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.#.g*t.MUC&g#g UNITED STATES NUCLEAR REGULATORY COMMISSION n
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- ,I w AsHINGToN. D.C. 205S5
%.....yY Novem1-10,-1988 orectorTws secasTAny l
MEMORANDUM FOR:
Victor Stallo, Jr.
m Executive Director for' dgations FROM:
Samuel J. Chilk, Secr
SUBJECT:
STAFF REQUIREMENTS - S.88-277 - AMENDMENT TO 10. CFR 50 REIATED.
NUCLEAR POWER PIANTS INTENANCE OF This is to advise you that the Commission (with Chairman Zach and Ccamissioners Carr and Rogers' approving, Commissioner Roberts
' disapproving,~and Commissioner Curtiss not participating) has approved publication in the Federal Register'of the proposed rule for public comments, subject to the updates transmitted in your memorandum dated October 13, 1988, and the following comments and changes.
I.
In regard to the rederal Register Notice:
1.
The Federal Register should solicit public comments on i
the following:
a.
The Commission believes that-the proposed 1
maintenance rule should be considered under 10 CFR 50.109 (a) (4) of the backfit rule which would J
exempt the maintenance rule from backfit requirements based on the' precepts that effective maintenance is necessary to assure adequate public protection and that the proposed rule codifies and standardizes previously existing Commission requirements, both explicit and implicit, in plant technical specifications, licensee safety analysis reports, and.10 CFR 50, Appendix B.
The Commission requests public comment concerning the need for a backfit analysis for this rulemaking.
b.
The Commission believes that the inclusion or balance of plant (BOP) equipment in the proposed maintenance rule is'necessary and proper._
However,'the Commission also recognizes that some licensee maintenance programs,.as presently configured, apply to structures, systems, and components that are, without question, irrelevant to protection of public health and safety from radiological hazards associated with the operation of the nuclear power plant.
The Commission 9408170103 940629 PDR CDMMS NRCC CDRRESPONDENCE PDR
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! I requests public comment concerning what i
' limitation, if any, should be placed on the final i
maintenance rule to provide some licensee flexibility in this regard.
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c.
The Commission desires to establish criteria l
within the maintenance rule which would form the i
basis for determining when~a maintenance program is fully effective and additional improvement is not warranted from a safety standpoint.
Such criteria might be either quantitative or
. qualitative and could be based on specific measurable attributes, on'overall plant performance, on program results, or on other i
attributes.
The Commission requests public comment concerning the need for such criteria,.the form of_such criteria, and the. criteria themselves.
d.
The Commission believes that individual worker accountability plays an important role in an effective maintenance program.
The Commission is therefore soliciting comments on the means for incorporating this consideration into a licensee's maintenance program.
e.
The Commission plans to issue by November 1989, a Regulatory Guide establishing standards and criteria for determining what' constitutes an effective maintenance program.
This Regulatory Guide is being developed in parallel with the I
final rulemaking.
The Commission encourages the J
industry to establish its own standards and i
acceptance criteria.
If an acceptable industry standard is available in this time frame, the i
commission will consider endorsing the industry standard in the Regulatory Guide.
An industry commitment to develop a maintenance standard, consistent with the Commission's schedule to issue a final Regulatory Guide by November 1989, would be necessary during this public comment' period.
f.
Commissioner Roberts had the following views:
"I cannot join the majority in supporting the proposed rulemaking on maintenance.
In order to have the benefit of the public's comments, it has been my custom to agree to publication of proposed rulemakings.
I cannot do so in this instance.
I have asked one fundamental question.
What are we trying to accomplish with this rule that cannot more effectively and innovatively be accomplished without a regulation?
I have not received a
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satisfactory answer. I do not believe the case ha:
j been made that, licensees do.not have established maintenance programs.
Most importantly to'me, there has been no demonstration that this rule would improve implementation of existing programs.
Neither have I been provided with compelling documentation on what the problem is and how, i
specifically, this-rule will-fix it.
On the contrary, the trendt staff has provided show f
continued improvement in the maintenance area.
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The proposed rule the Commission is now publishing
' fails-to. provide a basis for determining when a i
maintenance program is effective or when improvements are " appropriate."
We are even j
delaying publication of the accompanying Regulatory Guide _until the final rule.
Without being afforded the opportunity.to review this innlementatiSD document, the Commission'is left in j
the position of approving a specious rule. It is j
no wonder that this rulemaking would elicit such j
widespread opposition.
The public is being ask to comment on a rule of form but no substance.
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believe it would be more productive to delay i
issuance of this proposed rule until the draft regulatory guide is available for comment.
Only then can we receive meaningful comments on the i
rulemaking package.
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I am concerned that this rule goes beyond our j
authority.
I can not agree with a rule that would have the NRC regulating maintenance on all j
systems, structures and components regardless of i
whether they have a nexus to radiological safety or not.
I am troubled-by the attitude i
demonstrated when we request public comments on what-limitations, if any, should be placed on the i{
final rule to address structures, systems and components that are "without auestion irrelevant l
(my-emphasis) to the protection.of public-health and safety."
This clearly abdicates our responsibility to show that a regulation is needed.
We must ask ourselves: are we proceeding j
with this rulemaking for the sake of the rule itself?
As attested to by the cases where the Commission cited licensees, the NRC already has the authority to enforce compliance in the maintenance area.
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The arguments advanced by both the staff and the Commission in trying to comply with the requirements of the backfit rule have played a i
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significant role in my decision not to support j
the rule's compliance with 50.109 has been made on I
this proposed rulemaking.
The staff argument for the basis of cost.
Sme staff states that the 4
l backfit analysis shows that_"...the rule will j
provide a substantial' increase in the protection i
j of the public health and safety without any l
additional cost."
I am skeptical of the 4
assumptions made in the backfit and regulatory j
analysis and request comments on both these.
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I also request comments on the views of'the ACRS.
They state that "...there are l
characteristics of regulations, and especially the i
way in which they are typically enforced, that lead us to believe that, under a rule, a move i
'toward' uniformity would occur,-and this.is likely 1
to decrease the effectiveness of some of the j
better existing-programs."
I share their concern i
that the existence of this rule could make things l
worse and diminish rather than enhance the
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protection of the public.
1 Regarding " adequate protection," the Commission j
appears to be saying that since effective a
maintenance is necessary to maintain adequate i
protection, this rule should be excepted under i
50.109 (a) (4 ).
This exemption would prohibit staff from taking implementation costs into consideration.
l However, it would require that a documented t
evaluation be prepared for public comment.
l Therefore my opposition to the exception is.not to the exception itself but to the precedential e
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nature of the use of the adequate protection argument.
Let me state that I too strongly_
i believe that effective maintenance is necessary to j
assure that nuclear power plants are safe and to l
i provide adequate protection to the public.
I also i
believe, just as strongly, that this rule is not necessary to nrovide that nrotection, and that as the ACRS noted it may well have the opposite 3
j effect.
I believe that we can not afford to be i
careless about the use'of the-" adequate.
i protection" argument for exception to the backfit i
rule.
The Commission is in litigation about_this very issue.
The Commission addressed this point 1
in detail under the heading " Adequate Protection" j
in the Resnonse to' Comments on the final 10 CFR l
Part 50 Revision of Backfit Process for Power Reactors.
Let us remember that there had been i
concerns that in dealing with the backfit rule, j
the Commission would use the phrase " adequate protection" arbitrarily.
The commission could j
unwittingly be giving credence to that view.
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. Additionally, it seems to me that the Commission position as stated in the above comment 1.a is internally inconsistent.
The Commission needs to recognize that when it states that this rule is needed to maintain adequate protection, it is saying that the current operating plants _now pose t
undue risk to the public which we are presently tolerating.
If I believed that, I would suggest (as I'm sure would the rest of the Commission) that this rule.become immediately effective.
This is clearly not the case.
As the Commission in the very same comment shows,
"...the proposed rule codifies and standardizes nreviousiv existina (my emphasis) Commission requirements, both explicit and implicit, in plant technical specifications, licensee safety analysis reports, and-10 CFR 50, Appendix B."
It seems to-me that the Commission can't have it both ways.
I request comments on my_ views."
2.
The attached revised cost table (Attachment-1) as well as the accompanying narrative should be incorporated in the draft Regulatory Analysis.-
3.
The editorial changes and additions described in should be incorporated into the Federal l
Register Notice.
(EDO)
(SECY Suspense:
11/18/88)
II.
The staff is to continue, on an integrated.and high priority l
basis, its effort to develop a final Regulatory Guide on Maintenance of Nuclear Power Plants by November 1989.
The final rulemaking package is due to the Commission by April 21, 1989.
The final rule is to be accompanied by a draft Regulatory Guide or industry plan, standards and acceptance criteria, even in preliminary form, and schedule for developing complementary standards for maintenance which the Commission would consider endorsing in the final' Regulatory i
Guide.
The industry schedule must be consistent with the plan to issue the final Regulatory Gaide in November 1989.
The Commission intendu to postpone the effectiveness of the final rule pending publication of the final Regulatory Guide and a reasonable period for licensees to establish compliance with this rule.
(EDO) (Final Rule and Draft Reg Guide, l
SECY Suspense:
4/21/89 PRIORITY) i (EDO) (Final Reg Guide, SECY Suspense: 11/89 PRIORITY) e--
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t Additional Commissioner comments are incorporated in their vote sheets (Attachment-3)..
Attachments:
As stated c
cc: ' Chairman Zach' fCommissioner Roberts Commissioner Carr Commissioner Rogers-Commissioner Curtiss OGC GPA l
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I ATTACHMENT-1 REVISED COST TABLE i.
