ML20057D766
| ML20057D766 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1993 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Tipton T NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9310050336 | |
| Download: ML20057D766 (12) | |
Text
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L Mr. Thomas E. Tipton September 16, 1993 Vice President and Director Operations, Management, and Support Services Division Nuclear Management and Resources Council 1776 Eye Street, N.W., Suite 300 Washington, DC 20006-3706
Dear Mr. Tipton:
The detailed text that was developed as part of the NRC presentation at the NUMARC industry workshops on the implementation of the Maintenance Rule, is enclosed for your use and information. A copy of this material will be placed in the Public Document Room.
Should you have any questions regarding this matter, please contact Richard P. Correia at (301) 504-1009.
Sincerely, Original signed by Ashok Thadani for William T. Russell, Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation
Enclosure:
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ENCLOSURE TALKING POINTS FOR THE NRC PRESENTATION AT THE NUMARC MAINTENANCE WORKSHOPS (TITLE SLIDE)
The NRC is pleased to participate in the NUMARC Workshop on the implementation of the Maintenance Rule. We feel this is an important opportunity to communicate and facilitate implementation of the rule and regulatory guide. With me today are members of the NRC staff from the Office of Nuclear Regulatory Research, The Office of Nuclear Reactor Regulation, and the NRC Regional Offices. We will participate in the breakout sessions and be available to answer questions during the breakout sessions.
I would like to begin by discussing key aspects of the Maintenance Rule i
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l (Slide 1)
OBJECTIVE OF MAINTENANCE RULE This maintenance rule requires that licensees monitor the performance or condition of certain structures, systems and components (SSCs) against licensee established goals in a manner sufficient to provide reasonable assurance that those SSCs will be capable of performing their intended function.
The rule contains four sections:
Section (a)(1) describes the requirements for utility goal setting and monitoring; Section (a)(2) allows monitoring to be deleted for those SSCs controlled under an appropriate preventive maintenance program; Section (a)(3) requires the performance of periodic evaluation and adjustment activities Section (b) defines the scope of the rule The rule will be effective July 10, 1996.
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(Slide 2)
SCOPE: 50.65(b) i One of the reasons the maintenance rule was developed was a long standing concern in the NRC about the failures of balance of plant equipment and their contribution to safety system actuations, plant trips, and resulting failures of safety related equipment.
Consequently, the rule was written to specifically include non-safety-related SSCs.
The scope of the rule includes:
All safety-related SSCs Non-safety-related SSCs that:
Mitigate accidents or are used in EOPs Whose failure could prevent safety-related SSCs from fulfilling their intended function Whose failure could cause a scram or actuation of a safety system When identifying the plant specific non-safety related SSCs utilities are expected to use both plant specific and industry operating experience and not a " detailed" what if analysis to determine SSCs whose failures could cause a scram or safety system actuation. This concept will be covered in some detail during the workshop.
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(Slide 3)
GOAL SETTING AND MONITORING: (a)(1)
The fundamental concept of the maintenance rule is monitoring the effectiveness of maintenance rather than meeting programmatic requirements. This is a performance based rule.
Section (a)(1) requires that licensees monitor the performance or condition of SSCs, against licensee established goals, in a manner sufficient to provide reasonable assurance that they will perform their intended functions. Goals are established by each licensee, not the NRC. They are to be commensurate with the safety significance of the SSC and may be performance-oriented such as reliability or availability; or, condition-oriented such as pump flow or head. Licensees are encouraged to use PRA or IPE results in determining the importance of maintenance for SSCs in setting goals.
Licensees are required to monitor the performance or condition of the SSCs against these goals and to take corrective action when goals are not met. It is also acceptable to establish performance criteria for SSCs under a facility preventive maintenance program which if met would demonstrate effectiveness of the utility's preventive maintenance program. NRC expects that most SSCs performance will be evaluated as a part of a preventive i
maintenance program. NRC also expects that monitoring against
. specific goals under (a)(1) will receive high level management attention within the utility.
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(Slide 4)
PREVENTIVE MAINTENANCE WITHOUT MONITORING:
(a)(2)
When the maintenance rule was drafted it was recognized that there are SSCs in every plant whose performance is effectively controlled by preventive maintenance activities. To accommodate those SSCs, section (a)(2) allows SSCs whose performance or condition is adequately controlled by preventive maintenance to be exempt from the monitoring required by section (a)(1) of the rule.
To define " adequately controlled", NUMARC developed the concept of " performance criteria" which, if met, constitutes demonstration that preventive maintenance activities are adequate.
Each licensee is expected to develop performance criteria for SSCs maintained under Section (a)(2) of the rule and, following a second failure, to transfer SSCs that don't meet these performance criteria to (a)(1).
Generally an SSC that experiences a single maintenance preventible failure would require a root cause evaluation and corrective action. An SSC that experiences a second maintenance preventible functional failure would require a root cause evaluation and goal setting and monitoring under section (a)(1) of the rule.
The rule is intentionally silent on the type of preventive maintenance program a utility implements. It could be periodic, reliability centered, or based upon condition. Any preventive maintenance program which is effective is acceptable. There are aspects of a reliability centered maintenance program which would facilitate assessments required under (a)(3).
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(Slide 5)
EVALUATION AND ADJUSTMENT ACTIVITIES: (a)(3)
The original rule required that performance and condition monitoring activities and associated goals and preventive maintenance activities be evaluated at least annually, taking into account, where practical, industry-wide operating experience.
However, as the result of comments and suggestions from NUMARC and several licenses, the rule was amended to change the evaluation cycle from annual to at least every refueling cycle provided the interval between evaluations does not exceed 24 months.
