ML20070N882
| ML20070N882 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/13/1994 |
| From: | Krainik A ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Foley T NRC |
| Shared Package | |
| ML20070N848 | List: |
| References | |
| 102-02901, 102-02901-AKK-R, 102-2901, 102-2901-AKK-R, NUDOCS 9405100168 | |
| Download: ML20070N882 (4) | |
Text
i SArprw,umrreuorex P..t Arizona Public Service Cornpany P,ALO VEROC NUCLE AR oENERATING STATION PHOENIX. ARIZONA B6072 2034 P O Box 52034 102-02901 AKK/RAB/JNI i
April 13,1994 Mr. Thomas Foley, M/S 10 A 19 U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Foley:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2, and 3 Docket Nos. 50-528/529/530 Comments on NRC draft inspection Procedure" Maintenance inspection Procedure XXXXX".
File: 94-010-026 Arizona Public Service Company (APS) is responding to the Federal RcG ster notice, i
Vol. 59, No. 24, Friday, February 4,1994 page 5449, soliciting comments on'NRC's draft Inspection Procedure " Maintenance Inspection Procedure XXXXX." APS' comments are provided in the enclosures to this letter.
Should you have any questions, please contact Jeff irwin at (602) 393 5806.
Sincerely,
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A. K. Krainik, Manager Nuclear Ucensing i
AKK/RAB/JN1/did Enclosure cc:
W. F. Conway K. E. Perkins, Jr.
L N. Tran K. E. Johnston 9405100168 940425 PDR REVGP ERGNUMRC PDR ~
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l ENCLOSURE APS COMMENTS ON DRAFT MAINTENANCE INSPECTION PROCEDURE 1
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mm aa w.m e,a Page 3, Implementation Guidance: and Page 3, Requirements versus Acceptable Methods:
Die guideline does not address the expected documentation required for taking exceptions to Regulatory Guide 1.160/NUMARC 93 01, nor does it address how such deviations will be assessed for acceptability.
Page 5, Paragraph 3.02.a.1.(b)(2)
This paragraph implies that condition monitoring as well as reliability / availability monitoring is required for risk significant systems. This is not a requirement of 10 CFR 50.65.
Page 7, Paragraph 3.02.a.3 The requirement to set goals for SSCs with clearly declining pedormance is not a requirement of 10 CFR 50.65. Collecting data and taking early corrective action is a good practice, something that we plan to do, but a formal corrective action document should not be required.
Page 8, Paragraph 3.02.b.1.(b) & (c), and Page 11, Paragraph 3.02.c.2 These paragraphs state that either a single (or repetitive) maintenance preventable failure (MPF) (as opposed to a maintenance preventable functional failure (MPFF)) of components covered under the scope of the rule would require moving the SSC to a(1) with appropriate goal setting. This is not a requirement of and is contrary to other portions of 10 CFR 50.65 which requires a balancing of reliability and availability. In essence. this requirement would require utilities to prevent all component failures (regardless of its impact on function or system / train availability). In order to insure that only functional failures are considered for goal j
setting, a cost intensive scoping at the component level would be required. This paragraph also requires goal setting if performance degrades to an unacceptable value or there is a second MPF. However, goal setting is only required until such time as performance is acceptable. It is highly likely that conditions will occur where the performance is acceptable, g
(as evidenced by the performance criteria) when the second MPF occurs (especially as the system function does not have to be impacted). Does this mean that you set goals and then immediately move back to a(2) as the performance was always acceptable? A better approach would be to only require goal setting if the performance is unacceptable (via the performance criteria).
Page 1 of 2
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P, Page 10, Paragraph 3.02.c.1.(a) i The expectations regarding what is required to disposition from a(1) to a(2) once the root cause of the problem has been identified and equiprnent performance verified are not
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discussed.
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Page 11, Paragraph 3.02.c.3 i
l This paragraph imposes an additional requirement on the documentation requirements j
associated with assessing equipment removed from service above those required by 10 CFR i
50.65, Regulatory Guide 1.160 and NUMARC 93-01. It requires that a single data base be l
established for documenting all Maintenance Rule SSCs that are removed from service. Use of multiple tools (i.e., shift logs, status boards, etc.) is unacceptable, it also requires documented evaluations anytime that equipment is removed from service.
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Page 12, Paragraph 3.02.d.2 The examples should be clarified to recognize that different utilities classify safety related components differently. What may be non-safety related at one utility may be safety related
' another.