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Telet Indoctry Coote Over 30 Yeers for All Pleene (1984 Preeeen Worth le Willione of 1990 Dellere)
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i tedestry Cost Element Neleteesees Ploe 5
4 8.9 8
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S.9 Recordbeeptog and Reportlee 20 98 ISS M
M 100 ledestry Stendeed 1.0 9.8 3.7 Reg. telde Wethebope 0.3 0.4 0.8 0.1 0.4 0.0 0.1 0.4 0.0 0.1 0.4 0.'s leptement leproveeente (At Seee Ploete)
Preventive seletenence See 1500 4800 300 1800 4600 900 1600 4600 900 1800 4800 Belet..Spe. Coord 1
2.1 10.4 3
2.1 10.4 3
f.1 10.4 1
f.1 30.4 Melet. Info. Bretee 80 ISO 900 69 ISO 800 50 lle See se 1st See beleteleo6ility 0
0 et 0
0 It 0
0 et-0 0
et Procedores 8
14 08 8
14 04 5
14 St 8
14 se Imeressed Stefflet 40 SS OS 40 50 00 40 80 00 40 50 80 to Rodoee Overtlee Redeced Riete of Desite Property Deeece
-99
-88
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-99
-88
-20
-89
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-20
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-te Cost Seelege Dee Le leproved Avellobility sed Bedeced terrective teleteessee
-2900 -1990 -1500
-2900 -itte -1800
-9900 -1990 -1500
-2900 -1900 g Total get ledestry Coote -1998
-118 Stet 1988
-118 3909
-1999
-Ils 3406
-1991
-fl0 3001 Betes:
1.
Negetive signe denote cost eevince.
2.
Telees le table are reended.
8.
The eeloose lebeled 'O' coetele the beoe toee eetlestoe.
'L' desetes the lever eetlestos eed 'N' donetoe the opper eetlestes.
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I Ranoes for the Cost Estinatas in Chapter 5 pNL has been asked to provide ranges for the cost estimates in Chapter 5 of the maintenance regulatory analysis. This note discusses each of the major cost elements in Chapter 5 and presents upper and lower estimates for each.
A summary table, corresponding to Tables 3.1 and 5.1 in the regulatory analysis, is also provided.
The ranges are intended to give some indication of the sensitivity of the j
cost estimates to variations in some of the major assumptions. It should be stressed that the ranges are not statistical confidence interval, u d should not be interpreted as such.
There are two basic uncertainties in the' regulatory analysis that dominate all the others. Both were explicitly discussed in the regulatory analysis.
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First, the number of plants that will require substantial maintenance tuprovements is not precisely known. Both the costs and benefits can be strongly related to this factor. Industry asserts that the maintenance inttiatives undertaken in recent years have resulted in major is :. ments and that now there are very few plants with weak maintenance. NRC asserts that a significant number of plants still need substantial taprovement. Neither NRC nor industry has a good, up-to-date, quantitative basis for estimating this number with precision. The best-documented basis is still NUREG-1212, which was published more than 2 years ago. The regulatory analysis relied i
heavily on NUREG-1212.
Second, the taprovements that plants will be required to make are not precisely defined. The standard that plants will have to meet has not yet been written. And even if the standard already existed, the costs would be sensitive to how it was interpreted and tuplemented. Therefore, any estimate of costs to cogly with the standard must be highly uncertain at this time.
Maintenance Plan Development Costs As an upper estimate, it is assumed that the more substantial effort discussed in Chapter 5 (6 staff-months per plant, or $54,000) applies to all 110 plants, for a total cost of $5.9 million. As a lower estimate, the smaller level of effort (3 staff-months per plant, or $27,000) is assumed to apply at all 110 plants, for a total cost of $3 million. The base case assumed a 1:2 mixture of these two levels of effort, for a total cost of $4 million.
Recordkeeping and Reportino Costs i
The base case estimate was $98 million. The dominant factor was the assumption that the average plant would need to devote an additional 1820 staff-hours per year to data collection, data entry, and report generati6n. (This consisted of 1/2 staff-year, or 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />, of professional labor for data collection at $54 per hour,1/4 staff year, or 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />, for a data-entry technician at $31 per hour, and 8 staff-weeks or 320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br /> of professional labor for reporting). This added up to $86,800 per plant per year; when summed over all plants and over 30 years, this element accounted for $90 million of the total recordkeeping and reporting cost of $98 million. In developing a f
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x range for recordkeeping and reporting costs, it is sufficient to focus on N
the dominant $90 million estimate.
l This estimate could vary depending or. the extent of existing in-plant data collection activities. If it is assumed that the average plant already collects the necessary data and stores it in a readily retrievable fors, the j
only incremental cost would be the cost of producing the reports, or 320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br /> i
per year times $54 per hour. This amounts to $17.360 per plant per year.
Summed over 110 plants and 30 years of remaining plant life, the total is $17.9 million, as compared to the base case of $90 stilion. Thus the total i
l recordkeeping and reporting cost estimate would be roughly $26 million insteaa of $98 million. This is an optimistic lower bound; many plants do not currently i
collect all of the information needed for the postulated maintenance performance indicators.
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As an upper estimate, it is assumed that the average per-plant labor for collecting performance indicator data, entering it into a data base, and generating reports is twice as high as the base case. This assumption results j
in a total recordkeeping and reporting cost of $188 million, f
Industry Standani Develooment Costs i
The regulatory analysis provided a range of $1.76 million to $3.73 million j
for this cost element, with a nominal (base case) value of $2.75 million.
6 Reculatory Guide Develoosent Costs
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In the base case, it was assumed that 2 workshops would be held to obtain industry input on the development of the Regulatory Guide, and that two staff 1
members would attend from each plant. As a lower estimate, a single workshop j
attended by only one person per plant may be assumed, whfch would reduce the i
estimated cost by a factor of 4, to $95,000. As an upper estimate, it may be assumed that a third workshop might be needed, which would increase the base case cost by 50% to $570,000.
Costs to Isolement Needed Maintenance Iserovements
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Before presenting ranges for the costs of each of the postulated i
maintenance improvements, it is worth stressing that the principal source of uncertainty is not in the individual cost elements identified under this
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heading. Rather, as stated in the regulatory analysis, the more basic issue i
is to determine what improvements will be required:'
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"It is difficult to estimate with any precision the specific actions that each plant will have to take to tuprove its maintenance program 4
based on the rule. There are two principal reasons for this. First.
l available data on plant-speciffe maintenance programs and practices are 1 tatted. Second, at this early stage in the maintenance rulemaking process, there is not yet a clear, detailed definition of what constitutes l
an effective maintenance program."
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_ Preventive Maintenance The base case estimate was founded on essentfally two factors
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- 1. Roughly 25% of the 110 plants would have to implement exten of their preventive maintenance programs.
from information in HUREG-1212.
This estimate was derived e upgrades
- 2. The average cost of the upgrade would be $56 million j
mainly on the Sales experience.
This was based As a lower estimate, it may be argued that industry initiative two to three years have already addressed the issues discussed i s in the last so that only a handful (perhaps 5%) of plants w n NUREG-1212 improvement.
will be used as the lowe,r estimate.
mate lead to ratcheting and that a larga* number of plants w i
rule will substantial taprovements eed to make adequate or extensive pre,ventive mali,teneven thost that were judged in NUREG-1212 t might not be affected would be those ' ance programs.
The only plants that the one at Sales. If it is assumed t significantly affected, the base case.e '5% of the plants would be* a ast, ~v let be tripled.
Maintenance-Operations Coonif'iation the maintenance-operations interface by forinally assi 1212 had found that 13% of the plants had no pos o strengthen v ual. NUREG-The additional effort was assumed to be 400 staff-hours pe s responstbflity.
roughly one day a week.
initiatives since the publication of NUREG-1212 have addresAs a r year, which is and that only a handf effort in this area. ul of plants (i.e., 5) will still need to devote addltional sed this issue, reduced by a factor of 2 to roughly $1 million.Thus, the base case estim hours a year is not sufficient to achieve the necess 10 plants.
or 400 staff-It might be necessary to assign a person full-time to this ements at the responsibility, i.e., 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> a cost estimate by a factor of 5 to $ year, which would increase the base case 10.4 at11 ton.
Maintenance Information Systems For the base case it was assumed that 25% of the plants would upgrade portions of their maintenance information systems to provid need to capabilities for trending of equipment reifability.
affected plant to acquire additional hardware an enhanced The initial cost per as $250,000
$540,000 mated which assumed 5 people full time.
over 30 y, ears and discounting to present value at a 10% rea e as the operating costs per affected plant were about $51 milli n rate, on and the total
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cost including the additional hardware and training was $5.3 million per affected plant. For all affected plants, the total estimated cost was $147 i
million.
l As a lower estimate, it will be assumed that only los rather than 255 of j
the plants alght incur such costs, which would reduce the estimate by a factor i
of 2.5. The resulting estimate is about $5g million.
3 As an upper estimate, it may be argued that all plants should have i
j sophisticated equipment re11abt11ty trending capabilities. If 251 of the i
j plants already have such capabilities and another 251 will acq)uire them throug their preventive maintenance upgrades (as discussed separately, then the j
i remaining 50s of the plants would st111 need upgrades and should be included 2
in this cost estimate. This would increase the cost by a factor of two. If in addition, the average cost of the upgrade were doubled to allow for more,
extensive computer equipment and more staff, another factor of two increase i
in the costs would result. Thus, the upper estimate will be taken as $600 j
sillion, or four times the base case.
Maintainability j
For the base case, it was assumed that the rule would not utre any maintainability improvements. To provide some perspective on the saintainability issue, the regulatory analysis discussed a hypothetical maintainability improvement effort and estimated its cost as about $82 million.
1 This can be used as an upper estimate, although it should be reco maintainability improvements costs could be significantly higher,gnized that depending j
on how extensive the requirements were.
j Soare Parts The regulatory analysis discussed the possible need for computerized spare parts management, and estimated that the few plants that needed i
taprovement in this area would combine this upgrade with the preventive maintenance upgrade discussed separately. Therefore,.the incremental cost under this heading would be zero. As an upper estimate, one could argue that a few plants would need to implement computerized spare parts management.
However, the costs should still be negligible compared to other cost categories.
Therefore, no upper estimate is given for this cost element.
j Procedures It was assumed that 5 plants would need to extensively overhaul their maintenance procedures at a cost of $2.7 million per plant, for a total cost of $13.5 million. As an upper estimate, the number of affected plants might be significantly larger, perhaps by a factor of 5 (i.e.,- 25 plants). The j
total cost would then be $67.5 million.
As a lower estimate, it any be argued that industry initiatives have
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reduced the number of plants needing procedures upgrades to 2, rather than
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the 5 assumed in the base case. The total cost would then be roughly $5.4 sillion.
