ML20070N886
| ML20070N886 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/13/1994 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | Foley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20070N848 | List: |
| References | |
| NUDOCS 9405100177 | |
| Download: ML20070N886 (7) | |
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RonERT E. Denion Baltimore Gas and Electric Company Vice President Calvert Cids Nuclear Power Plant Nuclear Energy 1650 Calvert Cifs Parkway Lusby, Maryland 20657 410 $86-2200 Ext. 4455 Local 4to 260-4435 Baltimore April 13,1994 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington,DC 20555 ATTENTION:
Mr. T. Foley Performance & Quality Evaluation Branch
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on the Draft NRC Maintenance Inspection Procedure (59FR5449)
REFERENCE:
(a)
Nuclear Management and Resources Council, NUMARC 93-01,
" Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," May 1993 Baltimore Gas and Electric Company appreciates the opportunity to comment on the draft Maintenance Inspection Procedure. We worked closely with a number of NRC Region Ilicensees to develop the detailed comments provided in the attachment. During those discussions, we developed a few general comments based on the assumption that the inspection procedure will be used for both pilot and actual Maintenance Rule inspections.
As we reviewed the inspection procedure, we expected to find that it took advantage of the performance-based nature of the Maintenance Rule. The procedure appears to be written in a more prescriptive and process-oriented manner than required for a performance-based rule. Given the coop erative, working relationshi) between industry and NRC during development of NUMARC 93-01, we recommend t1at the NRC revise the inspection procedure to recognize that most utilities will use the NUMARC 93-01 recommended performance criteria in order to preclude a situation arising where a goal will have to be established (Section 9.3.4, NUMARC 93-01). Similarly, but specific to the Maintenance Rule, the procedure should also be revised to recognize that most utilities will choose to monitor the performance of systems, structures and components under (a)(2) of the rule against established performance criteria and only place them under (a)(1) of the rule if their performance is unacccptable.
9405100177 940425 PDR REVCP ERGNUMRC.
Mr. T, Foley April 13,1994 Page 2 Further, we recommend that the inspector should be guided to review the trended results of a licensee's maintenance program to determine which specific inspection activities should be performed. In essence, we recommend that the NRC closely preserve the inherent flexibility of this first performance. based regulation by directing the inspector to first review performance criteria established under the Rule and NUMA.RC 93 01. The inspection procedure should only be implemented when these criteria are not met. Our specific comments are discussed in Attachment 1.
Should you have any questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, t
RED /JMO/ dim Attachment cc:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC i
D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McLean, DNR J. H. Walter, PSC 1
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ATTACHMENT (1)
I DRAFT MAINTENANCE RULE INSPECTION GUIDE BALTIMORE GAS & ELECTRIC COMPANY's COMMENTS 4
i Baltimore Gas and Electric Company has the following specific comments on the draft Maintenance Rule Inspection Guide.-
Pane 1. Footnote 1. Ltnes 46 50 j
Footnote 1 states that not all items listed in this section are necessarily regulatory requirements unicss cxplicitly stated. Since non regulatory requirements are out of scope, all non-regulatory requirements should be deleted.
l Pane 1. Paranraph 02.01. Lines 35 39 i
The statements, "... condition of plant SSCs... " on line 36 and "... condition of SSCs..." on
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Line 38 should both refer specifically to systems, structures and components (SSCs) within the scope i
of the Maintenance Rule.
L 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. Therefore, Paragraphs 02.01, 02.02 and 02.03 should be implemented only if performance criteria established under 10 CFR 50.65 are not being met.
i Pane 1. Paracraph 02.02.a. Line 45 Pane 2 Line 13 The draft Inspection Procedure appears to assume that there w;11 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, i.e., Rule Paragraph (a)(1). The potential for there being no SSCs in (a)(1) needs to be addressed in this section.
l Pace 3. XXXXT 03, Line 8 i
j The NUMARC concept of " performance criteria" versus " goals" is not mentioned until Section 03.02.b (page 7, line 49). The general guidance section should mention this concept. Site experience to date indicates that awareness of the concept cannot be overemphasized.
