ML20070N873
| ML20070N873 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 03/23/1994 |
| From: | Dewease J ENTERGY OPERATIONS, INC. |
| To: | Foley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20070N848 | List: |
| References | |
| CNRO-94-00008, CNRO-94-8, NUDOCS 9405100155 | |
| Download: ML20070N873 (5) | |
Text
'
~
~
~ ~ ~
O==.
s:=
= ENTERGY lT"" *g'a*"
ns
'n
~ g:.c :. ;.
Jerrold o. Deweace March 23,1994 Mr. Thomas Foley Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Conunission Washington, DC 20555 Mail Stop 10-A-19
Subject:
Entergy Operations, Inc. Comments on the Draft Maintenance Inspection Procedure
Reference:
Federal Register Volume 59, Number 24,5449, Dated February 4,1993 CNRO-94/00008
Dear Sir:
The referenced Federal Register listing invited comments on the draft Maintenance Inspection Procedure. Entergy Operations,Inc., the licensee for Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station has reviewed the proposed rule change and offers the following comments for your consideration.
In general, the inspection procedure is consistent with the Rule and Guideline. We are encouraged that the inspection procedure reflects a performance based approach to inspections rather than a compliance based approach. This procedure is indicative of successful interaction between the industry and the NRC. However, some portions, as discussed in the attachment, appear to communicate expectations that are not consistent with or in excess of that required by the current regulation. Our comments are being submitted in advance of the public workshop m
)
i hopes that they may be useful for meaningful dialogue at the workshop, 3
9405100155 940425 PDR REVGP ERGNUNRC:
l.
l-l l
Entergy Operations Comments on the Draft Maintenance Inspection Procedure Page 2 of 2 CNRO-94/00008 March 23,1994
)
l In addition to our specific comments noted herein, Entergy Operations, Inc, provided input to the l
Nuclear Energy Institute (NEI) in regard to this request for comments.
l We appreciate the opportunity to provide our comments on the proposed inspection procedure l
and welcome any attempts for the industry and NRC to work together for performance based inspection guidance that is consistent with the requirements of the regulation without being unduly burdensome.
Our detailed comments are included as Attachment 1 to this letter.
Sincerely, b
v I
JGD/jkw attachment cc:
Mr. T. W. Alexion Mr. N. S. Reynolds l
Mr. R. H. Bernhard Mr. R. G. Schaaf l
Mr. R. P. Barkhurst -
Ms. L. J. Smith Mr. R. B. Bevan, Jr.
Mr. W. F. Smith Mr. L. J. Callan Mr. H. L. Thomas l
Mr. J. F. Colvin Mr. D. L. Wigginton Mr. S. D. Ebneter Mr. J. W. Yelverton Mr. E. J. Ford Corporate File [ ]
Mr. C. R. Hutchinson DCC (ANO)
Mr. J. R. McGaha Records Center (W-3)
Mr. R. B. McGehee Central File (GGNS) 1 Mr. P. W. O'Connor 3
l l
\\
Attachment I to CNRO-94/00008 Page1of3 March 23,1994 i
Entergy Operations Comments on the Draft Maintenance Inspection Procedure l
General Overall, the inspection procedure is consistent with the intent of the Rule. For the most part, it reflects a performance based approach that is consistent with the expectations of the industry Verification & Validation group. However, some portions appear unnecessarily prescriptive and process oriented rather than performance oriented.
Additionally, some portions appear to have expectations beyond that which is required by the Rule or the Guideline. Entergy Operations' primary concerns are discussed below with references to specific pages and lines of the draft maintenance procedure.
Specific Comments Pg 3,line 1519:
The inspection guide tends to emphasize emergency diesel generators separate from the Maintenance Rule. Such emphasis could yield two essentially separate maintenance programs, one for EDG's and one for everything else. This may lead to confusion and imply inadequacy in the Rule's ability to monitor for effectiveness of maintenance in all cases. Such duplication is unnecessary and never intendep by the Rule or the NUMARC e
Industry Guideline (93-01).
Pg 3,line 35 and pg 7,line 9:
The reference to similar NSSS designs is confusing and should be removed. Presumably this is intended to refer to operating experience type programs that are discussed on page 10,1(c). These programs should satisfy the intent of the 10CFR50.65(a)(3) for "taking into account, where practical, indu-strywide operating experience." The reference to similar NSSS designs could be misconstrued to imply that actions beyond that required by the rule are necessary. Also, existing operating experience programs should not be inspected as part of this procedure except to the c.xtent that they take into account
~
industrywide operating experience where practical.
Pg 4,line 22-47:
The guidance given for performing a more in-depth and extensive inspection is very subjective with no definitive tie to performance. For a performance based rule, some
-. ~ 1
,s Attachment I to CNRO-94/00008 Page 2 of 3 March 23,1994 specific tie to performance is expected. This guide relies solely on the inspector's judgment to initiate more extensive inspection. Such vagueness could lead to differences between regions and all the other complaints about inconsistency that the NRC tries to avoid. A more performance oriented approach should be provided here.
It is not clear why walk-down inspections are included in the inspection guide. The examples cited should be addressed by corrective maintenance and may not represent failures addressed in the Maintenance Rule. As such, examples such as corrosion, vibration, loose fasteners, etc., do not appear appropriate for an inspector to use as a basis for more rigorous inspections. This could lead to wasting resources by both the inspector and the licensee. The true measure of program effectiveness will be whether or not performance is acceptable and performance goals are met.
Pg 11, line 49:
=
I i
l The process described conveys a very prescriptive approach that is not reflective of the equivalent section in NUMARC 93-01. The NRC should recognize many different methods are possible that will capture the intent of this section of the rule. Guidance is given to verify the licensee maintains a list of all SSCs within the scope of the Rule and l
that the licensee updates this list to indicate when SSCs are out of service. Also, it should be recognized and emphasized in the inspection procedure that risk significant SSCs have the predominant impact on the performance of safety functions and are thus of primary concern. The assessment of equipment out of service is required "to ensure that the plant is not placed in risk-significant configurations." As such, it should follow that special controls should be necessary only for activities that involve removal of risk-significant equipment from service.
Pg 13, line 13-41:
This section should be revised to acknowledge the common industry practice ofincluding this equipment in a site's Q-list for non safety related SSCs whose failure could prevent safety-related SSCs from fulfilling their intended function. Many utilities will have no equipment in this category.
Pg 13,line 43:
=
What level of scoping is expected for this category of non-safety related SSCs that could cause a scram or actuation of a safety system? Line 44 states that licensees are required to identify... those non-safety related SSCs whose failure could cause a reactor scram or safety system actuation. Since the Rule allows plant level goals for this category, little
,6 Attachment I to CNRO 94/00008 Page 3 of 3 March 23,1994 1
benefit is seen in scoping, even at the system level. Furthermore, the Rule only requires performance or condition monitoring against goals that are commensurate with safety; it doesn't require identification of SSCs if the goals can be established without SSC scoping. As such, this expectation does not appear to be consistent with the requirements l
of the Rule or the Guideline.
Pg 15,line 7:
I As currently written, this section on documentation seeks more than is required by the Rule or the Guideline. The inspection guide should direct that the process for establishing goals (or performance criteria) be documented. Additionally, it should require the documentation to demonstrate that the monitoring program covers all SSCs as required by 50.65(b). Ilowever, this may be possible without the use of SSC databases.
Equipment covered by plant level goals may not require scoping, even at the system level.
l G
t
~
,