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Staffine to Reduce Overtime l
The regulatory analysis provided a range of $40 million to $60 million, with $50 million as :he nominal or base case estimate.
Reduced Risks of Onsite Prooerty Damage The regulatory analysis estimated a range of $26 million to $39 million.
133 million was used as the base case.
Cost Savinos Due to Improved Availability The base case estimate assumed that 20 to 30 affected plants (with substantial room for improvements in maintenance) would achieve a 5 percentage point igrovement in capacity factor. This resulted in cost savings ranging from $1.5 billion to $2.3 billion. The mid-point of the range, $1.9 billion, was used as the base case.
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EDITORIAL AND ADDITIONS I
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[7590-01]
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NUCLEAR REGULATORY CWOU5510N l
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Ensuring the Effectiveness of Maintenance Programs for Nuclear Power Plaats I
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l AGENCY:
Nuclear Regulatory Commission.
3:
j' ACTION:
Propose 6 Rele.
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SUMARY: The Commission is proposing to asend its regulations to require
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commercial nuclear power plant licensees to st e ngthen their maintenance c#,
I activities in order to reduce the likelihood of failures and events caused by the lack of effective' maintenance. The commission believes safet M M
,i be enhanced by defining an adequate maintenance program to ensure the l
effectiveness of such programs throughout the nuclear. industry. The proposed i
j rule requires plant maintenance programs to inc1sde specific activities, l
including the monitoring of the effectiveness of plant maintenance programs.
1 DATE: Comment period expires [ insert a date 2 months after the date of j
publication]. Comments received after this date will be considered if it
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is practical to do so, but assurance of consideration cannot be given i
except as to comments received on or before this date.
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ADDRESSES: Mail written comments to: Secutary, U.S. Nuclear Rpgulatory 4
cosmrission,11155 Rockville Pike, Rockville. MD 20852, Attent, ion: Docketing 1
and Service Branch.
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Deliver comments to: 11155 Rockv11e Pike, Rockville, MD 20852 l
between 7:30 an and 4:15 pm weekdays.
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[7590-01) i f
Copies of the paper on rulemaking options, transcript and proceedings
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4 of' the Public Workshop, draf t NUREG report,' draft regulatory analysis, environmental assessment and finding of no significant impact, the supporting j
statement submitted to OMB, and comments received may be examined at: the l
NRC Public Document. Room, 2120 L Street, Lower Level, N.W., Washington, D.C.
20037.
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FOR FURTNER INFORMATION CONTACT: Moni Day, Office of Nuclear Regulatory l
Research, U.S. Nuclear Regulatory Cosmission Washington, D.C.
- 20555, I
(301)492-3730.
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$UPPLEMENTARY INFORMATION:
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BACKGROUND
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On March 23, 1988, the Commission published a final Policy Statenent
.I on Maintenance of Nuclear Power Plants. In the Policy Statement, the
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Commission stated that it expected to publish a Notice of Proposed l
Rulemaking in the near future and provided the general framework for the j
proposed rule, i
I The Commission has a program to continually evaluate the operational j
performance of nuclear power plants. Analysis of operational events has shown that, in some cases, nuclear power plant equipment is not being maintained at a level to ensure that the equipment will perform, with a high degree of reliability, its intended function when required. A limited NRC examination of nuclear power plant maintenance programs has found a wide variation 1e tbs effectiveness of these programs. At some plants, maintenance has been a signf Htant contributor to plant reliability pglessandhence,isofsafetyconcern. The Commission believes safety
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y Cn enhanced by strengthening the effectiveness of maintenance programs throughout the nuclear industry and this is the objective of this propn4d rule.
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[7590-01) i husa.
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DESCRIPTION i
It is the objective of the Commission hat all components, systems J
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and stuctures of nuclear power plants bq effectively maintained so that plant equipment will perform its intend Ifunction when required. The i
i scope of the proposed rule is' intended o cover all systems, structures l
and components including those in t
$.Toaccomplishthisobjective, i
the proposed rule would require each commercial nuclear power plant to develop and implemes.t a well-defined program to assure that maintenance I
activities are conducted to preserve or restore, with prompt repair, the l
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' lability, performance and reliability of plant structures, systems, 1
and components. The program should clearly define the components and l
l activities included, as well as the management systems used to control j
i those activities. Further, the program should include' feedback of. specific t
4 results to ensure corrective actions, provisions for overall program l
evaluation, and the identification of poisible component or system de' sign j
problems. Compliance with the rule would be verified by NRC audit ana I
trspection.
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The proposed rule does not require that licensbes I
report Maintenance Performanc ggrs (f]r Howev g ach licensee j
would be required to have his own, monitoring,apstem which would be subject to NRC review. The Commission solicits comments on the application and l
usefulness of MPIs as part of the rule, and whether a set of MPIs exists which could indicate the effectiveness ant ma epange egg 1,np l
addition, the Commission solicits feedback n who rThlse ^^ "
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pbBl.1C WORK $ HUP l
2 The Commission held a Public Workshop on July 11-13, 1988 in Washington, D.C. to solicit early input for th formulation of the rule j
from the pubite and regulated industry. Prior to the Workshop, a paper on rulemaking options was distributed to interested parties to facilitate 3
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[7590-01]
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Work. hop discussions. The paper on rulemaking options, and the j
. transcriptandproceedings(NUREG/CP-0099)2 of the Workshop are available for inspection in the NRC Public Document Roos., 2120 L Street, l
Lower Level, N.W., Washington, D.C.
20037 j
j As a result of Workshop discussions, the Commission has come to the following conclusions:
i 1.
Rulemaking should encourage industry initiatives directed toware improving maintenance, since such initiatives promote industry restonsibility for problem identification and resolution; f
2.
Prescriptive rulemaking options may impeda industry initiatives and responsibility to improve maintenance; and
~
3.
Rulemaking should be directed toward spec g the NRC's om expectations in maintenance anc requi nitoring of the 6:.ectiveness of maintenance programs.
Therefore, the Commission proposes a maintenan~ce rule which gives incentive for industry to develop a standard for a maintenance program, which NRC may encorse in a Regulatory Guioe.
I Memorandum from Victor Stallo, Jr., Executive Director for Operations, to the Commissichers, " Proposed Rulemaking for the Maintenance of Nuclear Power Plants," dated June 27, 1988..
2 Copies of NUREG series reports may be purchased through the U.S.
Government Printing Office by calling (202) 275-2060 or by writing to the U.S. Government Printing Office, P.O. Box 37082, Washington, D.C.
20013 7082 5 Copies may also be purchased from the National Technical Informati6n 5ervice, U.S. Department of Sommerce, 5285 Port Royal Road, Speistf.ield, VA 22161. A copy is available for inspection or copyi for a fee in the NRC Public Document Room, 2120 L Street, Lower Le t;M.W., Washington,D.C. 20037.
4 Enclnsure 1 s'gw
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[7590-01)
S EXPECTATIONS FOR MAINTENANCE STANDARD 4
l The Commission encourages industry to develop a Maintenance Standard which will provide guidance for complying with requirements of the proposed j
i I
The Commissicn J.11 eves that the developsont of a standard will guide rule.
current industry initiatives towards developing and implementing acceptable j
i maintenance programs, and that utility participation in preparation of a j
Maintenance Standard will provide additional incentive ano responsibility for l
improving plant maintenance programs.
}
l The Commission f.
. to develop a Regulatory Guide to, provide guidance for complying with the rule if industry does not develop an adequate standard.
1 However, the Commission prefers to endorse an industry 4eveloped,s ard.
j To meet the Commission's plans for implementation of the rule tha,commihnt j
l to develop a Maintenance Standard should be made now and a final standard i
should be proposed ho later than Septesber 1, 198g. The Commission e'apacts to publish a Regulatory Guide endorsing a Nintenance Standare or providing NRC guidance by April 1, 1990. The comprehensive program, requirements of 4
l the proposed rule would be required to be fully implemented within one I
year following publication of the Regulatory Guide *
)
)
The proposed rule defines those attributes the Commission considers necessary I
for an acceptable Maintenance Program. To be acceptable, any standard developed to implement the rule should have the following characteristics:
l i
l Should define the plant systems, structures and components j
includedinthemaintenanceprogram(thescopeofthetvle I
covers.all systems, structures and components including those l
inthe80P);
Should require a ;;stematic evaluation (" systems approach") of j
i; the functions t.
.hjectivt, of plant systems, components and structures to d c5:uine maintenance activities and requirements; i
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Should provide clear and specific prograsumtic requirements that can be l
practically implemented to achieve high reliability; g
Should be comprehensive in addressing the activities and functions included in the proposed rule plus provisions for self assessment; l
i, l
Should reference standard: or guidelines such as those developed by ANS, i
ASME, IEEE, ASTM, INp0, or EPRI where pr:ctical to provide (a) specific j
l_
programmatic requirements or (b) guidance for maintenance of specific typ f
of equipment; Should allow flexibility for adoption of new innovative technologies a 1
j i
are validated; and 4
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Should provide for sufficient documenta, tion so that program effectivenes:
and compliance with requirements of the standard can be evaluated.
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TMSER.T p As noted above, an integral part of a good maintenance program is the monitor f
and fact.back of results. Programs should utilize quantitative measures to monitor and adjust the maintes. ace program activities., Measures that are bas j
j upon actual component reliability and failure history' provide useful indicati j#p' of maintenance effectiveness. Such measures need a well structured and compo i
Th f
hD oriented system; e.g}$PR05)to capture and track equipment history data.
Commission notes and encourages the use of the industry-wide NPROS for this f
purpose in view of the multiple uses for this data.
3 j
In addition, the Cosnission has conducted studies to review effective mainten l
j approaches and practices in other countries and industries and has documented findings in a draft NUREG series eeport. I The Commission seeks comments on j
draft NURES report which may be. sotaitted to the NRC as indicated under the
'j ADDRESSES heading.
