ML20127K926

Request for OMB Review & Supporting Statement Re 10CFR50, Domestic Licensing of Production & Utilization Facilities. Estimated Respondent Burden Is 3,634,365 H

ML20127K926
Person / Time
Issue date:	01/19/1993
From:	Cranford G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
FRN-58FR6730 AE22-1-135, OMB-3150-0011, OMB-3150-11, NUDOCS 9301260275
Download: ML20127K926 (14)

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PART lli.-C:mpl:te This Part Onlyif ths R:qu:stis far Approvalof a C:ll:cti:n gf Intymatirn Undir_thi Pcperw:tk Rsducti:n Act end 5 CFR 1320.

13. Abstra:t-Descree nceds uses and a4ected public in 50

• cess or teu " Nuclear Facilities, Nuclear Power Plant Constructior The maintenance rule requires licensees to establish goals for structures systems, and components (SSCs) and monitor performance, condition, and availability of these SSCs.

Licensees must evaluate, do periodic assessments, and keep records of these activities. NRC is endorsing the industry guidance in NUMARC 93-01 to support the information collections in this

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14. T,pe ct eforer atc :non on(check only one) -

Information c ollections not contained in rules 1[ Feguar w tmson 2 [ Emency sub~ss,on (ce*f f. cat =en at' ached)

Inforh1stion collections contained on rules 3 U Losvg repat on no chrge picwsed) 6 % or rter-nirat e"cuteru*#o9 7 Enter date of expected or artsal Federal 4 [ %t ce v c'opmec N emaug F#DV) A 2 %g A 'ssb+ n on peg ster pubhcation at this stage of ru'emak r g 5 [ Fea, WhM was p*evons p&ho B C E meqenc e si.rsvcn rcert r cat on attached) (month. day. year) 15 T,pe of rece* recueced fcnec* omy oce>

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17. Anns a reportr(i or dweve twden i 3[ 3,,,,,; py, pose statistics 1 %reter of resporcerts . IN 4 0 RetWatoryor comphance 2 Nmber of respomes per responcent  ; X.R l 5 0 Precam p'anres or management 3 Total annua! regenses (Ace 1 frmes me 2)  ! _kdl 3 . f 6 C Resm ch 4 Hours per 'esponse 8 E b5  ! 7 C Aust

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20. Cwent (most recent) OMB control number or comment number 24. Respondents

• obagation to comply (chec A the strorga st cbligaf>on inst appl,es) 1150-0011 i O voiu tary n

21. W%ested esp:raton cate s 2 C Reqwred to of,tain or retain a beneht e

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25. Are the respondents pnmanly edMnal agencies or er stdut ons or it, the ormry purpose of tne co!iecten related to Federal educaten programst O ves 00 No

26. Does tre agency use samphng to select respondents or does the agency recommena or prescrte the use of samphng or statistical analysis by reconcents? . C Yes b No

• 27. Pegwatory authonty for tre m'ormation cocettion 10 CFR W  ; or . , FR  ; or.other (specify).

PaperworkWrtif, cation in satmittrg t4s request for oMB accrovat the agency head, tee sen.or effoat or an authoured representative. es.rtif es that the requrements of 5 CFR 1320, the Prwacy Act, stat st:cai standards or trectaes. and any other appbcable mformatton poncy d4rectives have been complied with.

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OMB SUPP0 MING STATEMENT FOR 10 CFR S 50.65 AND ITS REGULATORY GUIDANCE, " MONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS" (3150-0011)

Descrin. tion of the Lnformation Collection By this submittal the NRC seeks OMB clearance of the information collections outlined in the performt ,r:ented maintenance rule and the industry prepared guidance, NUMAf 01, that the NRC intends to endorse. A specific goal of both the industr. .nd the NRC, associated with adopting industry guidance to implement the maintenance rule, is to avoid duplication of effort.

Section 7 of NUMARC 93-01 identifies this purpose.

Historically, NRC regulatory attention to maintenance of nuclear power plants was based on the following requirements:

. Quality assurance requirements of 10 CFR Part 50, Appendix B; Surveillance replacements in 10 CFR 5 50.36; and In-service inspection requirements in 10 CFR 5 50.55a.

Although the above requirements covered some c' the basic elements of nuclear power plant maintenance, they did not clearly define NRC's expectations f or ensuring the continued effectiveness of maintenance efforts at nuclear power plants. For the purpose of clarifying the NRC's expectations, the NRC has amended its regulations in 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities." The general requirements pertaining to maintenance at nuclear power plants are provided in 10 CFR S 50.65 (may be referred to hereafter as the maintenance rule or the rule), " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

The performance-oriented maintenance rule requires monitoring of the overall continuing effectiveness of licensee maintenance programs to ensure that: (1) safety-related and certain non-safety related, structures, systems, and components (SSCs) are capable of performing their intended functions; and (2) for non-safety related equipment, failures will not occur which prevent the fulfillment of safety-related functions, and failures resulting in reactor scrams or trips and unnecessary actuations of safety-related systems are minimized.

