ML20056C034
| ML20056C034 | |
| Person / Time | |
|---|---|
| Issue date: | 07/24/1991 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| FRN-56FR31324 AD00-2-015, NUDOCS 9108140166 | |
| Download: ML20056C034 (47) | |
Text
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-2 JUL 2 4 1991
/
FD E MEMORANDUM FOR:
James M. Taylor Executive Director for Operations
)
n FROM:
Edward L. Jordan, Chairman Committee to Review Generic Requirements i
SUBJECT:
MINUTES FOR CRGR MEETING 203 i
The Committee to Review Generic Requirements (CRGR) met on Friday, April 5, 1991, from 8:00 a.m. to 2:30 p.m.
A list of attendees at the meeting is enclosed (Enclosure 1). The following items were discussed at the meeting.
1.
C. Thomas and W. Brach of NRR presented for CRGR review a draft revised policy statement and rulemaking alternatives on maintenance.
The CRGR supported the package subject to a number of revisions and circulation of the revised package to CRGR members.
It was not expected (but was possible) that another CRGR meeting would be necessary to complete the CRGR review. This matter is discussed in Enclosure 2.
2.
E. Rossi and E. Murphy of NRR presented for CRGR review a draft bulletin supplement on Westinghouse mechanical steam generator tube plugs. The CRGR supported the supplement, subject to a number of revisions, to be coordinated with the CRGR staff.
This matter is discussed in.
In accordance with the ED0's July 18, 1983, directive concerning " Feedback and
/
l [n]
Closure of CRGR review," a written response is required from the cognizant C/
office to report agreement or disagreement with CRGR recommendations in these minutes.
The response, which is required with five working days after receipt of these minutes, is to be forwarded to the CRGR Chairman and is there is disagreement with CRGR recommendations, to the EDO for decision making.
l Questions concerning these meeting minutes should be referred to Dennis Allison (492-4148).
Original Signed by:
Denwood F. Ross JL Edward L. Jordan, Chairman Committee to Review Generic Requirements
Enclosure:
As stated cc:
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ENCLOSURE 1
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ATTENDANCE LIST CRGR Meeting No. 203 April 5, 1991 CRGR Members NRC Staff E. Jordan J. Johnson G. Arlotto W. Minners F. Miraglia W. Russell B. Sheron W. Brach L. Reyes C. Thomas L. J. Callan C. Ader J. Moore R. Fraley A. Vietti-Cook PNL J. Sharkey E. Doolittle Nicholas T. Saltos B. Richter R. Riggs CRGR Staff G. Grant C. Berlinger J. Conran C. E. Rossi D. Allison E. Murphy R. Freeman B. D. Liaw C. Y. Cheng H. Alderman i
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. to the Minutes of CRGR Meeting No. 203 Proposed Maintenance Policy Statement and Rulemaking Alternatives April 5, 1991 4
i TOPIC 1
C.. Thomas (NRR), W. Brach (NRR) and C. Ader (RES) presented for CRGR review the proposed final policy statement on maintenance, and two alternative proposed rules on maintenance requested by the Commission.
Briefing slides used by the staff to guide their presentation and discussion with the Committee at this meeting are enclosed (Attachments 1 and 2).
i BACKGROUND I
1.
The documents submitted initially to CRGR for review in this matter were transmitted by memorandum dated March 22, 1991, E.S. Beckjord to E.L. Jordan; that initial review package included the following documents:
a.
Draft Commission Paper (undated), " Staff Evaluation and Recom-mendation on Maintenance Rulemaking", and attachments:
- i.
" Staff Evaluation of Criteria for Obviating i
the Need for a Maintenence Rule" S
ii.
" Proposed Final Policy Statement on Maintenance" iii. Enclosure 3
" Proposed Final Amendment to 10 CFR 50.65 -
Process Rule", (including, as attachments, a supporting Environmental Assessment and implementing Regulatory Guide, " Maintenance Programs for Nuclear Power Plants").
I iv.
" Proposed Amendment to 10 CFR 50.65 -
Reliability Rule", (including, as attachments, a supporting Environmental Assessment and draf t implementing Reg. Guide, " Maintenance Programs i
for Nuclear Power Plants")
- v.
" Conceptual Approach for Imposition of a Maintenance Rule on Licensees Exhibiting Maintenance-Related Problems" 2.
A proposed Regulatory Analysis to support both the Process Rule and Reliability Rule alternatives in the package, was transmitted separately 1
to CRGR prior to Meeting No. 203.
l
3.
At Meeting No. 203, the staff provided to CRGR a draft summary of
" Revisions to the Commission Paper on Maintenance Rulemaking to Clarify
(
Items Identified by Senior Management Review", reflecting the consensus recommendations of a senior NRC management review panel for revision of the documents identified in Items 1. and 2. above.
(Attachment 3).
CONCLUSIONS / RECOMMENDATIONS As a result of their review of this matter, including the discussions with the staff at this meeting, the Committee recommended in favor of sending the package forward for final consideration and action by the Commission, subject to consideration / incorporation (as appropriate) of the comments and recom-mendations given below.
In doing so, the Committee indicated agreement with the staff's recommendation to forego rulemaking in the maintenance area and issue instead a revised final Policy Statement on Maintenance.
1.
The Committee supported the recommendations of the senior management review group (Attachment 3). 'In particular the Committee: agreed with'the, group's view that the package in its current' form paints too rosy a picture.
~
regarding-the' current acceptability of maintenance programs and performance.
across the: industry.
The results of NRC maintenance team inspections
~
indicate satisfactory progress to date across the industry in improving maintenance.
But those results also point to weaknesses in some licensees' programs and performance that must still be addressed.
This package should be revised throughout to more clearly convey that, while i
industry progress to date is acceptable, continued attention is needed to achieve full implementation of the improved levels of maintenance sought by the Commission.
2.