A free single copy of draft NUREG-1333, ' Maintenance Approaches and Practice:
3 5 elected Foreign Nuclear Power Programs a55 Other U.S. Industries: Rsview ani i
{
Lessons Learned.' to the extent of supply, may t'e obtained by writing to the Distribution Services Section, Document Control Branch Division of Support
{
Services, U.S. Nuclear Regulatory Crunission, Washington, D.C. 20555. A cop.
i also available for inspection or copying for a fee in the NRC Public Documen j
Room, 2120 L Street, Lower Level, NW., Washington, D.C. 20037,
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should provide clear and specific j
programmatic requirements that can be practically tuplemented to achieve high 1
l reliabilityr l
1 o
Should be comprehensive in aMressing the d
activities and functions included in the i
1 proposed rule plus provisions for self assessmenti s
o should reference standarde er cuidelines such j
as ^ hose developed by ANS, ASME, IEEE, AST4, l
INPO, or EPRI where practical to provida (a) 1 4
specific programmatic requirements or (b) i guidance for maintenance of specific types of 2
j equipment; j
o should allow flexibility for adoption of new j
innovative technologies as they are f
validated; and i
J l
o Should provide for sufficient documentation i
so that program effectiveness and compliance i
4 with requirements of the standard can be 1
i I45s;p,,i-evaluated.
1
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The Commission has oenducted studies to review effective 1
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maintenance approaches mad practions la other constries and Y
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l industries and,has documented the findings in a draft MUmse i
I series report.3 The Commission seeks coassents on the draft NURES
(
report which may to submitted to the NRC as indicated under the tl8
,i ADDRESSES headtsp.
x.
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As noted above, am, integral part of a good maintenance program is the monitoring sad feedback of results. Tzograms should utilise t
j quantitative measures to monitor and adjust the maiatoaanse i
f I
program activities.
Measures that are based upon astual i
component reliability and failure history provide use,ful dl-i i
indication of maintenance effectiveness.
Such measures need a l
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well structured anS component oriented sp tem; e.g., NPRDS to g
i oapture and track equipment history data. The Commission notes l
and encourages the use of the indust:7-wide NPRDS for thfa 1
i purpose in view of the multiple uses for this data.
1 The commission views maintenance rulemaking as an opportunity to encourage (a) goes maintenance practices, tt) the adoption of common maintensame standards, and (e) the development of valid quantitative measures of effootiveness which could become the l
basis for regulation by outoomes rather thaa processes. The i
j 3A free single copy of draft NOREG-1333,
" Maintenance i
Approaches and Practices in Selected Foreign Nuclear Power Fryg.as j
and other C.S. Industriest Review and 1,essons Taarned," to tha j
extent of supply, may be obtained by we.iti.7 to the Distribution Sa' vices Section, Document Control Branch, Division of Support
{
- Services, U.S.
Nuclear Regulatory Commission, Washington, D.C.
20555.
A copy is also available for inspection or copying for a i
fee in the NRC Public Document T me, 2120 I. Street, Iower Level, i
NW., Washington, D. C. 20037.
- 6a -
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herein proposed rule addresses (a) and (b) but not (o).
Follow-on rulemaking is envisioned which would build on the bases i
established in this rule and would define those validated N,
measurable quantities or indicators that could oredibly booosse C
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l the basis for regulatory attention or action la the fat.ure
.t instead of the systems for maintenance establish 4 under (a) and Y
(b) of this proposed rule.
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[7690-01]
g, 166 The draft NUREG report concludes that following are practices in i
foreign count and other U.S.industr maintenance programs'which have been found to contribute significantly to effective maintenance:
i l
1.
Focus on long term maintenance objectives; establish a proactive l
maintenance progrts es opposed to reactive maintenance; 2.
Use of a reliability centered approach to maintenance, including consideration of the man-machine interface; I
~
3.
Collection and engineering evaluation of failure, data (root cause analysis);
4.
Use of an integrated information system for collecting data and monitoring the effectiveness of a maintenance program; 5.
Use of maintenance technician training / certification programs; I
6.
Derive planning and scheduling tron overall program objectives; 7.
Enhance environment / motivation of maintenance technicians (e.g.
thru cross-training, " Crew Chief" concept); and i
8.
Clearly define interfaces between maintenance and other activities (engineering support, operations QA, QC, corporate offices, safety review).
j The Commission encourages in the development of any Maintenance "Standare, l
consideration of the findings in the above references draft NUREG report i
and any other pertinent studie on tive maintenance practices.
The Commission also encourage (Ehe Maintenance Standa steer incorporating appropriate maintenance derived from plant aging stuates{
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CERTIFICATION OF PIANT MAINTENANCE PROGRAMS The commission wishes to encourage industry initiatives and l
responsibility for problem identification and resolution.
Therefore, as a further way of encouraging' industry participation l
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i and responsibility, the commission is willing to consider a process of utilizing a designated' third party to review and
~
j certify licensee maintenance programs for conformance with the i
1 Maintenance Standard. This process, if successful, could
}
j alleviate the need for detailed NRC inspection of all licensee i
d maintenance programs.
The commission solicits proposals for conducting such a certification procssa.
COMMENTS REQUESTED i
l In addition to comments on the content of this Notice of j
Proposed Rulemaking, the cosmission specifically solicits input 4
j on the following questions 1.
Is it appropriate for the nuclear power j
l industry to develop a Maintenance Standard i
l and, if so, would the industry develop such a i
Maintenance Standard?
l e
2.
What level of detail should be included in 1
the Maintaance Standard?
3.
Is two years a reasonable time to develop, i
j ar.d implement a standard?
f 4.
Is it appropriate for a designated thi M party to certify plant. maintenance. programs j
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to comply with the Maintenance standard; and, I
l if so, would an organization be willing to
.f perform such certification?
5.
Should an industry-wide component failure a
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reporting system, e.g., NMtDS,.be used by all
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plants in order to support the sharing of J
maintens ce generis :;--:tp ; experience and facilitate
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i monitoring of maintenance' effectiveness?
I i
j s.
Are performanoe indientors that are being gg used by industry, may be used in the futidro, l
or have been used in the past appropriate j
sandidates as quantitative measures of f
maintemanos effectiveness? The Commission is l
particularly interested in experiemos or l
analysis conoorning indicators or the use of j
indicators of componest reliability as
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maintenance performance indicators.
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IMPACT E'* b '*3"gatorg ***Oo*5 N*$
i The sea.ompaava3 l
@ The economic impact of the proposed requirement en licensees l
shouldbenegligible.jthoughinitialfinancialinvestments i
will be required by some licensees to establish a systematic and comprehensive maintenance program, the savings due to decreased corrective maintenance costs and increased plant availability j
ahculd outweigh the investment' coats. The commission requects j
cooperation of inftsruid sieurces in oro.1, tc. davsicp furthur
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details and verification of this analysis.
l
- pgs,,g L % Co~.ssoon losirauss faf n',k yrop***'I ru le os Lg vlrdue l
eq to cret so.co9 Cs)(+) not saQeet +,.gfe reguarsned q,, m back(.'t (..J.n3 sad aael s's," 8" ' It has neverikeless P'"fa"'"*
s o p co d s,.4. #.e hacif& fators as
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[7590-01) r.and comunents regarcing this burden estimate or any other
-. collection of information, including suggestions for
- surden, to the Records and Reports Management Branch, x.siornation Support Services /1RM, Office of Administration ard mnt, U.S. Nucisar Regulatory Ceausission, Washington, D.C.
- ne Office of.Information and Regulatory Affairs. Office of m Sudget, Washington, D.C. 20503.
REGULATORY ANALYSIS
.urssion has prepared a draft regulatory analysis on this
- ution. The analysis examines the costs and benefits of the 1
u sidered by the Commission. The draft analysis is
- nspection in the NRC Public Document Room, 2120 L St., N.W.
20037. Single copies of the draft analysi:; smey be e
zrnoni Dey, U.S. Nuclear Regulatory Casumission, Washington, C 2 ) 492-3730.
.urssion requests public consnent on the draft regulatory mts on the draf t analysis may be sube itted to the NRC as
- =mmr the ADDRESSES heading.
BACKFIT ANALYSIS 4
aufe d[d8FC
- ;,.0 OT" !O.*??, the Commission has completed a backfit h
- r== proposed rule. The Comunission has determined, based on m : hat backfitting to comply with the requirements of this mwill provide a substantial incr4ase in protection to public
.musuty without any additional costs. The backfit analysis on mmurnination is based is as follows:
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Analysis and Deterstnation That the Rulemaking to
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Amend 10CFR50 Concerning Maintenance Complies C +
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with Backfit Rule 10 CFR 50.109 Ik song F4 I
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The Commission's ex'isting regulations,do not'exolicitly address I
the requirements of a cr_;;i...'... M ef active maintenance program. The y
Commission believes that safety ca e en anced by isproving the 4
1 Mr effectiveness of maintenance programs throughout the nuclear industry.
f f
The proposed rule requires nuclear power plant' maintenance programs to l
,,(
have a set of functions and activities which the Commission believes are j-essential for a comprehensive and effective program.
i t
Y The findings and conclusions of the Commission's assessment of the
,t effectiveness of plant maintenaece programs can be found in NUREG-1212, l
T j
" Status of Maintenance in the U.S. Nuclear Power Industry." The study
{
I showed weaknesses at' plants in a ' number of areas of maintenance which the j
j g7 Commission believes is critical for an overall effective program.
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L Further, analysis of operational events has-shown that, in some cases, j
k e
r plant equipment is not being maintained with a high degree l
l L
of reliabi that the equipsont will perform its intended function when 0,
l [4 required. The objective of the proposed rule is to require improvements i
f 1
for those plants that are poorly maintained, and also to prevent the W & Im au.sg% h s
declining performance of plants that are well-maintained.Y d8=
- F = 8* % m W tie asw a M eess-s aderd a as been es%,e a f.o be in o
v reo.cr -
timated The benefit of improvements in mai nance l
the order of 250,000 person-res for the lifetime of all nuclear power j
plants. Common sense also suggests that a well-maintained plant. poses g,
1 j
less risk than one poorly maintained. The proposed rule will, help ensure ;
a satisfactory level of performance for maintenanc j
j those activities and practices which, through experience, have been shown {
to be key elements of effective maintenance programs, and should result in -
a substantial enhancement of public health and safety.
