ML20087B641

Forwards Comments on Proposed Maint Rule Insp Procedure,Per Request During 950627 Workshop on Lessons Learned from Early Implementations of Maint Rule..

ML20087B641
Person / Time
Site:	Oyster Creek
Issue date:	08/02/1995
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C321-95-2214, NUDOCS 9508080207
Download: ML20087B641 (3)

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GPU Nuclear Corporation Nuclear

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ers:"r 88 Forked River New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

August 2,1995 C321-95-2214 t'

U. S. Nerlear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 I

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Proposed Maintenance Rule inspection Procedure On June 27,1995, the USNRC sponsored a public workshop on " Lessons Learned from Early implementations of the Maintenance Rule..." During that conference, a request was made by the USNRC for comments on the proposed revision to the draft inspection procedure.

Attachment I to this letter provides the GPU Nuclear comments for the Oyster Creek Nuclear Generating Station.

If any additional information or assistance is required, please contact Mr. John Rogers of my staff at 609.971.4893.

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) Vice John tartonJ.f Pipsident and Director l

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Attachment cc: Mr. Charles Petrone USNRC

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o to Oyster Creek NRC Project Manager  ;

O Administrator, Region i 9508080207 950802

! Senior Resident inspector PDR ApacK 0500o219 P PDR GPU Nuclear Corporation is a subsidiary of General Pubhc Utihties Corporation ,

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e. j ATTACHMENTI Comments.on Proposed.. Maintenance _ Rule _ Inspection-Procedure.627XX

1. Page 7, Line 27 through 41: There is no clear guidance on precisely what constitutes a

" train". Nuclear power plants have already designed into them the concept of redundancy. The word " train" has historically been used to describe: 1) an ,

independent identical system (redundant system) including such considerations as power  :

supply; or 2) an identical subsystem within a single side of a protective system; or 3) a separate system which uses inputs from several distinct and independent sources.

Therefore, a clear distinction must be made between redundant equipment and separate trains. While it is obviously important to prevent degradation of standby redundant components, it is difficult to classify a redundant system as a separate train and obtain meaningful data about their operations and performance criteria. Language should be added to the procedure to clearly establish Independent Performance Criteria for redundant components, and distinguish the difference between redundant equipment and separate trains.

2. Page 9, Lines 14 and 15: The language selected here could be taken to imply that specific numeric criteria also applies to structures. The assignment of numeric criteria to structures is an inexact science at best. Discussions with the staff have generally indicated that a plant walkdown documented by an engineering evaluation would be acceptable. The clarification needs to be added to this section to preclude future misunderstandings.

3. Page 10, Line 27 through 33: The INPo Safety System Performance indicator database provides information on a very limited number of systems, and would not meet the intent of the Maintenance Rule. Under the Maintenance Rule and NUMARC 93-01 guidance, many more systems must be included (risk significant vice safety related).

Additionally, due to the diversity of system design and concept, the archiving of data from different plants with different design concepts would be of questionable value for the industry as a'whole. Further, it is generally inappropriate for the staff to either recommend or dismiss any vendor of services in a formal NRC document. It is recommended that these lines be deleted.

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• C321-95-2214 Attachment i Page 2

4. The wording in the present draft addresses Maintenance Preventable Functional Failures. This is consistent with discussions and understandings between the staff, NUM ARC, NEl, and the industry. The entire purpose of the Maintenance Rule is to assure the required functions or selected systems will be available if required. At the Public Workshop, some key staff members indicated that to them, the wording in the original Statements of Consideration (addressing Maintenance Preventable Failures, with no regard to impact on function) was to be implemented. There are many components in each system which have absolutely no impact on system functionality. Under the understanding of some key staff members, every nut which becomes cross threaded, or indicating lamp which burns out could be considered a Maintenance Preventable Failure.

Apart from the obvious time and cost element of documenting each MPF component, such a tremendous increase in low quality data bears the real probability of clogging the database and masking actual existent problems. Searching for trends can result in a significant trend being missed (e.g. three significant failures were logged in a database where five cross threaded nuts were also logged. It is of paramount importance that the intent of the Maintenance Rule not be degraded by the inclusion of meaningless data solely for the purpose of increasing the database size. Immediate clarification of this point, to define and accept the MPFF requirement, must be made.

- 5. Page 18, Lines 23 through 33: The procedural significance of Control Room annunciators is very plant specific. At the Oyster Creek Nuclear Generating Sta: ion, there is a large number of annunciators in the Control Room. However, only a very limited number annunciate to alert the operator that a setpoint related to the critical plant parameters in the Emergency Operating Procedures has been reached. The indicator of the critical plant parameter, and not the annunciator, is used to provide an entry condition or action point in the Emergency Operating Procedures. Each licensee should identify which specific indicators are considered critical for that individual plant and include only those identified indicators and annunciators (and support equipment such as power supplies) as equipment covered by the Maintenance Rule.

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