Page 13, Paragraph 3.02.d.4 & 5 The requirement to use industry operating experience in determining the scope of the Maintenance Rule is not requred by 10 CFR 50.65.
Page 14, Paragraph 3.02.d.5 It is not clear if the requirement for scoping SSCs is based on. "could cause a trip" or "has caused a trip."
Page 15, Summary of 03.02.d 6
This paragraph implies a requirement for having procedures in place for the scoping effort. This is not required by 10CFR50.65. Reg. Guide 1.160 or NUMARC 93-01.
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m due o o er t m y so Post Office Box 1295 Birmingham, Alabama 3520t Tei: phone (205) 668-5131 Southern Nudear Operating Company o... uo,.y w,..io.ni the southem electnc system paner praieet April 13. 1994 DocketNos. 50-348 50-364 l
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington D.C. 20555 ATTENTION: Mr. Thomas Foley M/S 10-A-19 Comments on NRC draft Inspection Procedure l
" Maintenance Insoection Procedure XXXXX"
Dear Mr. Foley:
3 Southern Nuclear Operating Company has reviewed the NRC draft Inspection Procedure
" Maintenance Inspection Pre'cedure XXXXX " made publicly available by the Federal Register notice on February 4,1994. In accordance with the request fo'c comments, Southem Nuclear is in total agreement with the NEI comments that ce to be provided to l
the NRC. At the request ofNRC staff present at the recent NRC Public Workshop i
l conceming the new draft NRC Maintenance Inspection Procedure, Southern Nuclear has al:o attached additional comments. Also announced at that workshop was the fact that the NRC would be conducting eight pilot non-enforceable inspections ofutility implementation of the Maintenance Rule throughout the country. Performance monitoring programs to meet Maintenance Rule requirements should be in place by August 1,1994.
l Therefore, Southern Nuclear requests that Plant Farley be considered for one of the pilot inspections.
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APR 14 '94 10:22R1 SOUTFERN NJCLEAR 205 870 6108 P. 341 l,
U.S. Nuclear Regulatory Commission Page 2 3
0 Should you have any questions, please advise.
A Respectfully submitted, i
bM%s D. N. Morey i
Southern Nuclear Operating Company DNMSMG Attachment cc: Southern Nuclear Ooeratinn Comcaay Mr.R. D. Hill, Plant Manager U. S. Nuclear _Regulatorv Commission. Washington DC Mr.B. L Siegel, Licensing Project Manager l
U. S Nuclear Regulatory Commission. Region II Mr. S. D. Ebneter, Regional Administrator j
Mr. T. M. Ross, Senior Resident Inspector a
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APR 14 '94 80 22AM SCUTHERN NUCLEAR. 205 870 6108 P.4/11 Comments on NRC Maintenance Inspection Procedure General Comments The general approach of the draft Inspection Procedure does not take advantage of the 4
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 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.
1
" Piggy backing" emergency diesel generator commitments that licensees made as a result of10CFR50.63 " 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.
s Specific Comments Page L Lines 17-20 i
Delete, see genere1 comment above.
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APR 14 '94 10:22AM SOUTHERN NUCLEAR 205 870 6108 P.5/11 Comments on NRC Maintenance Inspection Procedure Page 2 Pane 1. Lines _35-39 Delete "and review equipment history records and other available documentation." This review is not consistent with " Maintenance Effectiveness." The inspector should j
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 records j
or other available documentation takes emphasis away from the Rule's performance based i
I nature. Additionally the statements ".. condition of plant SSCs.." on line 36 and
" condition of SSCs.." on line 38 should refer specifically to SSCs within the scope of the Maintenance Rule.
Pane 1. Footnote 1. Lines 46 50-Footnote 1, states that not allitems 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.
Pane 1 Lines 45 Page 2 line 13 The draft 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.
Page 2. Line 51 -Page 3. Line 3 Delete per first comment (Ref: Comment on Page 1, Lines 17-20).
P_ age 3. Line 36 Similar NSSS review statement should be deleted since Maintenance Rule has gone beyond NSSS part of the plant.
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APR 84 '94 10:23Ar1 SOUTERN NJCLEAR 205 870 6100 P.6/11 Comments on NRC Maintenance Inspection Procedure Page 3 Pane 3. Line 37 Add the following sentence:
"This can be accomplished by the license's existing operating experience program."
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Page 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 Pane 4. Lines 36-46 Reference to the visualinspection as a measure of maintenance effectiveness deviates from the performance t.ased methodology proposed by the Maintenance Rule for establishing maintenance effectiveness, does not restrict the inspector to in scope SSCs, and brings the-detennination of maintenance effectiveness to the component level rather than the SSC level. This section should be removed from the draft Inspection Procedure.
