ML20055F882

Discusses Commission Recommendations Re Development of Addl Proposed Rule on Plant Maint & Procedural Appproaches to Implementing Maint Rule Along Lines Set Forth in Encls

ML20055F882
Person / Time
Issue date:	05/23/1990
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
FRN-56FR31324 AD-2-10, AD00-2-010, NUDOCS 9007190324
Download: ML20055F882 (5)

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RELEASED TO THE POR s

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May 23, 1990..... e e o o s o e..... gg

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OFFICE OF THE e

SECRETARY

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-MEMORANDUM FOR:

James M. Taylor-Executive Director for Operations ii fl --

FROM:

Samuel J.

Chilk Mretary

SUBJECT:

NUCLEAR POWER PLANT MAINTENANCE L

i The Commission is concerned that at the conclusion of the current 118-month evaluation period provided for in the Commission's Policy Statement on Maintenance, they will be faced with the choice of either promulgating a highly-prescriptive, process-oriented regulation along'the lines of what.the staff has been' directed to develop, which would apply to all utilities, regardless of the quality of.the utility's existing maintenance program or defer to the industry

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'o take the lead on maintenance, Accordingly, the. commission (with commissioners Roberts, 1

Curtiss, and Remick agreeing asks-that, rule that the staff is curren)tly developing,in addition to t?J also develop a second proposed rule, the staff should together with the supporting. analysis and documentation, along the lines of the approach set forth in Enclosure-l.

..n addition, to implementing a maintenance rule,the staff should develop two procedura along the lines set forth in Enclosure 2.

Alternative 1 in Enclosure 2 should be incorporated in each rule that the staff prepares.

Alternative 2 should be developed in such a manner that would permit be applied in conjunction with-each of the two substantiveit to maintenance rules.

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The,two alternative maintenance rules, together with the t

procedural approaches to implementation of these two rules, should be submitted to the Commission no later than June 8, 1

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t 1991~..Then, in the event that the Commission should' decide at the conclusion of the 18-month evaluation period that a rule is necessary or appropriate, these various approaches will be available for the Commission's consideration.

(EDO)

(SECY' Suspense:

6/8/91 priority) 9007190324 900p23 40' NihRE iE PDC 1

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a objective of option 11-- the reliability-based,The a

results-oriented rule -- but.believe it should be elements,of the Commission's revised policy es maintenance.

would modify the secon,d paragraph, glements of R 2

" Reliability-Based, Results-Oriented Rule" follows:

(Enclosure"l), as.

highlight reliability problems,"To encourage improved to and to_ provide a mechanism for accountability, each license should develop meaningful maintenance and/or reliability goals.

These goals-would then serve as a basis for evaluating the effec

- maintenance program.tiveness of a licensee's t

Enclosures:

As stated cc:

Chairman Carr Commissioner Roberts Commissioner Rogers Commissioner Curtiss Commissioner Remick OGC i

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RELIABILITY-BASED, RESULTS-ORIENTED RULE h

Elenents of Rule:_

o Rule would' require that the reliability of key plant equipment -- at the system, component.or functional level as appropriate -- be periodically asse,ssed in a disciplined manner.

The assessment must be capable of highlighting

. problematic equipment and should consider adverse i

performance trends, surveillance or ISI/IST testing,as might be indicated during information.

as well as failure scope of equipment to be covered within theThis process w systems / functions covered by the rule.

methodologies such as the EPRI RCM program would be used Accepted identify " critical" components within systems related equipment, systems / functions covered by the' rule would in The whose failure could cause significant challenges to ey related equipment.'

The staff should provide written justification.wherever it proposes to include non related equipment / systems / functions within the scope of the

-safety rule.

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'To encourage improved maintenance performance reliability' problems, and to provide a mechanism forto highlightE l

accountability, each licensee should develop meaningful reliability goals.

as a basis for evaluThese reliability goals would'then serve maintenance program.ating the effectiveness of a licensee's c

ensuring that the information obtained from theirL or reliability assessments is fed back into their maintenance programs.

Root cause analyses and, t

reassessments of the adequacy of maintenance andwhere necessary, adverse trends and failures. surveillance activities would be requi

'o based maintenance and Technical Specification y-J particularly the key role of surveillance.and Section XI (ISI/IST) the role of TS in controlling al' lowed equipment outates Rule would require licensees to request changes to their TS ges.

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' The staff, rule and associated regulatory guide,in its current effort to develop a mai is already pursuing an accroach to defining the scope of non-safety related equipment that is of concern from a maintenance standpoint

I degrade reliability or where changes-are ne i

improve reliability.

Notes:

a)

The1 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 for 20

.i years.'

.Its success'does not depend upon.the use of.

i reliabilityEnumbers.

.Instead'it relies upon the i

establishment of a strong performance monitoring and feedback process.

b)

This approach would complement, 1

already underway in the IPE and technical specificationand cou improvement programs specification program)(including the risk-based technical 4

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et Enolosure 2 Alternative Conceptual Approaches to Implementation -

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COMPLIANCE WITH REGULATORY GUIDE OR INDU A

o' This approach would be patterned after 10 CFR 55 59(

which allows i c) ensees to meet certain operator requalification requirements either by meeting-

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i specified regulations'or by developing a program using an' alternative approach.

Applied-to maintenance.

that is acceptable to NRCfocus of this approach would be o the r

m-approach to maintenance or, whether it is based on NRC's 4.

NUMARC's proposed maintenance standards.an alternative, such as 2)

APPLICATION OF MAINTENANCE RULE TO POOR PE

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o This approach would include a mechanism to apply

-maintenance requirements to those licensees that the L'

NRC' determines are performing poorly in the area of maintenance.

Performance in the area of maintenance would be o

4 usedato identify problem plants, with a "trigge mechanism" established to identify those poor p

j performers who would be required to comply with the established maintenance: requirements.

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