[
improvements in maintenance serve to meet dual objectives: (1) enhance safety; and also (2) increase piant availability and capacit) 11 Q
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issued muler Sec.184,' 68 Stat. 954, as amended (42 U.S.C. 2234).
f Section 50.103 also issued under Sec.108, 68 Stat. 939, as amended (4211.5.C. 2237).
I For the purposes of Sec. 223, 68 Stat. 958, as amended (42 U.S.C.
I i
2273),ll'50.10(a),'(b),and(c) 50.44, 50.46, 50.48 and 50.54 ana l
50.54(a) are issued'under Sec.161b, 68 Stat. 948, as amended (42 l
U.S.C. 2201(b)); il 50.10(b) and (c) and 50.54 are issued under Sec. 1611, 48, stat. 949, as amended (42 U.S.C. 2201(1)); and il 50.9, l
1 50.55(e). 50.59(b), 50.70, 50.71, 50.72, 50.73 and 50.78 are issued l
under Sec.161o, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
t-1 i
2.
A new i 50.65 is added to read as follows:
6 j
i 50.65 Requirements to ensure the effectiveness of l
maintenance progress for nuclear
- power olants'.
i 1
(a) Applicability. The requirements of this section, apply to all nuclear power reactors licensed under i 50.21 b or 50.22.
e l
Fo the purpose of this section,pthe j
(b) Deftaitions.
l defines maintenance as the aggregate of those{ actions required l
to peeserve and promptly restore operability, reliability, and availability of, or to prevent the failure of, plant structures, systems, and camponents. The Consission intends the scope of j
the rule to sever all systems, structures and components, iacteding those in the 841ance-of-Plant,1 r = t; M
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^
j Maintenance includes not only activities traditionally associated l
with identifying and correcting actual or potential degraded i
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conditio 1.e., repatr, surveillance, diagnostic examinations, and prevMtive measures; but extends to all supporting functions for the conduct of these activities. Maintenance includes the following activities:
'l (1)
Technology in the areas of:
(1)
Corrective maintenance.
(11) Preventive maintenance, (iii)Predictivemaintenance,and i
(iv) Maintenance Surveillance; (2)
Engineering in support of main'.anance; (3)
Quality assurance and quality control of maintenance activities; (4)
Incorporation of plant modifications into the maintenance program; l
(5)
Equipment history and trending; (6)
Maintenance record keeping;
?
l (7)
Management of parts, tools, and facilities; (8)
Maintenance procedures; (9)
Post-Maintenance testing and return-tu-service activities; I
(10)
Measures of overall mainGEance program effectiveness; 21 l
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[7690-01]
(11)
Maintenance management'and organization in the areas 4
of:
i
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(1) planning.
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(.11) Scheduling.
(iii) Staffing.
l.
.,(iv) Shift coverage. and I
-(v)
Resource allocation; i
i (12)
' Control of contracted maintenance services; 1
(13)
Radiological exposure control.(including,ALARA) during t
l maintenance activities; J
1 l
(14)
Maintenance personnel qualification and training;.
i 2
(15)
Internal cosaunications between the maintenance l
]
organization ar.d plant operations and, support groups; b
i (16)
Communications between plant and corporate management and the maintenance organization; and l
N.'A & 4 (17) g'aintenance recossendations or requirements of
)
g 9
individual vendors.
(c) Requirements.-
Each holder of an operating license sub, ject to l
thissectionshall(1) establish,imgprg{magaigay effective and documented maintenance progr g y defined in j
- paragraph (b)ofthissection,and(2) sessheeffectiveness j
l of this maintenance program and, based upon this ass 2ssment, i
sake improvements, as appropriate. ~
i j
(d) Implementation. By [ insert a date 2 years after the effective date of the amendment] each licensee shall certify, by letter to i
22 Enc 1csure 1 i
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+
[7$9041]
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l the Director of the Office of Nuclear Reactor Regulation, that a i
l cc.mprehensive documented maintenance proggs,6f,ng,,mgintained and isplemented, which addresses all elemantsp' txx;;-
l Pr*Peam-e+ defined in paragraphg)gtJJge,ti,op igudj,ng, j
j menures to monitor /fiIdgaprove thegrogram, where appropriate.
In addition, each ficensee shall develop [ insert a date 3 months j
k after the effective date of the amendment) a timely and
' expeditious plan and schedule (including Key Milestones) for f
j meeting the requirements of this section.
h l
Dated at Rockville, Maryland this day of
,1988 4
i For the Nuclear Regulatory Commission.
I i
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Samuel J. Chilk, Secretary of the Cossaission.
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COMMIS820NE:RB' VOTE SHEETS I
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t N O T A T I-O N VOTE RESPONSE SHEET T0:
SAMUEL J. CHILK, SECRETARY OF THE COMMISSION 1
I FROM:
CHAIRMAN.ZECH
SUBJECT:
SECY-88-277 - AMENDMENT TO 10 CFR 50 RELATED TO MAINTENANCE OF. NUCLEAR POWER PLANTS I
APPROVED X*
DISAPPROVED ABSTAIN i
NOT PARTICIPATING REQUEST DISCUSSION.
COMMENTS:
- Subject to the attached comments.
?
l N-SIGNAt2RE U lo 21-E DATE Xf3 ENTERED ON "AS"
/
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/
NRC-SECY FORM MAY, 1987 t
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i CHAIRMAN ZECH'S G ZNTS ON SECY-BG-277:
I am in 4avor of publishing this proposed rulo en datetenance of Nuclear Power Plants. sucject to the catailed comments :.sted below.
I believe that effective maintenance is esse..tial to the l
continued safe operation of nuclear power plants and t!at such a rula is needed in crear to make clear the Commission's safety reautrements regarding etfective maintenannce, to f ur tner enhance -
the effectiveness of mair.tenance at some plants, and to assure the continued effectiveness of maintenance at the others.
1 reccqnite that the industry has made significant progress over the past several -years in improving overall piarformance including maintenance performance. and_I encour.ge their continued eHcrts j
.in this regard.
While I recentze the difficultv of specifying unif orm reoutren. nts f or maintenance given the cresent generation o+ " custom t.,s t i t pl ants", I believe that the staH,'s proposed-general approach to r ulemaking will provide the necessarv
- 1.ea t o 11 : t., to 4ccommodate plant specific differences.
I commend t.e itRC staff to carefully study comments received from the industry and the public. in recognition of the vast wealth of kncwledge and exper*.ence that thov have. acquired in the area of maintenance. and to meticulous 1v prepare the final' rule in such a way that the result will be to enhance, rather than detract from, t'io vvf ectiveness of current maintenance practices.
I also ccamend thw NRC staff to continue to'.nonitar industry emphasis and progress 2.n impro.ing maintenance eHectiveness during the rulseaking procosv.
Tha followino detailed ccmments should be.ncluded. i1 :he publiesttor f the proposed rules
~
1.
In ny m ew this proposed maintunerics rule snssid ':e cnsider ed under 10 CFR D.109(a)(4) of tne tacket, rule, t,ased c. the urecepts that ef +ective maintenence : a aeceacarv to assure that the tecility poses 10 undue risk to the public health and safety e.nd that the prvucw-d rulo codifies and standardices pronously ewi sta.iit Come.suion requirements. both explicit and implicit.
.n plant technical speci f i cati ons, licensee safety analysis recorts, +nd 10 CFR 30, Appendix B.
I believe that eff ective maintenance is necess.arv to provide reasonable assurance that plant structures. systems..or.
- omponent s (SSCs) will perform their intended f u.iction when acui-ed.
The demonstration of system operabt it ty via t ect, equired a,n the plant, tec hni e,*a.,1,yppq1 f i ca ti ;;.i.
c,,,,?
4e A J11 e.*ces.o.tztratiti. 'c+ -the uan.abi li ty of a- @JD *'.c - ce/ #if.s fts,
~~
I'n' tended saf ety f'>nction if the : ESC romaa ns i,..%e comign
configuration 4nd its perf ormance capab.l a ty i s ;nanntained
<<ithin the.seuign parameters assumed in pi+nt savety
.n.a t mes.
4-.
1 i
s In the past, the Commission has enforced maintenance j
~ requirements at nuclear power plants largely based on technical speci fication requirements, comena toents ccntained in plant saf ety anai s sis reports. And the cuality insurance l
criteria of 1CCFR50, Appendix B.
The maar.tenance-reouirements an many cases are implicit in those documents j
rather tesn suplicit.
In av view, this propcsed rutemaking 4
l mction mall -primarily provide explicit. treatment f or pre-existing requirements f or maintenance, clarif y -he 1
Commission's expectations f or the attainment of unif ormly high staridards of maintenance at all nuclear power plants, and provide the enforcement tools that may be needed to achieve the Com.aission's expectations.
I believe that the extension of NRC's maintenance rule to belance of dlin't e"quiprint'is necessary and proper.
Mcwever. some tacensue maintenance programs, as presently con 4 f gured,.acp;v to structures, systems, And components t5st are. without que s ti on. irrelevant to protection of-public health anc safwtv from radiological hazards essociatec with the operation of the nuclear power plant.
i The staf4 should carefully consider what limitation, if any, should be placed en the final maintenance rule, to provide some licensee +1exioility in this regard.
i 3.
The -staf f must caref ully consider the criteria that it will apply to cetsemine when a maintenance orogram is f ully eff ective and f urther improvements are no longer warranted frcm a safetv standpoint.
I encourao* the staff to provide i
clarification of its criteria. either in the final rule, or in the accompanvang regulatory guide.
}
4.
The Cedaes! Peoister Notice should. soli:it oubiac comments concernino comn.ents 1,
2.
and 0 above.
The icilowing are proposed cudations for inclusion in the motices 4.
Chairman Tech believes that the proposed maintenance rule should be exempt + rom the backfit rule l
requirements based on the precepts that of f ective maintenance is necessary to assure edequate public
{
protection and that the proposed rule codi fies.sno standard 12es previously existing Commissium i
requirements. both explicit and 1.npitca t.
in plant
{
technical specifications, licensee safety analysis" i
reports, and 10 CFR 50, Appendix B., The Commt ssion -,,
l requests public comment concerning the need for a j
b ack+ 1 t er.n1'.'si s f or thi s rul emaki ng.
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Chairman Zach helieves that the inclusion et :.tlance et plant (PCP) oculoesnt in the proposed main:.snance rule is necessary and proper.