The argument thatl there is~ evidence of a continuing industry?"co' mitment" m
to improved. maintenance, simply by virtue e'ithe' utilities' membership in INPO, and the existence of the INPO mainter.ance guidance document.
(90-008), comes across weak as justification for foregoing mainteneance rulemaking and issuing instead a revised l Policy. Statement.
The staff i
should consider augmenting the discussion in the package regarding the obligations imposed by INP0 membership, and regarding regulatory mechanisms (other than enforcement) as well as other industry initiatives, that will operate to help assure sustained good maintenance performance at operating reactors, after the one-time, four year industry self-assessment effort described in the package is completed.
As a specific point in this regard, the staff should reflect in the Commission Paper the staff's plans to provide reports to the Commission (interim report in 2 years; final report in 4 years) on the attainment of the goals of the Policy Statement, including industry actions and initiatives, and the results of NRC's j
related activities.
3.
A weakness in the package in its current form is that, although the staff's recommended alternative is the Policy Statement, that option is not reflected explicitly in the Regulatory Analysis included with the package.
In presenting this package for Commission consideration, the staff should address more clearly (a) the estimated additional cost burden to NRC, if any, that will result from implementing the Policy Statement approach (e.g., the cost of any anticipated additional
i inspection activity that may be required); and (b) the potential I
consequences of proceeding without either a rulemaking or a revised Policy Statement (i.e, no regulatory action).
t 4.
The licensees should be encouraged to to use plant specific PRA/IPE results for their facilities in shaping and guiding their maintenance programs / efforts, in identifying equipment maintenance priorities, and in evaluating maintenance performance.
However, particularly in the Process Rule context, care should be taken not to portray the risk-based approach as the only method acceptable to the staff.
The wording of Regulatory Position C.3 in the implementing Reg. Guide for the
(
Process Rule should be reexamined in this regard.
5.
The discussions of alternatives throughout the Commission Paper should be reviewed, and revised as appropriate, to make clearer which alternatives are being compared (i.e., process rule vs reliability rule, or policy statement vs rule).
In discussing Process Rule disadvantages, the concern that such a rule could delay ongoing industry reliability centered maintenance efforts should be given emphasis.
6.
The discussion of the Reliability Rule alternative should be expanded to more realistically and completely characterize the practical difficulties of attemoting to implement that approach at this time.
Examples of types of auest,ons that should be considered if the Commission should prefer t m, alternative are.
4 Is this approach tantamount to imposing a requirement on licnesees a.
/},' ' // for a living PRA/IPE?
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N b.
Is the state-of-the-art in reliability assurance for nuclear power l
e plant equipment ready for implementation of such a proposal in a i
reasonable time-frame (e.g., completeness / acceptability of needed equipment data bases)? Should the availablility of data from j
equipment aging studies be considered a prerequisite to initiating i
such a rule?
d.
What is the proper balance in emphasis with regard to equipment reliability vs equipment availability and how will this be reflected reflected in such a rule?
e.
How much time is needed for development of guidance for establish-ing realistic reliability goal numbers, and regulatory acceptance criteria for reviewing licensees' programs for implementation of such a rule and judging compliance with it?
i The general? Committee: view was-that the7 propose'd relfability' rule.is not-sufficientlydevelopedat?thistime.. The staff should identify it as a draft proposed rule when sending it forward to the Commission.
Altern-atively, it was suggested that the staff consider recasting it as an Advanced Notice of Proposed Rulemaking rather than as a proposed rule.
The Committee's view was that the proposed 3 year implementation schedule is unrealistic and should not be sent forward.
In view of the limitations s
' i l
i of the treatment of this alternative in the current package, the support-ing Regulatory Analysis may have to be revised, and a Backfit Analysis I
will also have to prepared, if the Commission chooses to publish this altamative for comment at this time.
7.
In response to a Committee question, the staff clarified that the performance objectives of the INPO maintenance document (INPO 90-008) referred to in the proposed Policy Statement are analogous to regulatory requirements which establish the level of program adequacy, while the sub-ordinate criteria set forth in that document represent excellence-type i
goals.
The Committee recommended that this point be made clear in the Commission Paper discussion of the industry commitment to conduct compre-hensive assessments against the INP0 guidance.
(The assessments will be conducted by reference to the INP0 performance objectives, but not neces-sarily all of the associated subordinate criteria.)
8.
The staff should revise the discussion of enforcement options in the Commission Paper to identify more specifically available regulatory mechanisms for addressing (in the absence of a rule) poor maintenance of balance-of plant equipment that is not covered by plant technical specifications.
9.
In the " Conclusions" section of the Commission Paper, it should be i
reiterated explicitly that Commission-approved criteria were used in making the dermination that a maintenance rule is not necessary at this time.
10.
The staff's plans to withdraw the Process Rule implementing Reg. Guide, if the rulemaking option is not chosen by the Commission, should be reflected in the Commission Paper.
t 11.
With regard to safety goals considerations, all three alternative actions put forward in this package were for the purpose of sustaining effective maintenance in the operating reactors.
The staff's estimate of the potential consequences of backsliding to 1985 levels of performance, in the absence of regulatory action is a 7xE(-5) increase in core damage frequency.
The Committee recognized the uncertainities inhercnt in this estimate of consequences, but agreed with the staff's judgement that regulatory action is needed.
Because issuance of a Policy Statement does not constitute backfitting; the Committee concluded that the staffs treatment of safety goals considerations for this package is acceptable.
12.
Additional specific wording changes to the package recommended by CRGR were as follows:
a.
Commission Paper (p.17, 2nd paragraph) l In the second sentence of the paragraph, insert the word " potential" in front of " advantage".
i b.
Proposed Final Policy. Statement (p.3, 2nd paragraph)
In the second sentence of the paragraph, insert the word " equipment" in front of " reliability values", and insert the word " design" in front of " assumptions".
c.
Proposed Final Policy Statement (p.3, 2nd paragraph)
Revise the third sentence of the paragraph to read as follows:
"Each licensee should monitor'the performance of these systems that are determined to be..."
d.