The maintenance rule requires that the licensees monitor the performance of SSCs within the scope of the rule against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Monitoring is not required where it has been demonstrated that the performance or condition of a SSC is being effectively controlled by appropriate preventive maintenance, such that the SSC remains capable of performing its intended function. Performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least annually. The objective of preventing failures through maintenance is to be balanced against the objective of minimizing unavailability of SSCs, in performing monitoring and preventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on performance of safety functions.

The fiRC staff proposes to provide regulatory guidance to implement the rule that will endorse an industry guidance document, f4UMARC 93-01, " Indust.y Guideline for Monitoring the Effectiveness of Maintenance at fluclear Power Plants." Although adoption of the regulatory guidance by licensees is voluntary, it is anticipated that licensees will adopt this guidance.

Therefore, the information collections and burden submitted for OMB clearance are based on this guidance.

The industry guidance is described as follows:

Utilities will be required to identify plant SSCs that are within the scope of the Maintenance Rule that perform a safety-related function, or upon failure could prevent a safety-related function from being fulfilled or cause a ccram or actuation of a safety-related system (Section 8.0)'. For SSCs not within the scope of the Maintenance Rule, each utility is to continue existing maintenance programs.

By the July 10, 1996 implementation date, all SSCs that are within the scope of the rule will have had their performance assessed and will have been placed in 9 50.65(a)(2) and be part of the preventive maintenance program. In addition, those SSCs with unacceptable performance will be placed in s 50.65(a)(1) with goals established and monitoring to meet the goals expected. This determination is to be made by licensee's assessments of the risk significance as well as the performance of the SSCs against utility-specific performance criteria. Specific performance criteria are established for those SSCs that are either risk significant or standby mode; the balance are monitored against the overall plant level performance criteria.

The process addressing 9 50.65(a)(1) includes licensees establishing goals for structures, systems, trains, and components that have nnt demonstrated acceptable performance. The key parameter is performante, which includes availability, reliability, or condition, as appropriato.

Risk significant SSCs should be identified by using +.11s such as an Individual Plant Examination. a Probabilistic S 9 .4ssessment, critical safety functions (e.g., inventory), or other methods, provided they are systematic and documented.

Refer to s;;t L.. h. = Por 93-01.

The performance of SSCs that do not meet the performance criteria established by a utility shall be subjected to goal setting and monitoring that -leads to acceptable performance. Many goals will be set at the system level. In addition, train and component level goals should be established (Section 9.0) when determined appropriate by the utility. Performance of structures, systems, trains, or components, as measured against established goals, will be monitored and documented until it is determined that the goals have been achieved and performance can be addressed in 6 50.65(a)(2).

SSCs within the scope of the Maintenance Rule whose performance is currently determined to be acceptable will be assessed periodically to assure that acceptable performance is sustained (Section 10.0).

Although goals are established and monitored as part of 6 50.65(a)(1), the preventive maintenance and performance monitoring activities are part of 6 50.65(a)(2) and apply to all of the SSCs that are within the scope of-the Maintenance Rule.

An assessment of the overall effect on plant safety will be performed for SSCs that support plant safety functions when they are taken out of service for monitoring or preventive maintenance activities.

Periodic performance assessment and monitoring are proposed to be implemented through utility specific programs that include, as appropriate, event cause determination, corrective action, consideration of industry operating -

experience, and trending.  ;

Sufficient data and information will be collected and retained so that the effectiveness of maintenance and monitoring efforts can be independently audited by the NRC. Section 13 of NUMARC 93-01 indicates industry proposed ,

documentation.

Based on the NRC staff's proposed regulatory guidance, the licensee's information collections will normally consist of program descriptions, data on goals and monitoring efforts, trends of failure data, and trends of  ;

availability data. The information will not be sent to the NRC,.nor will it be separately compiled unless it is information that is not otherwise collected. The objective is to rely on licensees existing documentation collection activities to the greatest extent possible in order to show progress in maintenance by-results in terms of performance, condition and availability of SSCs within the scope of the rule.

Although not explicitly required by the rule, each licensee.will need to collect, process and use existing maintenance records, data'and-industry information in setting and monitoring goals. Plant-specific SSC maintenance history and-performance trends based on SSC history must be' maintained.and-kept current .by licensees and compared with the licensee's. established goals and objectives. The SSC history may include data obtained from the plant- '

specific maintenance surveillance, preventive and corrective maintenance programs, and industry-wide experience. The monitoring activities are to be trended and the results compared with established goals to determine the need for corrective action, e.g., SSC modification, repair, replacement, or changes 3-t i

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to maintenance procedures.

A. 1Q.TIFICATION S

1. Need for the Coi section of Information. Licensees must collect and analyze information concerning the performance of SSCs within the scope of the maintenance rule-in order for them to use information from past experience to predict future _ plant vulnerabilities and plan appropriate maintenance activities aimed at eliminating or mitigating them.