Howeser. Chairman Zecn also recogna:es that some licensee maintsnence 7regrams, as presently configured, apply to structures,' systems.
nd compcoents that are, without questi on, ir relevant to I
prctection of public health and saf ety f rom radiological hazards associated w1th the operation of the nuclear power plant.
The Comm1ssion recuesta public comnant cencerning what limitatton, if any, should ha placed on the final matntenance rule, to provice scan licensee flex 1bility in thas regaro.
C.
Chairman _~.ech,destres to estaclish cr1terza within the
.naintensr.ce rule which' would f orm the basis f or daternt r trq when a maintenance program, is f ully effecti*,9
..id addstional improvement is not warrantee f r e,.1. 4 a.At' s t s s-. an d p oi n t.
Such c s teria enight be either over.ti tative or qualitatt ve and could be based on spectile neasuracle attributes. on uverrall plant performance, on program results, or on other attributes.
The Commission requests public comment concerning the reeed for such criteria, the form of such criteria, arid the criterz a themselves.
5.
I agree with C mmissioner Roger's vot. sheet comment regarding per*ormance-based rulemaking.
I support his desire to maintain this option f or the tuture.
l 4.
'r. Aodi tion to the 4.bove comments, specific editerial l
changes are inarked on the attached sheets.
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DESCRIPTION 1
l It is the objective of the Commission hat all components, systems l
I and structures of nuclear power plants be effectively maintained so that l
plant equipment will perform its intend iflinction when required. The j
scope of the proposed rule is intended o cover all systems, structures l
and components including those in th 0F). To accomplish this objective,
)
the proposed rule would require mch commercial nuclear power plant to I
develop and implement a well-deflued program to assure the.t maintenance j
activities are conducted tu preserve or restore, with prompt repair, the j
availability, performance and reliability of plant structures, systems, j
and components. The program should clearly define the components and j
activities included, as well as the management systems used to control j
those activities. Further, the progran should include feedback of specific 1
j results to ensure corrective actions, provisious for overall program
}
evaluation, and the identification of possible component or system design problems. Compliance with the rule woulti be verified by MRC audit and 4
i inspection.
1 l
The proposed rule does not require that licensees h-neCnd n l
report Maintenance Performanc g gtors (l#13 Howev g aph licenste j
would be required to have his own, monitoring f p wnich would be subject i
to NRC review. The Comnission solicits consents on the application and i
s usefulness of MPIs as part of the rule, and whether a set of MPIs exists 4
l whichcouldindicatetheeffectivenessgpla.ntnainspanceproyans.4,np 1
addition, the Commission solicits feedbackMhk rNINI'A' -9Hf
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.is the rule.
4e 6: MC
- S i
PUBLIC WORKSHOP i
'The Cosmission held atuolic Warishop.or July 11-13, 1988 in
(
i Washington, D.C. to solicit early input for tE formulation of the rule l
from the public and regulated industry. Prior to the korkshop, a paper on 3
rulemaking options was distributed to interested parties to facilitate
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3 4
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[7590-01]
1 Workshop discussions. The paper on rulemaking options, and the transcript and proceedings (NUREG/CP - 0099)2 of the Workshop are available for inspection in the NRC Public Document Room, 2120 L Street, I
Lower Level, N.W., Washington, D.C.
20037 As a result of Workshop discussions, the Commission has come to the following conclusions:
1 1.
Rulemaking should encourage industry initiatives directed toware improving maintenance, since such initiatives promote industry responsibility for problem identification and resolution; j.
2.
Prescriptive rulemaking options may impede industry initiatives l
and responsibility to improve maintenance; and f
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3.
Rulemaking should be directed toward specif,ying the NRC's P'h Il W i
j expectations in maintenance anc requirf, monitoring of the l
effectiveness of maintenance programs.
l Therefore, the Commission proposes a maintenance rule which gives incentive for industry to develop a standard for a maintenance program, which NRC may encorse in a Regulatory Guise.
1 Memorandum from Victor Stallo, Jr., Executive Director for Operations, to the Commissioners, " Proposed Rulemaking for the Maintenance of Nuclear Power Plants," dated June 27, 19,88.
O Copies of MUREs series reports naking furchased through the U.S.
be Government Printing Office by cal 202) 275-2060 or by writing to the U.S. Governecnt printing Office, P.O. Box 37082, Washington, D.C.
20013-7082. Copies s4y also be purchased from.the National Technical Inforration Service, U.S. Department of Inamarce, b285 Port Royal Road, Springfi=10, VA 22161. A copy is available for inspection or copying for a fee in the NRC Public Document Room, 2120 L Street, Lower Level, N.W., Washington, D.C.
20037.
a Enclosure'l
l
- ~
[7590-01]
EXPECTATIONS FOR MAINTENANCE STANDNtD The Commission encourages industry to develop a Maintenance Standard I
which will provide guidance for complying with requirements of the proposed rule. The Commission tielieves that the development of a standard will guide current industry initiatives towards developing and implementing acceptable maintenance programs, and that utility participation in preparation of a Maintenance Standard will provide additional incentive ano responsibility for 1
improving plant maintenance programs.
The Commission plans to develop a Aegulatory Guide 'to' provide guidance for complying with the rule if industry does not develop an adequate standard.
However, the Commission prefers to endorse an industry-developedgard.
To meet the Commission's plans for implementation of the rule the,cosehnt to develop a liaintenance Standard should be made now and a final standard
~
should be proposed ho later than Septes6er 1, 198g. The Cossission expects to publish a Regulatory Guide endorsing a Maintenance Standare or providing NRC guidance by April 1, 1990. The comprehensive program, requirements of the proposed rule would be required to be fully implemented within one year following publication of the Regulatory Guide.'
The proposed rule defines those attributes the Commission considers necessary I
for an acceptable Maintenance Program. To be acceptable, any standard developed to implement the rule should have the following characteristics:
Should define the plant systems, structures and components l
included in the maintenance program (the scope of the rule l
covers all systems, structures and components including those l
inthe80p);
Sha;;1t! require a systemstic evaluation (" systems approach") of -
the functions and objectives of plant systems, components and structures to determine maintenance activities and requirements; 5
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[7590-01]
Should provide clear and specific pregramatic requiremente that can be practically implemented to achieve high reliability; Should be comprehensive in addressing the activities and functions included in the proposed rule plus provisions for self assessment; 1
Should reference standa-ds or guidelines such as those develope, e,y ANS ASME, IEEE, ASTM, INP0, or EPA! where practical to provide (a) specific programmatic requirements or (b) guidance for maintenance of specific t of equipmentt Should allow flexibility for adoption of new innovative technologies as are validated; and r
Should provide for sufficient documentation so that program effectivent and compliance with requirements of the standard can be evaluated.
As noted above, an integral part of a good maintenance program is'the monits and feedback of results. Programs should utilize q antitative measures to monitor and adjust the maintenance program activities., Measures that are b.
Upon actual component reliability and failure history provide useful indica-ju-(4 of maintenance effectiveness. Such measures need a well structured and com h
oriented system; e.g}$PRDS)to ca'pture and track equipment history data.
Commission notes and encourages the use of the industry-wide NPRDS for this purpose in view of the multiple uses for this data.
In addition, the Commission has conducted studies to review effective mainte approaches and practices in other countries and industries and has document findings in a draft NUREG series report. 3 The Consission seeks connents o draft NUREG report which may be submitted to the NRC as. indicated under the i
ADORESSES heading.
i 3 '" W ffee single copi of draf t NURE3-1333. " Maintenance-Approaches and Practic
?
selected foreign Nuclear Power Programs asid Other U.S. Industrics: kevi&w :
Lessons Learned " to the extent of supply, may be obtained by writing to tr.
Distribution Services Section, Document Control Branch, Division of Support Services, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555. A cc also available for inspection or copying for a fee in the NRC Public Docume Room 2120 L Street, Lower Level, NW., Washington, D.C. 20037. Enclosure 1
- _ _ 1 9
1
[7690-01]
Iy ICG The draft NUREG report concludes that t following are practices in foreign count and other U.S. industr maintenance programs which have been found to contribute significantly to effective maintenance:
i 1.
Focus on long ters maintenance objectives; establish a proactive maintenance program as opposed to reactive maintenance; 2.
Use of a reliability centered approach to maintenance, including consideration of the man-machine interface; 3.
Collection and engineering evaluation of failure plata (root cause analysis);
4 Use of an integrated informat17n system for collecting data and monitoring the effectiveness of a maintenance program; 5.
Use of maintenance technician training / certification programs; 6.
Derive planning and scheduling from overall program objectives; 7.
Enhance environment /motivattun of maintenance technicians (e.g.
thru cross-training, " Crew Chief" concept); and 8.
Clearly define interfaces between maintenance and uther activities (engineering support, operations QA, QC, corporate offices, s4fety review).
The Cosuitssion encourages in the development of any Maintenance Standara, constoeration of the findings in the above referencea draft NUREG report end any ather pertiner.t studies on effective er ' - ance practices.
da. wJ Aq The Commission a lso encourages'tEhe Maintenance standa sicer f
' ncorporating appropriate maintenance derived from plant aging stucies{ na i
7 Encicsure.1
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-[7590-01]
CERTIFICATION PLANT MAINTENANCE PROGRAMS The Consission wishes to encourage industry initiatives and r bility for problem identification and resolution. Therefore, as a further way of encouraging industry participation and responsibility, the Commission is I
willing to consider a process of utilizing a designated third party to review and certify licensee maintenance programs for conformance with the Maintenance Standard. This process, if successful, could alleviate the need for detailed NRC inspection of all ifcensee maintenance programs. The Commission solicits proposals for conducting such a certification process.
f ComENTS REQUESTED In addition to comments on the content of this Notice,of Proposed Rule-making, the Commission specifically solicits input on the following questions:
1.
Is it appropriate for the nuclear power industry to develop a Maintenance Standard and, if so, would the industry develop such a Maintenance Standard?
2.
What level of detail should be included in the Maintenance Standard?
3.
Is two years a reasonable time to develop, and implement a standard?
4.
Is it appropriate for a designated third party to certify plant maintenance programs to comply with the Maintenance Standard; and, if so, would an organization be willing.to perform such
' certification?