Process Rule (p.34, paragraph (c)(1))
Check with OGC and, if appropriate, in the last sentence of the paragraph, change the term " Commission approved" to "NRC approved".
e.
Reg. Guide (Process Rule)
(p.3, paragraph 2.0)
Move the firrt sentence of the paragraph intact into the
" Discussion" section of the Reg. Guide.
- f. (" Conceptual Approach..") (p.1 at the bottom of page)
Add " Diagnostic Evaluations" to the list of measures of licensee 4
performance considered by the staff.
g.
Regulatory Analysis (pp.29-30)
Revise the discussion of the Maintenance Effectiveness Indicator.to reflect staff concern regarding lack of plant-to plant comparability in use of the absolute value of the indicator.
All changes to the package are to be coordinated with the CRGR staff before sending the package forward for final consideration and action by the Commission.
It was not expected that another formal meeting would be requ' red to complete the CRGR review of this matter.
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STAFF EVALUATION AND RECOMMENDATION ON MAINTENANCE RULEMAKING AGENDA INTRODUCTION / BACKGROUND (NRR)
CRITERIA TO OBVIATE THE NEEC FOR MAINTENANCE RULEMAKING AND STAFF ANALYSIS (NRR)
(
AVAIL ABLE ALTERN ATIVES POLICY STATEMENT (NRR)
PROCESS-ORIENTED RULE (RES)
REGULATORY GUIDE
- REGULATORY ANALYSIS RELI ABILITY-BASED RULE (RES)
CON CL USION S/ R ECOM M E N DATION S ma
+
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4 MAINTENANCE RULEMAKING BACKGROUND O
+ MARCH 1988 - NRC PUBLISHED POLICY STATEMENT ON MAINTENANCE
- APRIL 1989 - STAFF PROPOSED FINAL PROCESS-ORIENTED MAINTENANCE RULE (SECY-90-143)
- JUNE 1989 - COMMISSION DECIDED TO DEFER RULEMAKING FOR 18 MONTHS AND ISSUE REVISED POLICY STATEMENT
- AUGUST 1989 - STAFF ISSUED DRAFT REGULATORY GUIDE FOR PROCESS-ORIENTEJ MAINTENANCE RULE
- SEPTEMBER 1989 -
COMMISSION REQUESTED THE STAFF TO DEVELOP CRITERIA TO BE USED IN EVALUATING THE NEED FOR MAINTENANCE RULEMAKING
- DECEMBER 1989 - COMMISSION APPROVED REVISED POLICY STATEMENT ON MAINTENANCE
- JULY 1988-APRIL 1991 - STAFF CONDUCTED MAINTENANCE TEAM INSPECTIONS AND REINSPECTIONS AT SELECTED SITES
- MAY 1990 - COMMISSION APPROVED CRITERIA FOR EVALUATING THE NEED FOR MAINTENANCE RULEMAKING (SECY-90-137) AND IDENTIFIED ADDITIONAL FACTORS FOR CONSIDERATION
- MAY 1990 - COMMISSION DIRECTED THE STAFF TO DEVELOP A SECOND PROPOSED RULE THAT WOULD BE RELIABILITY-BASED O
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i CRITERIA FOR OBVIATING THE NEED FOR A MAINTENANCE RULE O
CRITERION 1 -
EFFECTIVE IMPLEMENTATION OF AN ADEQUATE MAINTENANCE PROGRAM CRITERION 2 -
FAVORABLE PERFORMANCE TREND CRITERION 3 - COMMITMENT TO AN ACCEPTABLE M AINTEN ANCE~ DOCUMENT CRITERION 4 - COMMITMENT TO A SELF-EVALUATION PROGRAM ADDITION AL FACTORS O
1.
ABILITY TO ENFORCE MAINTENANCE PROGRAMS OR STANDARDS 2.
STRENGTHENED COMMITMENT TO MONITOR EQUIPMENT PERFORMANCE AND FEEDBACK INFORMATION INTO THE MAINTENANCE PROGRAM 3.
PROVISION OF AN NRC MECHANISM FOR VERIFYING PROGRAM EFFECTIVENESS O
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CRITERION 1 LICENSEES HAVE EFFECTIVELY IMPLEMENTED AN ADEQUATE MAINTENANCE PROGRAM OR ARE COMMITTED TO AND PROCEEDING TOWARD THAT GOAL MTl RESULTS INDICATE THAT LICENSEES HAVE ADEQUATE MAINTENANCE PROGRAMS MTl RESULTS INDICATE THAT LICENSEES EXHIBIT AN IMPROVING TREND IN IMPLEMENTING MAINTENANCE PROGRAMS REINSPECTION RESULTS INDICATE THAT INDUSTRY IS MOV!NG TO IMPROVE THOSE AREAS THAT WERE O
'oENT'F'Eo ^8 we^xNESSES DuRiNG THE INITIAL MAINTENANCE TEAM INSPECTIONS STAFF CONCLUSION I
CRITERION 1 HAS BEEN SATISFIED O
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Yeaf Quarter / Year l
2
CRITERION 3 LICENSEES ARE COMMITTED TO THE IMPLEMENTATION OF A MAINTENANCE PERFORMANCE STANDARD ACCEPTABLE TO THE NRC STAFF REVIEW OF THE INDUSTRY MAINTENANCE PROGRAM DOCUMENT (INPO 90-008) FINDS IT TO BE GENERALLY ACCEPTABLE NRC OBSERVATION OF INPO EVALUATIONS HAS NOTED A LACK OF WIDESPREAD ADOPTION OF THE INDUSTRY MAINTENANCE PROGRAM DOCUMENT INDUSTRY'S COMMITMENT TO IMPLEMENT THE O
INDUSTRY MAINTENANCE PROGRAM DOCUMENT IS SATISFIED THROUGH BOTH AN INDIVIDUAL UTILITY'S MEMBER STATUS IN INPO AND THE NUMARC INITIATIVE FOR COMPREHENSIVE SELF-ASSESSMENTS USING PERFORMANCE OBJECTIVES OF INPO 90-008 STAFF CONCLUSION CRITERION 3 HAS BEEN SATISFIED l
CRITERION 4 LICENSEES HAVE IN PLACE OR ARE COMMITTED TO AN EVALUATION PROGRAM FOR ENSURING SUSTAINED PERFORMANCE IN THE MAINTENANCE AREA NRC OBSERVATION OF INPO EVALUATIONS FOUND THAT THE OVERALL EVALUATION PROCESS IS THOROUGH AND COMPREHENSIVE NRC OBSERVATION OF INPO EVALUATIONS ALSO a
FOUND THAT THE EMPHASIS INPO PLACES ON MAINTENANCE HAS RECENTLY INCREASED ALL LICENSEES ARE COMMITTED TO THE EVALUATION PROCESS BY VIRTUE OF THEIR MEMBERSHIP IN INPO AS PART OF A NUMARC INITIATIVE, ALL LICENSEES
+
WILL EVALUATE THEIR MAINTENANCE PROGRAMS USING INPO 90-008 OVER A 4-YEAR PERIOD, BEGINNING JANUARY 1,1992 STAFF FOUND THAT INDUSTRY HAS A COMPREHENSIVE PLAN FOR IMPROVEMENT OF MAINTENANCE PROGRAMS, AS DESCRIBED IN NUMARC'S INDUSTRY ACTION PLAN STAFF CONCLUSION CRITERION 4 HAS BEEN SATISFIED O
~
m
ADDITIONAL FACTORS
(
1.