Page 5 Line 2 Changing ".. monitor the performance or condition for all SSCs.." to ".. monitor the performance or condition for those SSCs..."would eliminate confusion.
Page 5 Lines 18-20 l'
Reference to preventive maintenance program results is taken out of context from NUMARC 93-01 and should be deleted.
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APR 14 '94 10:23AM SOUTKRN NUCLEAR 205 870 6108 P.7/11 Comments on NRC Maintenance Inspection Procedure Page 4 Pane S Lines 26-32 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 signi6 cant 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 to61s to independently verify a sample of this review.
Page 5. Lines 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.
Pane 6. Line 23 Revise the sentence that starts on line 23 as follows: "These goals will generally be at the function level and may be performance..."
Page 7. 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 ofNUMARC 93-01.
Pane 7. Line 15-17 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 would not be met before the end of the next surveillance cycle." to "...or where unacceptable SSC performance continues."
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APR 14 '94 10:23AM SOUTHERN NUCLEAR 205 870 6108 P.8/12 Comments on NRC Maintenance Inspection Procedure Page 5 Pane 7. Lines 27-28 Delete. This is prescriptive, not perfonnance based.10CFR65 does not require documentation of RCCA. Other programs do but those are addressed in other NRC inspection guidance.
Pare 8. Lines 1017 The definition ofMPFF and repetitive MPFF is highly subjective. This section 6f the draft 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.
Pane 8 Lines 19-27 The wording related to repetitive MPFFs is not consistent within this section. Lines 19 to 27 abould be deleted, leaving the remainder of the section to reference NUMARC 93-01 section 9.4.4.
Page 8. Lines 35-36: Page 9 Line 10: Pane 10 Line 42 Delete the references regarding a second MPFF. This is not a rule requirement and may be inconsistent with meeting our performance criteria.
Page 8. Lines 35-36 This section should be revised to indicate that SSCs are not automatically placed under the control ofparagraph(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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APR 14 '94 10:24Af1 SOUTHERN NUCLEAR 205 870 6108 P 9/11
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Ccmments on l
NRC Maintenance Inspection Procedure Page 6 Page 9. Line 10 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.
1 1
i Pyc 9. Line 37-31 This section provides guidance for the inspector to evaluate a sample of SSCs that have 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.
L Page 9 Line 45 Clarify " Low Risk Significant."
P_ age 10line 1 Does this paragraph mean tha Licensee should have a predetermined list oflow risk significant SSCs from which the inspector can choose a sample or is a criteria sufficient?-
t Pace 10_Line 10 This section should be revised to account for multi unit sites that might want to do the
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evaluation for both units at the same time within the 24 month cycle but not necessarily immediately following a refueling cycle.
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Pane 10 Lines 31-43
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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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APR 14 o94 10824AM SOUTFERN HJCLEAR 205 870 6100 P.10/11 e'
Comments on
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NRC Maintenance Inspection Procedure l,
Page 7 Pane 11.Line 9 Delete this sentence. (Ref Comment on Page 7, Lines 9-11) 4 Pane 11.1.ines 1518 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.
.. p Pane 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 ofservice. This section should be -
rewritten to: (1) delete the prescriptive nature of the inspection, (2) make it applipable to only SSCs that are risk significant and(3) not require a separate list of SSCs. Guidanza 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.
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Pane 11. Lines 40-41 l
Delete statement to keep all maintenance rule documents in one location. This would hinder our operation and would only serve to make auditing easier.
Pane 11 Line 47 i
Rule does not require a " documented" process.
Pare 11 Line 50 l
l Rule does not require us to " maintain a list" as stated.
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APR 14 '94 _a0:24AM SOUTHERN NUCLEAR 205 870 6108 P.aa/aa Comments on NRC Maintenance Inspection Procedure Page 8 Pane 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.
O Pane 14 Line 1 This section should be revised to be consistent with NUMARC 93-01; indicating that only
- those non-safety -related SSCs whose failure haa. caused a reactor scram or safety system l
actuation should be included in the scope of the Rule. This section currently requires l
SSCs that sg.g]d cause a scram to be included.
Page 14. Lines 18 21 Should add some comment to recognize that design changes that have eliminated trip hazards can be credited in the maintenance program.
Pane 14. Lines 30-32 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 NUMARC 93-01, instead of providing additional guidance, which is not as clear as that in NUMARC 93-01.
