ML20065L653
| ML20065L653 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/13/1994 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | Foley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9404210205 | |
| Download: ML20065L653 (10) | |
Text
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Southern Nuclear Operanng Company Post Office Box iP95 Birmingharn. A'abama 35201 Telephone (205) 868-5131 L
Southern Nudcar Operating Company o.vo ue,ey vice Proodent farief pro lsC1 Ihe Willhern U!%ffrG 5'6!ern April 13, 1994 Docket Nos. SC-348 50-364 U.S. Nuclear Regulatory Conunission Office of Nuclear Reactor Regulation Washington D.C. 20555 ATTENTION: Mr. Thomas Foley M/S 10- A-19 Comments on NRC draft inspection Procedure "Mainivniince.Jnsnqction Procqdure XXXXX" Dear Mr. Foley.
Southern Nuclear Operating Company has reviewed the NRC drall Inspection Procedure "Maintena11erJnspeelinDJ!rpmlurg_XXXXX," made publicly available by the Federal Register notice on February 4,1994. In accordance with the request for comments, Southern Nuclear is in total agreement with the NEl comments that are to be provided to the NRC. At the request of NRC staff present at the recent NRC Public Workshop concerning the new drat 1 NRC Maintenance inspection Procedure, Southern Nuclear has also attached additional comments Also announced at that workshop was the fact that the NRC would be conducting eight pilot non-enforceable inspections of utility implementation of the Maintenance Rule throughout the country. Perfbrmance monitoring programs to meet Maintenance Rule requirements should be in place by August I,1994.
Therefore, Southern Nuclear requests that Plant Farley be considered for one of the pilot inspections.
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Page 2 Should you have any questions, please advise.
Respectfully submitted, 0 '1 2hvw!
D. N. Morey Southern Nuclear Operating Company DNM/JMG Attachment cc: Equthern Nuclear Operating Company Mr. R. D. Hill, Plant Manager U. S. NLLclqadegulatory Commi1sion. Washington _D1 Mr. B. L. Siegel, Licensing Project Manager U S. Np_ clear Regulatory Cinnmission. Region II Mr. S. D. Ebneter, Regional Administrator Mr. T. M. Ross, Senior Resident Inspector 9
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Comments on NRC Maintenance Inspection Procedure General Comments The general approach of the draft Inspection Procedure does not take advantage of the performance based nature of the Maintenance Rule. The Procedure is written to be more prescriptive than performance based. In general, the Procedure should be re-written to recognize that most utilities will: (1) utilize NUMARC 93-01 recommended performance criteria prior to the need for goals; and (2) control SSCs under paragraph (a)(2) and move them to paragraph (a)(1) based on performance. The inspector should be guided to review the output of the licensee's implementation, e.g., performance of risk significant i
SSCs against performance criteria and the establishment ofgoals where required as a basis for performing additional activities.
Several sections of the Inspection Procedure refer to the use ofindustry wide operating experience used in implementing the maintenance rule. Industry wide operating experience programs are on going programs where action is taken as individual events or trends are identified to the utilities. The Inspection Procedure should be revised to reference existing NRC Inspection procedures for evaluating industry operating experience programs instead of providing new guidance.
" Piggy backing" emergency diesel generator commitments that licensees made as a result of 10CFR50.63 " Loss of All Alternating Current Power" into the inspection Procedure is confusing and unnecessary. If a plant has established an effective maintenance program for the whole plant, which includes diesel generators,it should not be necessary for the NRC to specify additionally that we must have an effective maintenance program for diesel generators. In addition many plants made commitments to 10CFR50.63 that go beyond effective maintenance yet this inspection procedure does not seem to recognize that fact.
Specific Comments hatLLinz 17-20 Delete, see general comment above.