ABILITY TO ENFORCE MAINTENANCE PROGRAMS ADEQUATE ENFORCEMENT OPTIONS EXIST TODAY FOR SAFETY-RELATED EQUIPMENT ENFORCEMENT OPTIONS FOR BALANCE-OF-PLANT EQUIPMENT THAT HAVE A DIRECT SAFETY RELEVANCE ARE ALSO ADEQUATE 2.
INDUSTRY COMMITMENT TO MONITORING AND FEEDBACK OF INFORMATION OF MAINTENANCE-RELATED MATTERS IMPROVEMENTS NOTED IN THE QUALITY OF MAINTENANCE AND INCREASED INDUSTRY EMPHASIS ON MAINTENANCE INDUSTRY MAINTENANCE DOCUMENT ADEQUATELY ADDRESSES THESE AREAS INDUSTRY COMMITMENT TO THE INDUSTRY t
MAINTENANCE DOCUMENT SEEN AS A MAJOR FACTOR IN DETERMINING INDUSTRY'S COMMITMENT TO MONITORING AND FEEDBACK OF INFORMATION OF MAINTENANCE-RELATED MATTERS 3.
NRC VERIFICATION OF MAINTENANCE PROGRAM EFFECTIVENESS PROPOSED REVISIONS TO THE NRC INSPECTION PROCEDURE FOR MONTHLY MAINTENANCE INSPECTION i
PROPOSED DEVELOPMENT OF A NEW INSPECTION e
PROCEDURE THAT INCORPORATES MTl GUIDANCE FOR USE AS A SPECIAL INSPECTION ON A CASE-BY-CASE BASIS
CONCLUSION THE FOUR CRITERIA FOR OBVIATING THE NEED FOR A MAINTENANCE RULE HAVE BEEN SATISFIED THE ADDITIONAL FACTORS FOR COMMISSION CONSIDERATION IN DETERMINING THE NEED FOR A MAINTENANCE RULE HAVE BEEN ADEQUATELY ADDRESSED OBSERVATIONS OF NUCLEAR POWER PLANT MAINTENANCE HAVE IDENTIFIED SATISFACTORY MAINTENANCE PROGRAMS AND IMPLEMENTATION OF THE MAINTENANCE PROGRAMS ALTERNATIVES AVAILABLE TO THE COMMISSION 1.
ISSUE A FINAL POLICY STATEMENT ON MAINTENANCE 2.
ISSUE A FINAL PROCESS-ORIENTED MAINTENANCE RULE 3.
ISSUE A PROPOSED RELIABILITY-BASED MAINTENANCE RULE FOR COMMENT 1
0
PROPOSED POLICY STATEMENT O
RESTATES THE COMMISSION POSITION ON THE IMPORTANCE OF MAINTENANCE RECOGNIZES INDUSTRY IMPROVEMENTS AND INITIATIVES RECOGNIZES INPO 90-008 AS AN INDUSTRY MAINTENANCE PROGRAM DOCUMENT OUTLINES MAINTENANCE PROGRAM ACTIVITIES q
AND SUPPORTING FUNCTIONS N.)