Page 17. Lines 4-6 NUMARC 93-01 states that a goal could be the same as the performance criteria. This section of the draft 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.
APR-14-94 THU 16:07 NUC. OPS. SERVICES FAX N0. 203 665 3664 P 02
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Northeast 107 $elden Snect. Dnlun CT 06037
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${ Utilities Systent 3,n3,,,,i:nime.,u me, comp,ny P O. Hot 270 liartford. CT 06 t 410270 (203) 665 5000 April 14, 1994 Docket Hos. 50-213 50-245 50-33_6.19-421 B14819 Re:10CFR50.65 U.
S. Nuclear Regulatory Commission Attention:
Mr. Thomas Foley Suite 300 10-A-19, OWFN Washington, DC 20555
Dear Mr. Foley:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.
1, 2,
and 3 Comments on Draft NRC Maintenance Inspection Procedure The purpose of this letter is to provide the NRC with comments from Connecticut Yankee Atomic Power Company (CYAPCO)
.and
. Northeast Nuclear Energy Company (NNECO) on the NRC Draft Maintenance Inspection Procedure XXXX.
Comments were requested by the NRC Staff at the March 31, 1994, NRC Workshop on this draft procedure.
i On behalf of the Haddam Neck Plant and Millstone Nuclear Power Station, Unit Nos.
1, 2,
and 3, CYAPCO and NNECO hereby provide, as Attachment 1, comments on the draft inspection procedure.
We appreciate the opportunity to participate in the comment process.
Should you have any questions regarding this. matter, please do not hesitate to contact Mr. Gerard van Noordennen at (203) 665-3288.
Very truly yours, a
CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY FOR:
J. F. Opeka Executive Vice President BY:
Ma v
E.
A.
DeBarba Vice President ec:
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APR;14-94 THU 16:08 NUC. OPS. SERV 1CES FAHO~7mF6b65 35B4 K 03 U.S.
Nuclear Regulatory Commission B14819/Page 2 April 14, 1994 cc:
T.
T.
Martin, Region I Administrator
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A.
B.
Wang, NRC Project Manager, Haddam Neck Plant J.
W.
Andersen,- NRC Acting Project Manager, Millstone Unit No. 1 g
G.
S. Vissing, NRC Project Manager, Millstone Unit No. 2 V.
L. Rooney, NRC Project Manager, Millstone Unit No. 3 W.
J.
Raymond, Senior Resident Inspector, Haddam Ncck Plant P.
D.
Swetland, Senior Resident Inspector, Millstonc Unit Nos.
1, 2,
and 3 U.S.
Nuclear Regulatory Commission Attention:
Document Control Desk-Washington, DC 20555
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-Docket Nos. 50-213 l
50-245 50-336 50-423 l
B14819 l
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i Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.
1, 2,
and 3 Comments on Draft NRC Maintenance Inspection Procedure i
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w m nvevs.v a N vs vvvw-5. vs Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.
1, 2,
and 3 Comments on Draft NRC Maintenance Inspection Procedure Pace / Line Nos.
Comment 1
35-39 In the absence of definitive acceptance criteria, the guidance to determine if the licensee has an effective maintenance program is subjective.
How will the inspector determine if the license'e's program i
is effective?
Additionally, what is the inspection rrequency of this procedure?
9, 10 This section discusses the need for licensees to take into account industry-wide operating experience during the establishment of goals.
Is it the NRC expectation that licensees i
develop additional programs to accomplish this or are existing licensee programs adequate?
2 32-36 This section requires licensees to take into
- account, where practical, industry-wide j
operating experience during
.the periodic l
evaluations / assessments.
What is the NRC expectation for licensee usage of industry 1
operating experience?
3 35-37 This section requires the inspector to verify that licensees evaluate maintenance and equipment problems at plants with similar NSSS designs to identify possible generic problems.
Is this evaluation above and beyond those problems reported through normal industry-wide operating experience?
5 26-32 This section states that licensees must have clear criteria for selection of risk significant systems which can be utilized by the inspector in reviewing this determination.
This does not allow'for the use of a " Functional Review" as outlined in NUMARC 93-01.(D (1)
Nuclear Management and Resource
- Council, NUMARC-93-01," Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated May 1993,
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U.S. Nuclear Regulatory Commission B14819/ Attachment 1/Page 2 April 14, 1994 Comments on Draft NRC Maintenanco Inspection Procedure Pane / Line Nos.