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Pane 3. XXXXX-03, Line 12 N
Regulatory Guide 1.160," Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"is cited as the guidance that will be used when the utility proposes an alternate method for complying with specified portions of the Maintenance Rule and for compliance with 10 CFR 50.63, the Station Blackout Rule. Almost all industry effort to date has been placed on ensuring that maintenance programs meet the expectations of NUMARC 93-01. However, the inspection procedure is based on ensuring.that licensees meet the intent of the regulatory guide.
Even though Regulatory Guide 1.160 endorses NUMARC 93-01, there are some areas where the Regulatory Guide 1.160 specifically differs from NUMARC 93-01. Therefore, a licensee could develop a program that fully l
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A'ITACIIMENT (1)
DRAIT MAINTENANCE RULE INSPECTION GUIDE BALTIMORE GAS & ELECTRIC COMPANY's COMMENTS i
meets NUMARC 93 01 but does not meet the inspection procedure. We recommend that the NRC q
review and revise the regulatory guide and inspection procedure to ensure that a licensee could base their maintenance program on NUMARC 93-01 and be confident that they were meeting the intent i
of the regulatory guide and the inspection procedure.
e Pane 4. Paragraph XXXXX 03. Lines 36 46
}j Reference to the visual inspection as a measure of maintenance effectiveness deviates from the performance-based methodology proposed by the Maintenance Rule for establishing maintenance effectiveness, does not restrict the inspector to in-scope SSCs, brings the determination of maintenance effectiveness to the components level rather than the SSC level, and can result in the i
decision to perform further reviews being subjective. This section should be deleted from the draft Inspection Procedure.
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Pane 5. Paragraph 03.02.a. Line 2 i
Revise "... monitor the performance or condition for all SSCs... " to "... monitor the performance or condition for those SSCs... " in order to eliminate confusion.
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Pace 5. Paranraph 03.23.a.1(a). Lines 18 20 i
Reference to " preventive maintenance program results" is taken out of context from NUMARC 93-01 and should be deleted.
Pane 5. Parseraph 03.02.a.1(a). Lines 26 32 Depending on the method used, the inspector may or may not be able to "use the licensee's own j
criteria" to determine if the licensee has identified those SSCs that are risk-significant. The inspector i
should evaluate the methodology used, review the resultant risk-significant SSCs and verify that the methodology was properly implemented.
De phase, "... commensurate with their importance to plant risk," implies varying degrees of risk.
The risk-significant methodologies do not result in an overall ranking or prioritization of risk l-significance. Reference to varying degrees of risk should be deleted.
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Pane 5. Paragraph 03.02.1.1(b). Lines 34 57 i'
He examples provided should be revised to use the terms, " risk significant" and "not risk significant,"
instead of, "more risk significant" and "less risk significant." Regulatory Guide 1.160 should be revised to use the same terminology. The industry understands this graded approach (risk significant, i
and not risk significant) and believes that it is a positive step. However, the wording proposed in the draft Inspection Procedure ("more and less risk significant") might lead us away from the graded j
approach to a more prescriptive one.
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Y ATTACHMENT (1)
DRAFT MAINTENANCE RULE INSPECTION GUIDE BALTIMORE GAS & ELECTRIC COMPANY's COMMENTS 1.
1 Pane 7. Paranraph 03.02.a.2(b). Lines 211 The wording should be revised to be more consistent with Section 9.4 of NUMARC 93-01.
e Pane 7. Paranraph 03.02.a.3. Lines 15-17 Revise "... 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."
Pane 8. Paranraph 03.02.b.1(a). Lines 1-2 l
This section should be revised to indicate that performance criteria can be established at a higher level than system or train, e.g., plant or a group of systems by standby systems that are not risk significant. The performance criteria established must effectively monitor the performance of the.
- systems.