IDENTIFIES FUTURE NRC ACTIONS THAT WILL CONTINUE TO EMPHASIZE THE IMPORTANCE OF MAINTENANCE i
1 O
)
MAINTENANCE PROGRAM ACTIVITIES AND SUPPORTING FUNCTIONS O
MAINTENANCE MANAGEMENT AND TECHNOLOGY
+
PLANNING AND SCHEDULING STAFFING SHIFT COVERAGE RESOURCE ALLOCATION CONTROL OF CONTRACTED MAINTENANCE SERVICES AVAILABILITY OF PARTS, TOOLS, AND FACILITIES -
MEASURES OF MAINTENANCE PROGRAM EFFECTIVENESS COMMUNICATIONS ENGINEERING RADIATION EXPOSURE CONTROL MAINTENANCE PERSONNEL QUALIFICATION AND TRAINING QUALITY ASSURANCE DOCUMENTATION TESTING AND RETURN TO SERVICE 4
O
FUTURE NRC ACTIONS TO CONTINUE
~
EMPHASIS ON MAINTENANCE O
CONTINUATION OF MAINTENANCE TEAM INSPECTIONS ON A CASE-BY-CASE BASIS REVISE 2515 PROGRAM TO INCLUDE THE MAINTENANCE TEAM INSPECTION GUIDANCE ENCOURAGE LICENSEES TO UTILIZE PRA INSIGHTS IN THE MAINTENANCE PROCESS ENCOURAGE INDUSTRY TO DEVELOP RELIABILITY ASSURANCE PROGRAMS THAT ENSURE THAT RISKS ARE MAINTAINED AT ACCEPTABLY LOW LEVELS PROVIDE A STAFF REPORT TO THE COMMISSION ON THE PROGRESS INDUSTRY HAS MADE IN RESPONDING TO THE FINAL POLICY STATEMENT AND ON THE STATUS OF MAINTENANCE 4 YEARS AFTER THE POLICY STATEMENT IS ISSUED, WITH A 2-YEAR INTERIM REPORT
~
SUMMARY
OF STAFF ANALYSIS, CONCLUSION, AND RECOMMENDATION ANALYSIS INDUSTRY HAS MADE CONSIDERABLE IMPROVEMENTS IN THE QUALITY OF MAINTENANCE INDUSTRY HAS INCREASED EMPHASIS ON MAINTENANCE AND HAS RENEWED ITS COMMITMENT TO ENSURING SUSTAINED PERFORMANCE IN THE MAINTENANCE AREA SENIOR NRC MANAGERS CONCLUDE THAT INDUSTRY ACTION IN RESPONSE TO INCREASED NRC AND INDUSTRY EMPHASIS ON MAINTENANCE HAS RESULTED IN OVERALL IMPROVEMENT IN NUCLEAR POWER PLANT MAINTENANCE ACTIVITIES SECY-90-137 CRITERIA HAVE BEEN SATISFIED AND ADDITIONAL FACTORS HAVE BEEN ADEQUATELY ADDRESSED O
SUMMARY
OF STAFF ANALYSIS, CONCLUSION, AND RECOMMENDATION O
(CONTiNusD) 1 CONCLUSION THE STAFF CONCLUDES THAT THERE IS NO CURRENT NEED FOR MAINTENANCE RULEMAKING t
THE STAFF BELIEVES THAT CURRENT AND PLANNED INDUSTRY AND NRC MAINTENANCE-RELATED ACTIVITIES ARE SUFFICIENT TO CONTINUE THE EMPHASIS ON MAINTENANCE AND MAINTAIN OR IMPROVE CURRENT LEVELS OF INDUSTRY PERFORMANCE l
CONTINUE DEVELOPMENT OF RELIABILITY ASSURANCE PROGRAM RECOMM ENDATION ISSUE THE FINAL POLICY STATEMENT ON MAINTENANCE DELETE THE MAINTENANCE ESCALATION FACTOR AND REVISE THE ENFORCEMENT POLICY
c m erri u s
's/fl, P G %j e
CRGP BRIEFING APRIL 5,1991 MAINTENANCE RULEMAKING ALTERNATIVES P
O i
O aa,
1 2
fo Enc lo s u o-e 2 2
1 MAINTENANCE RULEMAKING HISTORY
/'
V) o PROPOSED PROCESS-ORIENTED RULE (10 CFR 50.65)
WAS PUBLISHED FOR PUBLIC COMMENT IN NOVEMBER 1988.
o FINAL PROCESS-ORIENT RULE AND DRAFT REGULATORY GUIDE WERE PROVIDED TO THE COMMISSION IN APRIL 1989 (SECY-89-143) o IN JUNE 1989 COMMISSION DECIDED TO DEFER RULEMAKING FOR 18 MONTHS AND DIRECTED STAFF TO ISSUE DRAFT REGULATORY GUIDE.
o DRAFT REGULATORY GUIDE WAS PUBLISHED FOR PUBLIC COMMENT IN AUGUST 1989.
O' o
IN MAY 1990 COMMISSION DIRECTED STAFF TO DEVELOP A SECOND, PROPOSED RULE THAT WOULD BE RELIABILITY BASED.
1
MAINTENANCE RULEMAKING ALTERNATIVES o
TWO ALTERNATIVE RULEMAKING PACKAGES HAVE BEEN DEVELOPED PER COMMISSION DIRECTION A FINAL PROCESS ORIENTED RULE (10 CFR 50.65)
AND FINAL REGULATORY GUIDE.
A PROPOSED RELIABILITY-BASED, RESULTS 1
ORIENTED RULE AND DRAFT REGULATORY GUIDE.
o AS DIRECTED BY THE COMMISSION, BOTH RULES EXPLICITLY ALLOW LICENSEES TO DEVELOP MAINTENANCE PROGRAMS BASED ON NRC APPROVED ALTERNATIVE INSTEAD OF REQUIREMENTS OF THE RULE.
t o
BOTH RULES HAVE AS THEIR OBJECTIVE TO PROVIDE
\\
REGULATORY REQUIREMENTS AND GUIDANCE DIRECTED TOWARD ENSURING THAT EFFECTIVE MAINTENANCE PROGRAMS ARE MAINTAINED OVER THE LIFE OF THE PLANT.
1 o
3
]
SCOPE OF MAINTENANCE RULES THE SYSTEMS, STRUCTURES, AND COMPONENTS (SSC) o COVERED BY EITHER RULE ARE THE SAME.
o THE RULES WILL ENCOMPASS BOTH SAFETY-RELATED AND NON SAFETY-RELATED SSCS.
NON SAFETY-RELATED SSCS WILL INCLUDE THOSE THAT ARE RELIED UPON TO MITIGATE ACCIDENTS OR TRANSIENTS OR ARE USED IN PLANT EOPS, WHOSE FAILURE COULD PREVENT SAFETY-RELATED SSC FROM FUNCTIONING, AND WHOSE FAILURE CAUSES A SCRAM OR ACTUATION OF A SAFETY-RELATED SYSTEM.
o THE ACTUAL SSCS COVERED BY A MAINTENANCE PROGRAM WILL BE DETERMINED BY THE LICENSEE
\\
AND WILL BE PLANT-SPECIFIC.