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Comments on
'l NRC Maintenance Inspection Procedure Page 2 bgdJ,ines 35-39 Delete "and review equipment history records and other available documentation." This review is not consistent with " Maintenance Effectiveness." The inspector should determine if the licensee's maintenance program is effective through determination of whether or not performance criteria are being met as opposed to the subjective methods described in this paragraph. The inspector should review and concur with the reasonableness of the site's performance criteria. Reliance on equipment history r.sords or other available documentation takes empharis away from the Rule's performance based nature. Additionally the statements ".. condition of plant SSCs.." on line 36 and
" condition of SSCs.." on lii J should refer specifically to SSCs within the scope of the Maintenance Rule.
has_Lliqlqote IJings 46-50 Footnote 1, states that not all items listed in this section are necessarily regulatory requirements unless explicitly stated. Since non-regulatory requirements are out of scope, all non-regulatory requirements should be deleted.
hgc_LLinss 45-Page_2Jine 13 The draf1 Inspection Procedure appears to assume that there will be a permanent population of SSCs that are controlled in accordance with Rule paragraph (a)(1).
Implementation of NUMARC 93-01 will result in all SSCs being evaluated to (a)(2) criteria for determination of the need for goals and goal monitoring. The potential for there being no SSCs in (a)(1) needs to be addressed in this section.
hadding 51 - Page 3. Lind Delete per first comment (Ref.: Comment on Page 1, Lines 17-20).
hge 3. Line 36 Similar NSSS review statement should be deleted since Maintenance Rule has gone beyond NSSS part of the plant.
l-1 Comments on NRC Maintenance Inspection Procedure Page 3 bgdJine 37 4
Add the following sentence:
"This can be accomplis. ed by the license's existing operating experience program."
bge 3. Lines 45-46 The Maintenance Rule is very unclear and required a large NUMARC document for interpretation. This sentence could give inspectors open license to employ their own interpretations of the ' clarity' of these requirements.
i bge.4, Lines 36-46 I
Reference to the visual inspection as a measure of maintenance effectiveness deviates from i
the performance I ased methodology proposed by the Maintenance Rule for establishing maintenance efTectiveness, does not restrict the inspector to in-scope SSCs, and brings the determination of maintenance effectiveness to the component level rather than the SSC level. This section should be removed from the draft Inspection Procedure.
bge 5 Line 2 Changing ".. monitor the performance or condition for all SSCs.." to ". monitor the performance or condition for those SSCs.. "would eliminate confusion.
hac.1Linctl.830 Reference to preventive maintenance program results is taken out of context from NUMARC 93-01 and should be deleted.
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l Comments on NRC Maintenance Inspection Procedure Page 4 "agCJ.liacils:22 Depending upon which method was used, the inspector may or may not be able to use the licensee's own criteria to determine if the licensee has identified those SSCs that are risk significant. The inspector should evaluate the methodology used, review the resultant risk significant SSCs, and verify that the methodology was properly implemented. For our plants risk significance determination was done with PRA computer models and expert panel review, We are concerned that the inspector will not have the tools to independently verify a sample of this review.
Pase_5.LLinc3 34-54 Needs clarification. We do not intend to have a graduated risk significant scale. Either it is risk significant or it is not risk significant, per NUMARC 93-01.
EagcJLLin9 21 Revise the sentence that starts on line 23 as follows: "These goals will generally be at the function level and may be performance.. "
Eagc_2 lines 9-11 Delete. This statement is prescriptive, whereas, the Maintenance Rule is supposed to be performance based. Credit should be given for licensees existing OEP and existing NRC inspection procedures. In general the wording should be changed to be more consistent with section 9.4 of NUMARC 93-01.
19Ec l Lin93 1-11 A better definition is needed concerning what a " clearly declining trend" means. Change
" or where a clearly declining trend in SSC performance or condition indicates the goals j
would not be met before the end of the next surveillance cycle." to "..or where unacceptable SSC performance continues."
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- Comments on NRC Maintenance Inspection Procedure Page 5 PJigc.llinc121-28 Delete. This is prescriptive, not performance based.10CFR65 does not require
. documentation of RCCA. Other programs do but those are addressed in other NRC inspection guidance.
bge 8. Litics 10-17
'l The defmition of 31PFF and repetitive MPFF is highly subjective. This section of the drafl j
Inspection Procedure should require the inspector to evaluate the licensees methodology for making MPFF and repetitive MPFF determinations. This section should reference the Rule, Regulatory Guide, NUMARC 93-01 and NUMARC Workshop questions and answers when performing this evaluation.