Section (a)(3) also requires that adjustments be made where necessary to ensure that the objective of preventing failures of SSCs through maintenance is appropriately balanced against the objective of minimizing unavailability of SSCs due to monitoring or preventive maintenance. This is intended to avoid situations where excessive maintenance or monitoring of an SSC causes that SSC to be unavailable and thus adversely impact safety.
Section (a)(3) also requires that an assessment of the total plant equipment out of service and overall effect on plant safety functions be made whenever plant equipment is taken out of service for maintenance. This requirement is in addition to any operability requirements in facility Technical Specifications.
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(Slide 6)
DEVELOPMENT OF REGULATORY GUIDANCE In order to facilitate the development of guidance for the implementation of the maintenance rule ajoint NRC/NUMARC steering group was formed in late 1991. It was decided that both the NRC and NUMARC would develop their own versions of implementation guidance. The steering group met in a series of i
eight public meetings to discuss the details of both versions of the guidance.
In June 1992 the NRC informed NUMARC that their latest version of the NUMARC 93-01, " Industry Guideline for i
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" had developed to the point where it would, with some additional work, be acceptable to the NRC. At that time the NRC staff suspended work on its own guidance and directed its efforts to the review of the NUMARC document and the i
preparation of a Regulatory Guide that would endorse the NUMARC 93-01.
During July through December 1992 NUMARC and industry representatives performed a Verification and Validation of the Industry Guideline document NUMARC 93-01. The NRC participated in the V&V process as observers.
i The NRC published a draft regulatory guide for comment which proposed endorsement of the Industry Guideline, NUMARC 93-01 as providing acceptable methods for implementing the maintenance rule. Public comments were resolved by the staff and the Regulatory Guide 1.160 was issued in June 1993 i
endorsing the NUMARC Guideline.
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(Slide 7)
REGULATORY GUIDE 1.160 The scope of monitoring efforts under the maintenance rule, as defined in 10 CFR 50.65(b), encompasses those SSCs that directly and significantly affect plant operations, regardless of what organization performs the maintenance activities. For I
example, since maintenance activities that occur in the switchyard can directly affect plant operations, all electrical distribution equipment out to the first inter-tie with the off-site distribution system should be considered for inclusion under the scope of the maintenance rule. This means that even though the maintenance in the switchyard may be performed by off-site maintenance personnel, the work is still within the scope of the rule. As a result, plant management needs to be aware of and have the ability to control these activities.
At the time of development of the maintenance rule regulatory guide, the staff had underway a rulemaking to revise the station blackout rule. Under the rule licensees made commitments to maintain the emergency diesel generator target reliability of 0.95 or 0.975. The proposed rule would have required, among other i
things, testing and record keeping to demonstrate those commitments. The staff recommended that subject to certain revisions to the NUMARC guideline, and regulatory positions in the Maintenance Rule Regulatory Guide, that SBO rulemaking was not needed. These examples relate to goal setting and/or performance criteria for Emergency Diesel Generators. A utility should use their selected reliability target (i.e. their SBO commitment to the NRC) as either a goal with subsequent monitoring or a performance criterion, under the maintenance rule.
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(Slide 8)
REGULATORY GUIDE 1.160 (continued)
Similarly, plant specific emergency diesel generator unavailability due to maintenance, assumed in the Individual Plant Examination (IPE) analysis, should be used as the basis for a goal or performance criterion under the maintenance rule. In establishing reliability and unavailability goals or performance criteria, licensees should consider the objectives of (a)(3) and balancing preventing failures of SSCs through maintenance against minimizing unavailability of SSCs due to manitoring or preventive maintenance.
EDG performance could be monitored using the trigger values from NUMARC 87-00, Appendix D or equivalent licensee established unavailability criteria.
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(Slide 9)
EMERGENCY DIESEL GENERATOR TESTING AND REPORTING REQUIREMENTS The NRC staff is preparing a generic letter that will advise licensees that they may request a license amendment to remove accelerated testing and special reporting requirements for emergency diesel generators (EDGs) from plant technical specifications (TS).
The staff will recommend that licensees adopt the accelerated testing provisions of the improved Standard Technical Specifications with an option to relocate the accelerated testing requirements for EDGs from the technical specifications to the maintenance program after the maintenance rule goes into effect on July 10, 1996.
However, those licensees who wish to implement the maintenance rule early may request the removal of the TS provisions for accelerated testing and special reporting requirements for EDGs at that time. Licensees who do so must commit to implement a maintenance program for monitoring EDG performance consistent with the provisions of the maintenance rule and the guidance of Regulatory Guide 1.160.
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(Slide 10) o 4
FUTURE ACTIVITIES The NRC staff will prepare an inspection procedure that will be used to verify the implementation of the maintenance rule. A draft of this procedure will be discussed at a public workshop in the spring of 1994. I know many of you are anxious to know what will be included in the inspection procedure so you can take it into account when developing your program for implementing the maintenance rule. The inspection procedure will be developed from the maintenance rule,10 CFR 50.65 and the industry guideline NUMARC 93-01. Thus if you want to know what will be in the mspection procedure you should refer to those two documents.
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The NRC staff plans to perform pilot inspections during late 1994 and early 1995 to validate draft inspection procedures and give the selected licensees early feedback on their implementation of the rule. The results will be provided to licensees for information only, no enforcement actions will be taken. The selection of plants will be coordinated through NUMARC who will ask for volunteers from those utilities who are fairly far along implementing the rule.
The NRC will hold another workshop, probably in the spring of 1995 to discuss lessons learned during the pilot inspections and the final version of the inspection procedure.
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