4-
y PROCESS ORIENTED RULE O
THE RULE:
o DEFINES MAINTENANCE AS THE AGGREGATE OF THOSE ACTIONS REQUIRED TO MINIMIZE THE DEGRADATION OR FAILURE OF, AND RESTORE THE INTENDED FUNCTION OF STRUCTURES, SYSTEMS, AND COMPONENTS.
o IDENTIFIES BASIC PROGRAMMATIC ACTIVITIES THAT SHALL BE INCLUDED IN A MAINTENANCE PROGRAM.
REQUIRES AN ASSESSMENT, AT LEAST ANNUALLY,.
o OF MAINTENANCE EFFECTIVENESS.
o REQUIRES CORRECTIVE ACTIONS TO ADDRESS PROBLEMS' IDENTIFIED DURING ASSESSMENT.
o REQUIRES IMPLEMENTATION WITHIN 2 YEARS.
5-
PROCESS ORIENTED RULE (CONTINUED)
MAINTENANCE PROGRAM ACTIVITIES o
MAINTENANCE MANAGEMENT AND TECHNOLOGY CORRECTIVE MAINTENANCE AND PREVENTIVE MAINTENANCE.
PLANNING.
SCHEDULING.
STAFFING.
SHIFT COVERAGE.
RESOURCE ALLOCATION.
CONTROL OF CONTRACTED MAINTENANCE SERVICES.
AVAILABILITY OF PARTS, TOOLS, AND FACILITIES.
MEASURES OF MAINTENANCE PROGRAM EFFECTIVENESS.
INTERNAL COMMUNICATIONS.
EXTERNAL COMMUNICATIONS.
o ENGINEERING SUPPORT TO MAINTENANCE.
o RADIATION EXPOSURE CONTROL.
MAINTENANCE PERSONNEL QUALIFICATION AND o
TRAINING.
QUALITY ASSURANCE AND QUALITY CONTROL.
o DOCUMENTATION, INCLUDING EQUIPMENT HISTORY '
o AND TRENDING, MAINTENANCE RECORD-KEEPING, AND MAINTENANCE PROCEDURES.
o TESTING AND RETURN TO SERVICE.
6
PROCESS ORIENTED RULE (CONTINUED)
REGULATORY GUIDE PROVIDES FURTHER DETAILS OF o
THE ACTIVITIES TO BE INCLUDED IN A MAINTENANCE PROGRAM.
REGULATORY GUIDE PROVIDES GUIDANCE ON THE o
USE OF GOALS AND OBJECTIVES AS AN AID IN ASSESSING THE EFFECTIVENESS OF MAINTENANCE PROGRAMS.
PROVIDES EXAMPLES OF INDICATORS CURRENTLY BEING USED FOR WHICH GOALS SETTING SHOULD BE CONSIDERED PRA/IPE SHOULD BE USED IN SETTING GOALS AND FOR DETERMINING RISK SIGNIFICANCE OF SSCS O
7
RELIABILITY-BASED RULE C
\\
THE RULE:
o FOCUSES ON RESULTS OF MAINTENANCE - NOT ON PROGIMMMATIC ACTIVITIES.
REQUIRES LICENSEES TO ESTABLISH PLANT, o
STRUCTURE, AND SYSTEM PERFORMANCE GOALS COMMENSURATE WITH SAFETY IMPORTANCE.
o REQUIRES PROGRAMS TO PERIODICALLY MONITOR AND TREND PLANT, STRUCTURE AND SYSTEM PERFORMANCE.
REQUIRES A COMPARISON, AT LEAST ANNUALLY, OF o
THE RESULTS OF THE PERFORMANCE MONITORING WITH THE GOALS TO DETERMINE THE NEED FOR CORRECTIVE ACTION.
o REQUIRES CORRECTIVE ACTIONS TO ADDRESS PERFORMANCE PROBLEMS.
o REQUIRES IMPLEMENTATION WITHIN 3 YEARS.
RELIABILITY-BASED RULE (CONTINUED)
DETAILS OF APPROACH TO ESTABLISHING PERFORMANCE GOALS DISCUSSED IN REGULATORY GUIDE.
GOALS TO BE SET BY EACH LICENSEE, NOT NRC.
o GOALS TO BE ESTABLISHED AT THE SYSTEM LEVEL o
(SYSTEM PERFORMANCE OR UNAVAILABILITY) FOR SYSTEMS RELIED UPON TO MITIGATE ACCIDENTS OR TRANSIENTS AND AT THE PLANT LEVEL (E.G, SCRAM RATE, ESF ACTUATION RATE) FOR SSCS WHOSE FAILURE CAUSES A SCRAM OR SAFETY SYSTEM ACTUATION.
INFORMATION FROM PLANT-SPECIFIC PRA/IPE o
SHOULD BE USED TO ESTABLISH GOALS.
o GOALS TO BE USED AS AN AID TO ASSESSING MAINTENANCE PERFORMANCE, NOT AS A TRIGGER FOR REPORTING TO NRC.
RELIABILITY-BASED RULE (CONTINUED)
DETAILS OF APPROACH TO MONITORING AND ASSESSING PERFORMANCE DISCUSSED IN REGULATORY' GUIDE.
o EACH LICENSEE TO ESTABLISH METHODS FOR MONITORING PLANT AND SYSTEM LEVEL PERFORMANCE.
INPO HAS DEVELOPED METHOD FOR MONITORING SELECT SAFETY SYSTEM UNAVAILABILITY RES IS DEVELOPING SIMILAR METHOD IN SUPPORT OF RISK-BASED PERFORMANCE INDICATORS.
