVAILABILITY OF SSCs (i.e.
RELIABILITY VS. AVAILABILITY)
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ADJUST M AINTEN ANCE ACTIVITIES TO APPROPRIATELY-BALANCE RELIABILITY AND UNAVAILABILITY
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IMPLEMENTATION ACTIVITIES INTERACTIONS WITH THE INDUSTRY O
e NRC REGULATORY GUIDE RELATED ACTIVITIES i
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NRC MAINTENANCE INSPECTION PROCEDURES-
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INTERACTIONS WITH INDUSTRY NRC FORMED STEERING GROUP TO OVERSEE REGULATORY GUIDE DEVELOPMENT AND TO INTERACT WITH NUMARC ON THE INDUSTRY O
GUIDELINE DEVELOPMENT EFFORT (8/91 - 7/92) e NRC STEERING GROUP INFORMED COMMISSION OF INTENT TO ENDORSE NUMARC GUIDELINE (7/92)
NUMARC CONDUCTED VERIFICATION AND o
VALIDATION (V&V) EFFORT ON GUIDELINE WITH EIGHT UTILITIES PARTICIPATING (8 - 12/92) e LESSONS LEARNED FROM V&V REFLECTED IN PROPOSED CHANGES TO INDUSTRY GUIDELINE (3/93)
(Slide 13)
=
NRC REGULATORY GUIDE ENDORSES INDUSTRY IMPLEMENTATION
. GUIDELINE 0;
e OFFERED FOR PUBLIC COMMEN i (11/92 - 1/93)
RESPONSES FROM 11 ORGANIZATIONS SCHEDULED TO BE ISSUED BY JUNE 30,1993 10 4
'h (Slide 14)
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RELATED ACTIVITIES EMERGENCY DIESEL GENERATOR (EDG)
RELIABILITY (SBO RULE) AND RESOLUTION OF GENERIC ISSUE B-56 STAFF OUTLINED FOR THE COMMISSION FIVE OPTIONS p"3 AND PROVIDED STAFF RECOMMENDATIONS INDUSTRY GUIDELINE AND REGULATORY GUIDE FOR MAINTENANCE RULE MODIFIED TO PROVIDE GUIDANCE FOR EDG SURVEILLANCE AS AN ALTERNATIVE TO RULEMAKING e
LICENSE RENEWAL RULE
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O SECY 93-049 DESCRIBED STAFF PROPOSALS FOR LICENSE RENEWAL IMPLEMENTATION MAINTENANCE RULE IMPLEMENTATION A KEY FACTOR IN l
INTEGRATED PLANT ASSESSMENT (IPA) PROCESS AS AN EFFECTIVE PROGRAM TO M AN AGE AGE-RELATED DEGRADATION l
(Slide 15) l
NRC MAINTENANCE INSPECTION PROCEDURES INTERIM PROCEDURE ISSUED 1/93 TO BE USED o
UNTIL RULE EFFECTIVE DATE NEW PROCEDURE TO BE DRAFTED AFTER REGULATORY GUIDE ISSUED e
PUBLIC. WORKSHOP BY JUNE 1994 FOR COMMENT ON DRAFT PROCEDURE O
PILOT INSPECTIONS BEGINNING LATER PART OF 1994 TO VALIDATE PROCEDURE l
(Slide 16)
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7 III.
IMPACT ON BALANCE OF PLANT T
O e
REQUIRES ADDITIONAL FOCUS ON BALANCE OF i
PLANT COMPONENTS INCLUDES ONLY SSCs WHOSE. FUNCTION CAN AFFECT PLANT SAFETY SCOPE BOUNDED BY FUNCTION OF SSC; FOR EXAMPLE, TERMINATES AT INTER-TIE WITH OFF-O SITE POWER, BUT INCLUDES THE SWITCHYARD GOALS / CRITERIA CAN BE AGGREGATED TO A PLANT, SYSTEM OR TRAIN LEVEL (S'lide 17):
i
b 111. IMPACT ON BALANCE OF PLANT (Cont.)
1 REQUIRES CORRECTIVE ACTION FOR INITIAL
. O FAILURES ENCOURAGES THOROUGH AND EFFECTIVE i
CORRECTIVE ACTIONS FOR INITIAL FAILURE REP'ETITIVE FAILURES REQUIRE:
CAUSE ANALYSIS O
GOALSLTO BE ESTABLISHED l
SPECIFIC MONITORING GREATER MANAGEMENT. ATTENTION TO
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PROBLEM COMPONENTS (Slide 18)
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111. IMPACT ON BALANCE OF PLANT (Cont.)
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i REQUIRES ASSESSMENT OF BOP SYSTEM 1
O A V AI L A BI LITY A N D A S S E S S M E N T LO~F MAINTENANCE PERFORMED DURING EACH CYCLE 1
e REQUIRES BALANCING AVAILABILITY AND RELIABILITY l-EXPECTED RESULTS INCLUDE:
O LESS CORRECTIVE MAINTENANCE MORE EFFECTIVE PREVENTIVE MAINTENANCE ANDLCONDITION MONITORING (Slide 19)-
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e EXPECTED RESULTS (Cont.)
GREATER RELIABILITY OF SECONDARY PLANT COMPONENTS FEWER PLANT TRANSIENTS AND REACTOR O
TRIPS IMPROVEMENT IN OVER ALL PL ANT AVAILABILITY IMPROVEMENT IN THERMAL PERFORMANCE O
IMPROVED OVERALL PLANT SAFETY e
(Slide 20)
.