5.
Should an industry-wide component failure reporting system, e.g.,
NPRDS, be used by all plants in order to support the sharing of gener maiMa-" -kpee+t+aglexperience and facilitate monitoring of maintenance effec-tivenessff
, JesA ah %
't_
0_
i 4 acco-f*j@y-0 The economic fapact of the proposed requirement on licqnsees should be negligible.
though initial financisi investments will be required oy some ifcensees to establish a systasatic and comprehensive maintenance progra g the savings due to decreased corrective maintenance costs and increased plant availability should cotweigh 1.ne investment costs. The Commission requests cooperation of informed sources in order to develop further details and verification of this analysis. Enclosure 1 I
.____.____]
.e s' r
[7590-01) conditio 1.e., repair, surveillance, diagnostic examinations, and prevMive measures; but extends to all supporting functions for the conduct of these activities. Maintenance includes the i
l following activities:
.s r(1)
Technology in the areas.cf:
(1)
Corrective maintenance, (ii) Preventive maintenance, (iii)Predictivemaintenance,and (iv) Maintenance Surveillance; (2)
Engineering in support of maintenance; (3)
Quality assurance aad quality contrci of maintenance activities; (4)
Incorporation of plant modifications into the maintenance progras;
~
(5)
Equipsent history and trending; (6)
Maintenance record keeping; (7)
Management of parts, tools, and facilities; (8)
Maintenance procedures; (9)
Post-Maintenance testing and return-to-service activities; (10)
Measmes of overall maint7ance program eff ectiveness; 21
P
)
[7590-01]
Should provide clear and specific prograumatic requirements that can be practically implemented to achieve high reliability; Should be comprehensive in addressing the activities and functions included in the proposed rule plus provisions for self assessment; I
Should reference standards or guidelines such as those developed by ANS ASME, IEEE, ASTM, INp0, or EPRI where practical to provide (a) specific prograsustic requirements or (b) guidance for maintenance of specific t of equipment; Should allow flexibility for adoption of new innovative technologies as are validated; and Should provide for sufficient documentation so that program effectivens and compliance with requirements of the standard can be evaluated.
As noted above, an integral part of a good maintenance program is'the moniti and feedback of results. Programs should utilize quantitative measures to monitor and adjust the maintenance program activities., Measures that are b.
upon actual component reliability and failure history provide useful indica-k g' of maintenance effectiveness. Such measures need a well structured and com p,.b -h ortanted system; e.g
$PRDS)tocaptureandtrackequipmenthistorydata.
Commission notes and encourages the use of the industry-wide NPR05 for this l
purpose in view of the multiple uses for this data.
In addition, the Commission has conducted studies to review effective maints approaches and practices in other countries and industries and has document findings in a draft NUREG series report. 3 The Commission seeks comments o draft NUREG report which may be submitted to the NRC as. indicated under the ADORESSES heading.
3 " T thee single cop? of draf t NURE3-1333.
- Maintenance; Approaches and Practic 7
Selected foreign Neclear Power Programs ali3 Other U.S. Industrics: ke,16w :
Lessons Learned.' to tb extent of supply, may be obtained by writing to tt Distribution Services Letton, Document Control Branch, Division of Support Services. U.S. Nuclear Regulatory Cosmission, Washington, D.C. 20555. A cc also available for inspection or copying for a fee in the NRC Pubit-Docume Room, 2120 L Street, Lower Level, NW., Washington, D.C. 20037.
-6 Enclosure )
~
l
[7$90-01]
'J i
Ig6 The draft NUREG report concludes that following tre practices in foreign count and other U.S. industr maintenance programs which have been found to contribute significantly to effective maintenance:
i 1.
Focus on long term maintenance objectives; establish a proactive maintenance program as opposed to reactive maintenance; 2.
Use of a reliability centered approach to maintenance, including consideration of the man-machine interface; 3.
Collection and engineering evaluation of failure plata (root cause analysis);
4 Use of an integrated infonnation system for collecting data and monitoring the effectiveness of a maintenance program; 5.
Use of maintenance technician training / certification programs; 6.
Derive planning and scheduling tron overall program objectives; 7.
Enhance environment / motivation of maintenance technicians (e.g.
thru cross-training, " Crew Chief
- concept); and 8.
Clearly define interfaces between maintenance and other sctivities (cngineeringsupport,operationsQA,QC,corporateuffices, safety review).
The Cosmiission encourages in the development of any Maintenance Stancare, consieeration of the findings in the above referencea draft NUREG report end any ather pertiner.t studies on effective maintenance practices.
As s 4 dG The Commission also encourages!'Mintenance Standa sicer
' ncorporating appropriate maintenance derived from plant aging stucies{ su i
7 Enclosure.1
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-[7590-01)
CERTIFICATION Pl. ANT MAINTENANCE PROGRAMS The Commission wishes to encourage industry initiatives and r bility for problem identification and resolution. Therefore, as a further way of encouraging industry participation and responsibility, the Commission is I
willing to consider a process of utilizing a designated third party to review and certify licensee maintenance programs for conformance with the Maintenance Standard. This process, if successful, could alleviate the need for detailed NRC inspection of all licensee maintenance programs. The Commissirn solicits proposals for conducting such a certification process.
t COMENTS REQUESTED In addition to comments on the content of this Notice,of Proposed Rule-making, the Comeission specifically solicits input on the following questions:
1.
Is it appropriate for the nuclear power industry to develop a Maintenance Standard and, if so, would the industry develop such a Maintenance Standard?
2.
What level of detail should be included in the Maintenance Standard?
3.
Is two years a reasonable time to develop, and implement a standard?
4.
Is it appropriate for a designated third party to certify plant maintenance programs to comply with the Maintenance Standard; and, if so, would an organization be willing.to perform such
'ertification?
c 5.
Should an industry-wide component failure reporting system, e.g.,
NPROS, be used by all plants in order to support the sharing of gener maiabe -4epeeeMaglexperience and facilitate monitoring of maintenance effee-tivenessff
,JM 1
0_d~ah %
4..-c a r The economic impact of the proposed requirement on licqnsees should be negligible.
though initial financial investments will be required by some licensees to establish a systematic and comprehensive maintenance program. the savings due to decreased corrective maintenance costs and increased plant availability should atweigh 'the investment costs. The Commission requests cooperation of informed sources in order to develop further details and verification of this analysis. Enclosure 1
e
[7590-01]
conditio 1.e., repair, surveillance, diagnostic examinations, and prevMfive measures; but extends to all supporting functions for the conduct of these activities. Maintenance includes the l
following activities:
-(1)
Technology in the areas of:
(1)
Corrective maintenance, (11) Preventive maintenance, (iii)Predictivemaintenance,and (iv) Maintenance Surveillance; (2)
Engineering in support of maintenance; (3)
Quality assurance and quality contrc) of maintenance activities; (4)
Incorporation of plant modifications into the maintenance program;
~
(5)
Equipment history and trending; 9
(6)
Maintenance record keeping; (7)
Management of parts, tools,t.nd facilities; (8)
Maintenance procedures; (9)
Post-Maintenance testing and return-tu-service activities; (10)
Measures of overall maintTriance program eff ect!veness; 21
.+
[7590-01) issued under Sec.184, 68 Stat. 954, as amended (42 U.S.C. 2234).
Section 50.103 also issued under Sec.108, 68 Stat. 939, as amended (42U.S.C.2237).
I For the purposes of Sec. 223, 68 Stat. 958, ai amended (42 U.S.C.
2273),il50.10(a),(b),and(c) 50.44, 50.46, 50.48 and 50.54 ana 50.54(a) are issued under Sec.161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); il 50.10(b) and (c) and 50.54 are issued under Sec.
g 1611, 68, stat. 949, as amended (42 U.S.C. 2201(1)); and il 50.9, 50.55(e), 50.59(b), 50.70, 50.71, 50.72, 50.73 and 50.78 are issues under Sec.161o, 68 Stat. 950, as amended (42 U.S.C.' 2201(c)).
2.
A new i 50.65 is added to reso as follows:
5 50.65 Requirements to ensure the effectiveness of
~
maintenance programs for nuclear' power plants'.
(a) Applicability. The requirements of this section, apply to all nuclear power reactors licensed under i 50.21 b' or 50.22.
H~h LJ.
y (b) Definitions. For the purpose of this section the Commission defines maintenanc6 as the aggregate of thos actions required to preserve and promptly restore operability, reliability, and availability of, or to prevent the failure of, plant structures, systems, and components. The Commission intends the scope of the rule to cover all systems, structures and components, including those in the Salance-of-Plant.x - - m;; M m.m'ur A
Maintenance includes not only activities traditicr. ally associated with toentifying and correcting actual or potential degraded
^
20
(7590-01]
(11)
Maintenance management and organization in tne areas of:
i (1)
- Planning, (11) Scheduling, (iii) Staffing, (iv) Shif t coverage, and (v)
Resource allocation; i
(12)
Control of contracted maintenance services; (13)
Radiological exposure control (including ALARA) during maintenance activities; (14)
Maintenance personnel qualification and training; (15)
Internal communications between the maintenance organization er.d plant operations and. support groups; (16)
Communications between plant and corporate management and the maintenance organization; and bebEE l
(17) g'aintenance recommendations or requirements of inci<idual vendors.
(c) Requirements.
Each holder of an operating license subject to this section shall (1) establish, imp g n g g ma g aig a y J effective and documented maintenance progr g y defined in paragraph (b) of this section, and (2)sess de effectiveness of this maintenance progr.m and, based upon this assessment, make improvements, as appropriate. (d) Implementation. By [ insert a date 2 years after the effective dateoftheamendment]eachlicenseeshallcertify,byletterto 22 Enciesure 1 O
.o i [7$90-01)' l the Director of the Office of Nuclear Reactor Regulation, that a comprehensive documented maintenance proggs,gingintained .and implemented, which addresses all elementspf : -9t:n;.x arenemm*+definedinparagraphp)gtgj c,tiopigudJng I measures to monitortfiis Amprove thegrogram, whert appropriate. In addition, each ficenh shall develop [ insert a date 3 months after the effective date of the amendment] a timely and expeditious plan and schedule (including Key Milestones) for meeting the requirements of this section. Dated at Rockville, Maryland this day of 1988 For the Nuclear Regulatory Commission. Samuel J. Chilk, Secretary of the Cossaission. 23 Enciesure 1
i a NOTATION VOTE ' RESPONSE SHEET - TO: SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM: C0ffilSSIONER ROBERTS i
SUBJECT:
SEN-88-277'-AMENDMENTTO10CFR50RELATEDTO MAINTENANCE OF NUCLEAR POWER PLANTS ^ I APROVED DISAPPRO'KD ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION COMMENTS: j l l l i -} $} ~ S 6NA RE to/pt if I DATE YIE E l ENTERED ON "AS" / / / / I NRC-SECY FORM MAY, 1987 1
- L.