APPLICATION IS FOR SELECT SYSTEMS
(}
o WHERE UNAVAILABILITY MONITORING IS NOT V
EFFECTIVE IN TIMELY DETECTION OF CHANGES IN SYSTEM PERFORMANCE OR WHERE ANY FAILURE IS CONSIDERED UNACCEPTABLE EACH LICENSEE SHOULD EXAMINE ITS PREVENTIVE MAINTENANCE ACTIVITIES TO DETERMINE IF THEY PROVIDE THE NECESSARY ASSURANCE THAT PERFORMANCE CAN BE MET.
O EACH LICENSEE TO ENSURE THE INTEGRITY OF THE MONITORING PROCESS.
O
4 REGULATORY ANALYSIS BASES:
o JUSTIFICATION FOR MAINTENANCE RULE IS BASED ON THE QUALITATIVE ARGUMENTS OF IMPORTANCE OF MAIN'ENANCE OVER THE ENTIRE LIFE OF THE PLANT.
o REGULATORY ANALYSIS BASED ON MAINTAINING CURRENT LEVEL OF SAFETY (PREVENT " BACKSLIDING") AND IMPROVING PERFORMANCE OF THE MARGINALLY SATISFACTORY PERFORMERS o
SUBSTANTIAL INCREASE IN PUBLIC HEALTH AND SAFETY BEYOND THAT PROVIDED BY CURRENT REGULATIONS.
Oo THE QUANTIFICATION OF MAINTENANCE BENEFITS AND COSTS ESTABLISH THE COST EFFECTIVENESS OF MAINTENANCE.
HOW EITHER RULE AFFECTS THE QUALITY OF MAINTENANCE IS A JUDGMENT.
11 O,
REGULATORY ANALYSIS (CONTINUED)
ASSUMPTIONS:
o WITH NO RULE ALL PLANTS WILL BACKSLIDE WITHIN SIX YEARS TO A LEVEL BEFORE INDUSTRY INITIATIVES (1985 LEVEL OF PERFORMANCE)
POINT ESTIMATE:
ALL PLANTS BACKSLIDE TO 1985 LEVEL LOWER BOUND:
50% OF MARGINALLY SATISFACTORY PLANTS BACKSLIDE UPPERBOUND:
PREVENT BACKSLIDE PLUS REDUCE PREVENTABLE FAILURES FOR SATISFACTORY AND MARGINALLY SATISFACTORY TO CURRENT LEVEL OF GOOD PERFORMERS.
o 80% OF COMPONENT FAILURES ARE PREVENTABLE.
50% AVERAGE MAINTENANCE EFFICIENCY (50%
o REDUCTION IN PREVENTABLE FAILURES AT COMPONENT LEVEL SINCE 1985).
12 L
REGULATORY ANALYSIS VALUE/ IMPACT o
ESTIMATED CHANGE IN CDF IS ON THE ORDER OF 7X105 PER REACTOR YEAR o
ESTIMATED VALUE FROM EITHER RULE,52,000 PERSON-REM PROCESS RULE HAS ESTIMATED NET SAVINGS ($262M) o o
RELIABIL.ITY RULE HAS ESTIMATED NET COST $82M 13
SAFETY GOALS Gb o
PROPER MAINTENANCE IS ESSENTIAL TO PLANT SAFETY o
REGULATORY ANALYSIS FOCUSED ON CHANGE TO CORE DAMAGE FREQUENCY o
SAFETY GOAL SUBSIDARY OBJECTIVE FO'1 CORE DAMAGE FREQUENCY IS 10"/ REACTOR YEAR o
PRIOR TO 1985, CORE DAMAGE FREQUENCY FROM INTERNAL EVENTS WAS ASSUMED ON THE ORDER OF 10" PER REACTOR YEAR FOR THE AVERAGE PLANT.
(BASED ON COMPILATION OF EXISTING PRAS) o INDUSTRY M'AINTENANCE HAS IMPROVED SINCE 1985.
f THEREFORE, AVERAGE CORE DAMAGE FREQUENCY
\\
HAS IMPROVED o
THE DEGREE TO WHICH RULE IS NEEDED TO MEET SAFETY GOALS IS DEPENDENT ON JUDGEMENT OF DEGREE TO WHICH BACKSLIDING IS ASSUMED WITHOUT RULE 14
r 0
PROCESS ORIENTED RULE U
ADVANTAGES CONSISTANT WITH MTI GUIDELINES AND INPO GUIDANCE WOULD NOT REQUIRE SIGNIFICANT CHANGES TO GOOD PROGRAMS AREAS NEEDING IMPROVEMENT HAVE BEEN IDENTIFIED BY MTI PROCESS DISADVANTAGES DOES NOT ENSURE LICENSEES PROGRAMS ARE PROPERLY FOCUSED ON RISK SIGNIFICANT EQUIPMENT POTENTIAL TO FOCUS LICENSEE RESOURCES AWAY FROM INDUSTRY INITIATIVES TOWARD IMPLEMENTATION OF THE RULE
r RELIABILITY-BASED RULE ADVANTAGES FOCUS LICENSEES MAINTENANCE A"TIVITIES ON RISK SIGNIFICANT EQUIPMENT CONSISTENT WITH CURRENT RELIABILITY PROGRAMS AND INITIATIVES SUCH AS THE EPRI RCM PROGRAM DISADVANTAGES FURTHER GUIDANCE MUST BE DEVELOPED FOR USING PERFORMANCE MONITORING NOT PRACTICAL TO USE SYSTEM OR EQUIPMENT r
FAILURE DATA TO MONITOR PERFORMANCE OF
\\
HIGH RELIABILITY, LOW POPULATION EQUIPMENT NOT A PROACTIVE APPROACH TO MAINTENANCE, MAY NOT ENSURE THAT ALL NECESSARY MAINTENANCE RELATED ACTIVITIES ARE PERFORMED 16 4
I I
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REVISIONS TO THE COMMISSION PAPER ON MAINTENANCE RULEMAKING TO CLARIFY ITEMS IDENTIFIED BY SENIOR MANAGEMENT REVIEW f,
1 N
/
1.
Differentiate between licensees having adequate maintenance programs and the implementation of those programs.