Pane 8. Paragraph 03.02.b.1(b). Lines 1017 The definition of Maintenance Preventable Functional Failure (MPFF) and repetitive MPFF is highly subjective. This section of the draft Inspection Procedure should require the inspector to evaluate the licensee's methodology for making MPFF and repetitive MPFF determinations. This l
section should refer the inspector to the Rule, Regulatory Guide, NUMARC 93-01 and NUMARC workshop questions and answers for additional information regarding the acceptability of the licensee's methodology.
Page 8. Paranraph 03.02.b.1(c). Lines 19 27 The wording related to repetitive MPFFs is not consistent within this section. Lines 19 to 27 should be deleted, leaving the remainder of the section to reference NUMARC 93-01, Section 9.4.4.
Pane 8. Paranraph 03.02.b.1(c). Line 33 Revise " single MPFF" to "second MPFF" to be consistent with lines 35 and 36.
Pane 8. Paragraph 03.02.b.1(c). Line 35-36 This section should be revised to indicate the 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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t ATTACilMENT (1)
DRAIT MAINTENANCE RULE INSPECTION GUIDE BALTIMORE GAS & ELECTRIC COMPANY's COMMENTS Pane 9. Paranraph 03.02.b. Line 10 s
The term maintenance preventable failure used in this line and others should be revised to maintenance preventable functional failure to be consistent with Regulatory Guide 1.160 and NUMARC 93-01.
Pane 9. Paranraph 03.02.b.2(a). Lines 37 38 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.
Pane 9. Paranraph 03.02.b.2(b). L.ine 45 De term low risk significance, used in this line and others, should be revised to be consistent with NUMARC 93-01 terminology. ~ In this case, low risk significance applies to SSCs that are not risk significant.
Pane 10. Paranraph 03.02.c.1(b). Lines 31 33 This section should be revised to state that if unavailability is the performance criterion and perforaiance is judged to be acceptable, then the system / train can remain m Paragraph (a)(2).
Pane 11. Paranraph 03.02.c.3. 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 revised 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 licensee's methodology.
Pane 13. Paranraph 03.02.d.3. Lines 611 '
This section provides guidance for the inspector to evaluate a sample of non-safety-related SSCs that are included in the Emergency Operating Procedures (EOPs). His section should be revised to require the inspector to review the licensee's methodology to determine if specific SSCs in EOPs are in the scope of the rule. The methodology provides the justification for the exclusion of SSCs that are not within the scope of the rule.
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A1TACIIMENT (1)
DRAFI' MAINTENANCE RULE INSPECTION GUIDE BALTIMORE GAS & ELECTRIC COMPANYs COMMENTS Pane 14. Paranraph 03.02.d.5, Line 1 This section should be revised to be consistent with NUMARC 93 01, indicating that only those non-safety-related SSCs whose failure has caused a reactor scram or safety system actuation should be v
included in the scope of the Rule. This section currently requires SSCs that could cause a scram to be included.
Pace 14, Paranraph 03.02.d.6, Lines 30 32
'Illis section provides guidance related to the exclusion of SSCs from the scope of the Rule based on their aircady 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.
Pace 17. Parneraph 03.03.e. 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.
The followine comment applies to the paces in the inspection procedure listed below.
The industry-wide operating experience program is an ongoing requirement where action is taken as individual events or trends are identified to the utilities. The draft Inspection Procedure should be revised to reference existing NRC Inspection Procedures for evaluating industry operating l
cxperience programs instead of providing new guidance.
I Page 1, Paragraph 02.02.a, Line 45, Page 2, Line 13 Page 2, Paragraph 02.02.c.1, Lines 35 36 Page 3, Paragraph XXXXX-03, Lines 35 37 Page 6, Paragraph 03.02.a.2(b), Lines 5155 Page 7 Paragraph 03.02.a.2(b), Lines 211 Page 10, Paragraph 03.02.c.1(c), Lines 45 55 Page 13, Footnote, Lines 46-53
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