- -.-.. _:. _ -^
~ ~- j i l t i 1 1' TMR COMMENTS ON SECY-88-277 1 \\ I fully support the views of the ACRS on this proposed rulemaking j and can not approve this proposed maintenance rule. The rule as j proposed would require that each licensee establish, implement, and maintain an effective and documented maintenance program and j, to assess the effectiveness of this program and make I improvements, as appropriate. Without bei M afforded the opportunity to review the accompanying Regulatory Guide, the Commission is left in a position of approving a specious rule. t Furthermore, I do not believe that the staff has adequately made i j a case that licensees do not have established maintenance i Staff has not demonstrated that this rule would programs. J improve the implementation of the existing programs. Staff I provides no basis to determine when a maintenance program is effective or when improvements are "appropria*e". I also do not l agree with a rule that would have us regurad ag maintenance on all systems, structures and components regardless of'whether they have a nexus with radiological safety or not. I am skeptical of l the assumptions made in the backfit and regulatory analyses and -specifically request comments on both of these documents. l 2 also request comments on the views of the ACRS. I share its ~ concern that the existence of this rule could make things worse. } j They state that "... there are characteristics of regulations, and especially the way in which they are typically enz'orced, that j lead us to believe that, under a rule, a nevo toward uniformity i would occur, and this is likely to decrease the effectiveness of 1 j some of the better existing programs." It is because I believe on the importance of good maintenance practices that I am voting i l against this rule. I e 4 i l 1 j I I
s. p i e e f NOTATION VOTE i RESPONSE SHEET TO: SAMUEL J. CHILK, SECRETARY OF THE COMMISS10N 1 f FROM: COPPl!SSIONER CARR
SUBJECT:
SECY-88-277 - AMENDMENT TO 10 CFR 50 RELATED TO MAINTENANCE OF NUCLEAR POWER PLANTS k I l l APPROVED X w/co==nts DISAPPROVED . 20',.IN NOT PARTICIPATING REQUEST DISCUSSION l COMMENTS: see attached coments. i 1 l l Ms.hc n._. SIGNATURE 10 9.8 '% 8 DATE YIS. 80. ENTERED ON "AS" / / / / NRC-SECY FORM MAY, 1987 l
j 1 'Coastissioner Carr's vote on SECY-88-277 l In I agree with the Chairman's and Constissioner Rogers' cosusents. i addition, I have the following comments. i 1. I believe that maintenance programs should provide a means for establishing individual worker accountability for maintenance j, ' I recessend that staff carefully consider how this performed. j j criterion can be incorporated into the mismaking and I would i solicit comment on this subject in the r:1emaking notice. + The current staff proposal is for issuance of the Final Rule in 2. April 1989 with the Aegulatory Guide to follow in Novem6er 1989. i A better course of action would be to delay issuance of the Final J Rule so that it can he put forward along with the Regulatory Guide which will provide essential information on rule implementation. i Therefore, I recossend that the Regulatory Guide, which will 1 j endorse the industry standard or define the NRC guidance, be issued concurrently with the Final Rule by November 1989. i 4: I l i k i 4 Y 3 s ( l k 1 ~ i l i i J, i 1 1
s. .v e n.
- i..
f l NOTATION VOTE l ESfQUESHEET i ] TO: SAMUEL J. CHILK, SECRETARY OF THE COMMISSION \\ ^ FROM: COMMISSIONER ROGERS i f
SUBJECT:
SECY-88-277 - AMENDMENT TO 10 CFR 50 RELATED TO MAINTENANCE OF NUCLEAR POWER PLANTS i t j so act r. i APPROVED uaw m ktst. DISAPPROVED ABSTd!N i i NOT PARTICIPATING REQUEST DISCUSSION 1 i COMMENTS: i I hold the opinion that the Commission now has a unique opportunity i here to take an important new positive step in regulation. Therefore, I feel that the proposed rule should include an additional statement that allows that to take place. My approval of the proposed rule is contingent upon such an addition. The suggested additional wording is included in the new pages 6 and 8 which are attached. i. e d i A
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i_ .e ,~ i D - , -. ~., j should provide clear and specific o ~ i programmatic requirements that can be practically implemented to achieve high d 1 reliability; I l should be comprehensive in addressing the j o i activities and functions included in the i l proposed rule plus provisions for self i 5 assessment; should reference standards or guidelines such o j as those developed by ANS, ASME, IEEE, ASTN,, i i INPO, or EPRI where practical to provida (a) l specific programmatic requirements or (b) i j guidance for maintenance of specific types of j equipments should allow flexibility for adoption of new o 3 innovative technologies as they are \\ l validated; and should provide for sufficient documentation o f so that program effectiveness and compliance l with requirements of the standerd can be 4 I evaluated. The Commission has oonducted studies to review effective, a } saintoaanoe approaches and practices in other oountries.and i I i Enclosure 1 l i t 3 j 1
.~ i i { { i j industries and has documented the~ findings in a draft NURES series toport.3 The Commission seeks comments on the draft NUR38 l report which may be submitted to'this NRC as indicated under the k f ADDRESSSS heading. g I 1 i i As noted above, an integral part of a good maintenanos program is the monitoring and feedback of results. Programs should utilise g,uantitative asasures to monitor and adjust the maintemanoe program activities. Naasures +, hat are based upon motsal component reliability and failure history provide useful indication of maintenamos effectiveness. Such measures need a . 11.t-stur.d and oom,onent ori.at.4 system,..... S t. ospture and track equipment history data. The commission notes and enoourages the use of the industry-wide NPRDS for this purpose in view of the multiple uses for this data. The Commission views maintenance rulemaking as an opportunity to encourage (a) good maintenanoe practices, (b) the adoption of oommon maintenanos standards, and (o) the development of valia quantitative measures of effectiveness which oonld become the basis for rsegulation by outoomes rather thaa processes. The 3A free single copy of draft NUREG-1333, ' Maintenance Approaches and Practices in Selected Foreign Nuclear Power Programs and Other U.S. Industries: Review and Lessons Learned," to the extent of supply, may be obtained by writing to the Distribution Services Section, Document Control Branch, Division of Support
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Nuclear Regulatory Commission, Washington, D.C. 20555. A copy is also available for inspection or copying for a fee in the NRC Public Document Room, 2120 L Street, Iower Inval, NW., Washington, D. C. 20037. - 6a -
i + 4 l. 1 1 herein proposed rule addresses (a) and (b) but act (s). Follow-on ruleakking is envisioned which would build on the bases l established in this rule and would define those validated l measurable quantities.or indicators that could eredibly beoose i j j the basis for regulatory attention or action in the future f instead of the systems for maintenanos established under (a) and (b) of this proposed rule. i ) i i f 1 4 1 I i 1 i i 4 i J e t ) I j 4 e 1 f ( l 2 I - 6b - I i J 1
- '- - r z _ _-.: - ^ fe. ~' 1 i e.. !~ l 4 CERTIFICATION OF PIANT MAINTENANCE F5t0 GRAMS The' Commission wishes to encourage industry initiatives and responsibility for problem identification and resolution. Therefore, as a further way of encouraging industry participation l a,4 responsibility, the Ccamission is willing to consider a process of utilising a designated third party to review and certify licensee maintenance programs for conformance with the Maintenance standard. This process, if successful, could i elleviate the need for detailed NRC inspection of all licensee maintenance programs. The Commission solicits proposals for conducting such a certification process. COMMENTS REQUESTED In addition to comments on the content of this Notice of Proposed Rulamaking, the Commission specifically solicits input un the following questions: 1. Is it appropriate for the nuclear power industry to develop a Maintenance standard and, if so, would the industry develop such a Maintenance standard? 2. Mhat level of detail should be included in the Maintaanos standard? 3. Is two years a reasonable time to develop, and implement a standard? 4.... Is it appropriate for a designated third ch party to certify plant maintenance programs e e
l j.. ~ i f i i i l l . to comply with the Maintenance Standard; and, if.so, would an organisation be willing to perform such certification? Should an ir.dustry-wide component failure j 5. l 2 l reporting system, e.g., NPRDS, be used by all { plants in order to support the sharing of 1 generic operating experience and facilitate i j monitoring of maintenance effectiveness? 6. 1Lre performance indicaters that are being g I used by industry, may be used in the future,, J I er have been used in the past appropriate sandidates as quantitative measures of 1 maintemanos effootiveness? The commission is 1 particularly interested in experienee er ~ smalysis ooneeraing indioators er the use of indicators of oomponent reliability as 1 malatoaanoa performanoe indicators. S IMPACT J j The economic impact of the proposed requirement on licensees should be negligible. Although initial financial investments i j will be required by some licensees to establish a systematic and t l comprehensive maintenance program, the savings due to decreased l corrective maintenance costs and increased plant availability i should outweigh the investment oosts. The Commission requests cooperation of ins.%rmed sources in order to develop further details and vari.';. cation of this analysis. . Sa -
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NOTATION VOTE RESPONSE SHEET TO: SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM: COMMISSIONER CURTISS l
SUBJECT:
SECY-88-277 - AMENDMENT TO 10 CFR 50 RELATED TO MAINTENANCE OF NUCLEAR POWER PLANTS 8 APPROVED DISAPPROVED ABSTAIN 1 REQUEST DISCUSS 10N' NOT PARTICIPATING xx COMMENTS: l (ik F. s / F James R. 'Curtiss* ( SIGNATURE October 27, 1988 DATE YEE HQ ENTERED ON "AS" / ! l NRC-SECY FORM MAY, 1987 I}}