ML20055F862
| ML20055F862 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Carr, Roberts, Rogers NRC COMMISSION (OCM) |
| References | |
| FRN-56FR31324 AD-2-8, AD00-2-008, NUDOCS 9007190309 | |
| Download: ML20055F862 (5) | |
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-1 NUCLEAR REGULATORY COMMISMhiASED TO THE PDR
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- . drh o cp April-26, 1990 kble,
inish OFFICE OF THE
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commissioner
[g COMJC-90-f
' MEMORANDUM FOR:
Chairman Carr Commissioner Roberts Commissioner Rogers Commissioner Remick 1
,o TROM:
James R. Curtiss M.
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SUBJECT:
NUCLEAR POWER P T MAINTENANCE
- n COMJC-89-13, I recocmended for your consideration two alternative conceptual approaches on the subject of maintenance at. nuclear power plants and suggested that we direct the staff to.
develop each of-these two concepts in more detail for Commission c:nsideration.
Option 1 would be a reliability-based, results-Oriented' rule; option-2 would be a maintenance rule focused on poor performers.
I' recommended this course of action because of a concern on my part that at'the conclusion of the current 18-month evaluation period provided for in the Commission's Policy Statement on Maintenance, we will be faced with what I consider to be an
- unacceptable 1"either-or" choice
Either promulgate a highly-prescriptive,: process-oriented regulation along the lines of.what the' staff has been-directed toJdevelop, which would apply to.all
-utilities, good or bad; or defer to the industry to take the lead on maintenance.
.Since.I circulated COMJC-89-13, I have had the opportunity to discuss-the concept of a reliability-based, results-oriented approach-to maintenance in more detail with those who have had considerable experience in this arena.
Additionally, I have spoken ~with each of you individually about the two conceptual approaches outlined in COMJC-89-13.
Your1 comments and suggestions have proven to be most helpful.
Based upon these discussions, I continue to believe that we should direct the staff to flesh out both of the conceptual approaches originally outlined in COMJC-89-13, with some minor refinements, for our consideration.
Accordingly, I would
, recommend that we direct the staff to develop proposed rules, together with the supporting analysis and documentation, along the lines of the two options set forth in the attachment.
You will note that option 1, the reliability-based, results-oriented rule, has been modified to respond to the concern over our ability to establish numerical reliability requirements for key l
plant equipment.
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YOO7190309 900426
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PDR' COMMS NRCC r
CORRESPONDENCE PDC L
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.As I-suggested'in COMJC-89-13, I would propose-that'we'ask the staff to-submit these two alternatives to the Commission at the same time that the staff submits the proposed. rule that it is:
! currently developing.-.Then, in the event that the commission-
~ hould' decide at the conclusion of the 18-month evaluation period s
.that a rule is necessary or appropriate, fwe will have before us ~
i three options, developed in similar detail, to evaluate.
1ECY, please track.
Attachment:
as stated cc:
v sv f1-MAINTENANCE RULEMAKING ALTERNATIVES OPTION 1 --' RELIABILITY-BASED, RESULTS-ORIENTED RULE Elements of Rule:
Rule.would require thatsthe reliability of key plant e
equipment -- at the system, component, or functional level, as appropriate -- be periodically assessed in a disciplined The assessment must be capable of highlighting manner.
problematic equipment and should consider adverse performance trends, as might be indicated during surveillance-or ISI/IST testing, as well as failure information.. Licensees would be encouraged to establish meaningful reliability goals as a tool to encourage improved maintenance performance-and to highlight reliability.
j problems.
l Systems / functions covered by the rule would include safety
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re'.ated equipment, as well as non-safety related equipment i
whose failure could cause significant' challenges to safety related equipment.'
Rule would be sufficiently flexibile to permit licensees to define the scope of equipment to be covered within the systems, using accepted methodologies, such as the EPRI RCM program, to identify " critical" 3'
components within systems.
Licensees would be required to establish a mechanism for-l p
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ensuring that the information obtained from their reliability assessments is fed back.into their maintenance j
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programs.
Root cause analyses and, where necessary, j
reassessments of the adequacy of maintenance and l
surveillance activities would be required for significant-i c
adverse trends and failures.
h Rule kould recognize the strong nexus between reliability-l e
based maintenance and Technical Specifications (TS),
particularly the key role of surveillance and Section XI i
q (ISI/IST). testing in identifying-reliability problems and L
the-role of TS in controlling allowed equipment outages.
L Rule would require licensees to request changes to their L;
_TS in cases where TS requirements are found to potentially-degrade. reliability or where changes are necessary to I;
improve reliability.
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' I would note that the staff, in its current effort to i
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develop a maintenance rule and associated regulatory guide, is already pursuing an approach to defining the scope of non-safety related equipment that is of concern from a maintenance L
standpoint.
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The rule would be non-prescriptive, focusing on results rather than methods.+
It is based upon the key principle of a' proven, reliability-based approach to maintenance that has been used successfully in the aircraft industry forL20 years.
Its success does not depend.upon the use of reliability nunbers.
Instead.it relies upon_the establishment of a strong performance monitoring 1and feedback process.
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This' approach would complement, and could draw upon, work already underway in the IPE and technical specification improvement programs (including the risk-based technical specification program).
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1 OPTION 12 -- MAINTENANCE RUL2'FOR POOR PERFORMERS Elements of Rulti Rule would. include a mechanism to apply maintenanca-e requirements to those licensees that the NRC determines are j
performing poorly in the' area of maintenance.
E Performance in the area of maintenance would be evaluated e
through a. process similar to that. currently used to-identify; problem plants, with a " trigger mechanism" established to ' '
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. identify-those' poor performers who would be requiredito H
i comply with the established maintenance requirements.
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2 The substantive requirements to be imposed by the rule would be established independent of the' development of this concept.
The focus of this effort would be on establishing the procedural aspects-of the rule which would apply whatever
-substantive maintenance requirements are established to poor
, performers.
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