The revision notes an improving trend in the implementation and performance of maintenance programs.
(Conforming changes throughout paper) 2.
Delete the recommendation to retain the enforcement escalation factor for maintenance.
Add staff plans for a revision to the Enforcement Policy to include examples in the maintenance area.
3.
Add staff plans to report to the Commission on the attainment of the goals of the Policy Statement including industry actions and initiatives, and the results of associated NRC activities.
Includes an interim report at two years and a final report at four years.
4.
Change reference to INPO 90-008 from " industry maintenance standard" to
" industry maintenance program document."
(Conforming changes throughout paper)
[.
5.
Expand discussion on balance-of-plant enforcement options and delete reference to an unpublished SECY paper on balance-of-
\\
plant performance.
6.
Expand elements of a maintenance program identified in the Policy Statement to include areas of deficiency noted during Maintenance Team Inspections.
(Conforming changes throughout paper) 7.
Expand discussions of rule alternatives to include the basis of the backfit analysis and associated assumptions.
- Also, included are additional disadvantages of each rule alternative.
8.
Delete intermediate (six month) step in implementation of the process-oriented rule.
9.
Clarify discussion of industry initiative for self-assessment using INPO 90-008 to note that assessment will use performance objectives as basis and not necessarily the associated subordinate criteria.
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QQ NUCLE AR MANAGEMENT AND RESOURCES COUNCIL y
or i. r #
. u. 3:a. m.ge x n:n m 2_ :. w n :,
f, (h.
August 16, 1991 I
mw.t ux l
The Honorable Ivan Selin Chairman U. S. Nuclear Regulatory Comission Washington, D. C. 20555 I
Dear Chairman Selin:
The purpose of this letter is to inform you of the industry's reaction l
and response to the NRC's recent adoption of a final maintenance rule.
Since the early 1980's, the industry has focused significant effort on improving l
maintenance programs and practices.
The progress the industry has made in improving maintenance has been the subject of continuing discussion between the NRC and the industry over the last several years.
There has been agreement between the industry and the NRC that maintenance programs have improved dramatically and that no fundamental generic safety issues exist with respect to maintenance.
Thus, we were surprised when the Cor: mission issued a final maintenance rule.
We were also disappointed that there was no opportunity for industry and public consideration and coment regarding the nature, scope, interpretation and ramifications of that rule, which embodied a completely new concept of performance-based regulation.
We have previously communicated to the Commission in a letter to Comissioner Curtiss dated May 21, 1991, that we think there is merit in developing a performance-based regulatory concept.
In fact, in discussions and correspondence on the NRC's Regulatory Impact Survey, we encouraged the l
NRC to pursue just that kind of innovative regulation, regulation that is built around defined performance goals and provides licensees with the flexibility to determine the appropriate manner in which to reach those goals.
l Where additional regulation is necessary, this appears to be a logical way to move away from the prescriptive, paper-oriented type of regulation which has developed in this country over the past two decades. This would also be consistent with the Kemeny Commission report on the accident at Three Mile Island that concluded regulations by themselves cannat assure safety and that voluminous and complex regulations can scrn as a negative factor in nuclear safety. The industry, thrnugh NUtiARC,thas.been working with the NRC to develop the performance-based regulation concept-through a pilot,pFogr 1
l
^ Hany of! thel principles embodied in the final maintenance rule are supp.am.
orted by t the industry, and many in the' industry are using elements of that concept ~ in' their own maturing programs. We believe, however, that a ' pilot program would have' enabled both the, industry and the NRC..to identify the many unknowns.
' associated with the concept of performance based regulation.
We had focused a
)
on using the emergency diesel generator reliability issue as a pilot program
)
to learn those lessons in a discrete context as opposed to applying it without l
testing to an area as broad as maintenance.
l E
r c
rn s
- m.,,
u a ja L Chairman Selin
, ),
August 16, 1991 r
(,T)
Pa9e 2 The industry's major concerns regarding the maintenance rule are not with the concept of performance-based regulation, but rather. with its application to maintenance and how such a broad concept will be enforced in the field.
We have repeatedly stated our belief that sound maintenance is vital to safe, reliable operation of our plants, our commitment to make improvements in our programs, and our conviction that existing regulations were fully adequate.
Nevertheless, the industry believes that it'is in our long-term interest to proceed ~ aggressively to turn the concept into.a workable reality and to develop guidance, as envisioned in the maintenance rule, that.
draws upon the industry's broad experience and expertise. Our goal will be to develop a method of implementation that will satisfy the industry's objectives and provide an appropriate regulatory basis for the NRC in the maintenance area.
The industry's generic efforts will be focused through and coordinated by NUMARC. A NUMARC working group is being formed to provide an appropriate senior industry management focus in the development of this approach. Mr.
Corbin A. McNeill, President and Chief Operating Officer of. Philadelphia..
Electric Company, will chair the Haintenance Working Group. We have already undertaken. steps to establish a working relationship with senior NRC staff _ to coordinate our activities as we move forward to satisfy our respective.
responsibilities and to resolve any issues _ that.are yet undefined but are sure m
I i
to arise. To ensure that'our efforts are correctly focused, we believe it V
will be important for the Commission to take an active role 'as we work with the NRC staff to develop an acceptable approach to implement the maintenance rule to ensure that there is a common understanding among the Commission, the NRC staff, and the industry so that resolution can be achieved within the established time frame.
Further, after we all have a better understanding of how to implement this rule and its ramifications, we would expect to ask for the Comission to carefully consider whatever recommendations that we conclude would be necessary for successful implementation of the rule.
We would appreciate your support and that of the other Commissioners in this effort.
Sincerely, 7(cr/g Byron Lee, Jr.
BLjr/RWB:bjb cc:
Commissioner Kenneth C. Rogers Commissioner James R. Curtiss s
i Commissioner Forrest J. Remick Mr. James M. Taylor
]
Or. Thomas E. Hurley j
Dr. Eric S. Beckjord 1
9
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