Pac _8_Li.nes 19-27 The wording related to repetitive MPFFs is not consistent within this section. Lines 19 to-i 27 should be deleted, leaving the remainder of the section to reference NUMARC 93-01 i
section 9.4.4.
bge 8. Lines 35-36: Pagq1Line 10: hge 10 Line 42 Delete the references regarding a second MPFF. This is not a rule requirement and may be inconsistent with meeting e 1 performance criteria.
Page 8. Lines 35-36 This section should be revised to indicate that SSCs are not automatically placed under the control of paragraph (a)(1). The movement from paragraph (a)(2) to (a)(1) is based on an evaluation of the MPFFs, their cause and corrective action.
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Comments on NRC Maintenance Inspection Procedure Page 6 bge_2 din 03 The term maintenance preventable failure used in this line and others should be changed to maintenance preventable functional failure to be consistent with Regulatory Guide 1.160 and NUMARC 93-01.
hge_2di.n_c_37-38 This section provides guidance for the inspector to evaluate a sample of SSCs that have
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been determined by the licensee to be inherently reliable by reviewing the associated documentation. This section should be revised to guide the inspector to review the licensee implementation methodology to provide the justification and basis for any exclusion decisions.
bge 9. I.ine 45 Clarify " Low Risk Significant "
bge_10 Line 1 Does this paragraph mean the Licensee should have a predetermined list oflow risk significant SSCs from which the inspector can choose a sampic or is a criteria sullicient?
bgsl0.liticM This section should be revised to account for multi unit sites that might want to do the evaluation for both units at the same time within the 24 month cycle but not necessarily immediately following a refueling cycle.
bgel0_Ljnes 31-43 This section should be revised to state that if unavailability is the performance criterion and performance isjudged to be acceptable, then the system / train can remain in paragraph (ax2).
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Comments on
'NRC Maintenance Inspection Procedure Page 7 Page 1llinc_2 Delete this sentence. (Ref. Comment on Page 7, Lines 9-1!)
bge 11. Lines 15-18 Delete this sentence. As it is written, the licensee would be required to prove that the Maintenance Rule has forced us to get better and to document this proof.
hge 11. Lines 20-52 This section of the draft Inspection Procedure requires a prescriptive evaluation of the licensees work control scheduling process as it relates to consideration of risk to core damage. This section includes prescriptive requirements that are not included in the Rule, Regulatory Guide or NUMARC 93-01, e.g., maintenance of a single list of SSCs and identification as to whether the SSCs are in or out of service. This section should be rewritten to: (1) delete the prescriptive nature of the inspection, (2) make it applicable to only SSCs that are risk significant and(3) not require a separate list of SSCs. Guidance should be provided to the inspector to evaluate the methodology developed by the licensee for consideration of risk and the implementation of that methodology. Review of the adequacy of the evaluation should be based on the licensees methodology.
hgelllincs 40-41 Delete statement to keep all maintenance rule documents in one location. This would hinder our operation and would only serve to make auditing easier.
bgcllline 47 Rule does not require a " documented" process.
haclklint.10 Rule does not require us to " maintain a list" as stated.
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Comments on NRC Maintenance Inspection Procedure l
Page 8 bgc_12, Lines 22-26 Delete this example since it prejudges that all of these non-safety systems will be in the scope of the rule.
bge 14 Line i This section should be revised to be consistent with NUhfARC 93-01; indicating that only those non-safety -related SSCs whose failure has caused a reactor scram or safety system actuation should be included in the scope of the Rule. This section currently requires SSCs that could cause a scram to be included.
bge_L4J.ines 18-21 Should add some comment to scrognize that design changes that have climinated trip hazards can be credited in the maintenance program.
bge 14. LugD0-32 This section provides guidance related to the exclusion of SSCs from the scope of the Rule based on their already having programs requiring control of their maintenance. This section should reference NUh1 ARC 93-01, instead of providing additional guidance, which is not as clear as that in NUh1 ARC 93-01.
bge 17. Lings 4 6 NUhiARC 93-01 states that a goal could be the same as the performance criteria. This section of the dral1 Inspection Procedures indicates that the goal should be more aggressive than the performance criteria. This section should be revised to indicate that goals should be established based on performance and corrective action defined by the licensee.
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