ML20055F869

Staff Requirements Memo Commenting on COMJC-90-3.Agrees W/ Option 1 That Maint Program Should Have Systematic & Disciplined Process for Identifying Key Plant Equipment

ML20055F869
Person / Time
Issue date:	05/04/1990
From:	Carr K NRC COMMISSION (OCM)
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR31324, REF-10CFR9.7 AD-2-9, AD00-2-009, COMJC-90-003, COMJC-90-3, DD-2-9, NUDOCS 9007190315
Download: ML20055F869 (2)

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CHAtAMAN May 4, 1990 i

i MEMORANDUM FOR:

Samuel J. Chilk Secretary of the Comission FROM:

Kenneth M. Carr

SUBJECT:

COMMENTS ON COMJC-90-3 I agree with the general objective of Comissioner Curtiss' option 1, that each maintenance program should have a systematic and disciplined process for identifying key plant equipment and periodically reviewing the history of the reliability of the equipment.

The process should provide for appropriate follow up actions based on this information, such as increasing surveillance and testing, performing preventive maintenance or providing an engineering fix.

In my view, NRC requirements would provide the optimum regulatory framework if this option were integrated with programatic criteria as described in the Comission's policy statement.

I suggest the elements described in Commissioner Curtiss' option 1 be incorporated into a broader maintenance rule and regulatory guidance which includes the programatic criteria in the Commission's policy statement.

I still question whether adequate data are currently available for licensees to establish good reliability targets, but egree that the process suggested I

by Comissioner Curtiss will enhance each licensec's understanding of maintenance for key plant equipment. Adoption of a regulatory programatic framework for maintenance will ensure that maintenance practices which evolve-from the reliability approach are applied as one standard of maintenance throughout the plant and that licensees-do not focus on the management of reliability data.

If option 1 is pursued as a rule without l

the programmatic framework for maintenance, I would continue to have L

concerns about our enforcement options and our ability to ensure an improved level of maintenance at a facility.

1.

I do not-believe we should pursue option 2.

I still believe option 2 is L

reactive in that it would allow a degraded plant condition to develop before the rule would result in corrective actions.

Implementation would involve what I view as a "get well" program rather than an approach to prevent such degradation at all plants.

I believe it would be difficult to establish objective criteria for an option 2 rule that could be clearly understood by

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e.,.e-i Samuel J. Chilk May 4, 1990 all parties and that would indicate when the rule would apply, and no longer apply, to a licensee.

It is instructive on this score that in the regulation of medical licensees, the Commission has recognized a generic solution is more appropriate in dealing with medical poor performers than responding to individual triggering events.

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Kenneth M. Carr cc: Commissioner Roberts Commissioner Rogers Commissioner Curtiss Commissioner Remick EDO OGC 3

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