Camngnt 1
i 5
34-57 The terms "less-risk-significant" and "more-
)
risk-significant" are not' addressed in either i
These terms must be clearly defined to avoid subjective; interpretations by different inspectors.
The inspection procedure requires some parameter trending for critical components.
This is inconsistent with NUMARC 93-01.
The planned monitoring for all risk significant systems is-system / train availability and reliability.
7 5-12 This section states, "The inspector should verify that the plant.
established and implemented a documented method or process for considering industry operating experience, where practical, when establishing goals."
What is the NRC expectation for plant processes to use industry operating experience when establishing goals?
7 21-28 This section requires licensees to document root cause analyses and corrective actions when either goals are not met or for a
clearly declining trend.
Does this connote a
" formal" root cause analysis must be conducted?
7 22, 23 The term " clearly declining trends" is not i
addressed in NUMARC 93-01, as requiring goal i
setting.
Goal setting is only required if the Performance criteria is not satisfied, or if Maintenance Preventable Functional Failures (MPFFs) have occurred, or repetitive failures have occurred.
8 1, 2' This section appears to impose a requirement that would require additional resources to justify the method for monitoring non-risk-significant
- systems, structures, and
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Nuclear Regulatory Commission B14819/ Attachment 1/Page 3 April 14, 1994 Comments on Draft NRC Maintenance Inspection Procedure Pa cte / Line Nos.
Comment components (SSCc) that are in a standby mode.
While the approach to non-rick-cignificant SSCs that are in a standby mode is consistent with NUMARC 93-01, it should be noted that nothing in the inspection procedure specifically requires systems / train level performance monitoring criteria for standby systems.
8 20-23 This scotion states in part, "where one or more maintenance preventable failures (or MPFFs) occur on SSCs..."
For consistency with NUMARC 93-01, this sentence should be changed to:
"when one or more repetitive maintenance preventable functional failures (MPFFs) occur..."
9 45 What is the definition of
" Low Risk Significance"?
Does this mean "non-risk-significant" as definod in NUMARC 93-017 If the answer is yes, then the terms should be consistent.
10 31-33 This section discusses the potential need to adjust preventive maintenance (PM) activities where the SSC availability is " judged to be unacceptable".
There should not be a
requirement to adjust PM activities if the ectabliched performance goals are being met.
In addition, the term " judged unacceptable" should be cefined to eliminate si:bjective interpretations.
10 36, 37 The statement "...other remedial action, such as modification or replacement" is indeed within the scope of Goal Setting which is considered as a corrective action plan within NUMARC 93-01.
Therefore, this sentence should simply
- state,
" subject to the requirements of paragraph (a) (1). "
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Nuclear Regulatory Commission B14819/ Attachment 1/Page 4 April 14, 1994 Comments on Draft NRC Maintenance Inspection Procedure 1
I Pace / Line Nos.
Cnnunt
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10 45-55 The industry-wide operating experience program is an ongoing. requirement where action is
- taken, as appropriate, as individual events and/or trends are l
identified to other licensees.
Why is this program included as part of the periodic
(
l assossment?
I 11 36-52 This section discusses the need to keep track of the status (in or out of service) of plant equipment and that the status should be kept in one location.
In addition, this section states that the inspector should verify the adequacy of the evaluations made by the licensee before taking the SSCs out of l
service.
What are the expectations of the l
NRC since these requiromonts arc not specified in NUMARC 93-01?
13 6-11 The requirement to document the specific reason why a non-safety related SSC contained within the Emergency Operating Procedures was classified as "out-of-scope" is new and is i
clearly inconsistent with NUMARC 93-01.
14 30-32 The basis statement would indicate that all SSCs with existing maintenance requirements can be excluded.
The items can be excluded because they do not meet the minimum threshold and are being maintained effectively.
The " maintain effectively" may be truly pushing the envelope on some SSCs.
s 15-17 There are surprisingly numerous details relative to the emergency diesel generators (EDG).
Does this imply that pilot inspection licensees must have the EDG Maintenance Rule requirements implemented prior to the inspection?
Is there a specific date, other than the Maintenance Rule compliance date (July 10, 1996) that the EDGs must be
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B14819/ Attachment 1/Page 5 April 14, 1994 Comments on Draft NRC Maintenance Inspection Proceduro Pace / Line Nos.
. Comment i
complete for Station Blackout Rule compliance?
17 3-7 This section implies that whatever number of hours of unavailability the licensee establishes as acceptable (regardless of the value),
can be second guessed by the inspector without basis.
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