2. Aaency use of information. Information on performance criteria, goal setting and monitoring results, failure data, unavailability di,ta, and documentation of periodic assessments required by the rule will be reviewed at the licensee's facilities by NRC inspectors in order to evaluate SSC serformance and ensure that the SSCs are capable of fulfilling t1eir intended function,- and  ;

thereby maintain safe operation of the plant. Reporting _of information to NRC headquarters or regional offices is not-required. -

3. Reduction of Burden Throuch Informat, ion Technoloav. -The regulations in 5 50.65 do not require licensees to use any ,

particular information technology. However, the NRC encourages the use of new and effective technology that would reduce the burden for the collection and management of information. .

i 4 Effort to identify Duplication. _ Licensees are currently: required <

to collect and document information concerning the condition and-behavior of plant equipment in accordance with 10 CFR 50, Appendix B (e.g., procedures, quality assurance programs, records), 6 50.36 (surveillance requirements), 5 50.48 (fire protection), g 50.49 (environmental qualification), 5 50.55a (in-service inspection requirements), 5 50.61 (pressurized thermal- shock), 9 50.62_

(anticipated transient without scram),:5 50.63 (station blackout),

and 10 CFR 54 if applicable _ (license renewal). At least some of-this same information will be used_by licensees to partially meet the requirements in 5 50.65 with respect to safety-related SSCs.

5. Effort to Vse Similar Informatign. Currently required or voluntary information and documentation will be used where available, i.e.,10 CFR 50 sections listed under item 4 above.

6. Effort--to Reduce Small Business Buthn. The rule affects only nuclear power reactor licensees. None of these licensees fall-within the definition of:a small business, as defined in the Commission's Size Standards (50 FR 50241; December 9, 1985). .

7. Conseoug. Dees of less Freouent Collection. Licensees must I establish procedures for addressing the scope of the rule, setting goals, monitoring, assessing, and correcting performance, as appropriate. This is a one-time collection. Licensees will ,

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thereafter have to collect, document, and maintain failure '

histories for maintenance-preventable functional failures (MPffs),

as defined in the industry guidance, l.icensees will use collected information to identify trends, update component f ailure data  :

bases, and propose design, operational, procedural, or other  !

maintenance related corrective action. - At least annually, licensees are required to assess the overall- effectiveness of  ;

their maintenance efforts. >

Collection of failure and unavailability information and attendant cause analyses are driven by the frequency and type of failures.

NRC inspectors will be expected to judge the adequacy of each licensee's efforts by the results in terms of acceptability of  !

failure rates and unavailability rates for plant equipment.-

Accordingly, the frequency of collection of data is driven by--

events as well as the existing maintenance schedule for each plant. It is not possible to collect the information less frequently and yet ensure the safety of the public and plant. '

operation.

8. Circumstances Which Justify Variation From OMB Guidelines The maintenance rule does not change any of the existing requirements for records retention. Maintenance surveillance and failure records and data must be retained in accordance with ,

existing plant procedures and requirements. If this results in a need for licensees to retain records for longer than three years, it will result from trends in failures and unavailability of SSCs and not as a result of any specific requirements of the ,

maintenance rule or its proposed implementing guidance. - The ,

adequacy of licensee's efforts will be judged on the basis of acceptability in equipment performance and availability.

Therefore, record retention times will be driven by the needs'of licensees to show acceptable trends.

9, Consultations Outside the AaencY. Information-Concerning the proposal for a maintenance rule was discussed in a public workshop held at the Mayflower Hotel in Washington, C.C. on July ll-13, 1988. On November 28,1988, the Commiulos published for'public comment, a rotice of proposed rulemaking-(53 FR 47822)_on nuclear power plant maintenance programs. In support of-a=previously.

proposed, prescriptive version of the maintenance rule, the Commission also published a draft regulatory guide on_ August 17, '

1989 (54 FR 33988) for-public comment. The-Commission published the final performance-based maintenance rule,10 CFR 5 50.65, on July 10,1991 (56 FR 31306) to take effect on July 10. 1996.

Since-July 10, 1991 the NRC office of Research 3rovided copies'of the Regulatory Analysis' for 10 CFR 5 50.65 to tie public as-described in the Federal Register (56-FR 31320). notice.

The NRC staff has had numerous interactions in public meeti.ngs with NUMARC since the publication of the maintenance rule. In NRC-SECY-92-229, dated June 25, 1992, " Implementing Guidance for'the F

. - - _ ~ - - - . - . - . - - - . - . . . - - - . - - - _ . _ - - - . - . - -

Paintenance Rule,10 CFR 50.65," the NRC staff explained its i approach and described its interactions with NUMARC to the Commission. By a memorandum from S. Chilk, Secretary for the .

Commission to J. Taylor, Executive Director for Operations, dated July 17, 1992, the Commission endorsed the staff's approach.

NRC staff members attended meetings in September-December 1992- l with NUMARC and several licensees who volunteered to participate q in a NUMARC sponsored verification and validation (V&V) effort to I test the NUMARC guidance. The V&V effort was concluded in December 1992. Draft regulatory guidance that outlines the NRC staff's intention to endorse the industry gritance was issued for public comment on November 24, 1992 (57 FR b 286).

10. [on fident i al i ty_.o f In forma tion . None, except for proprietary information, 11, 1qstification for Sensitive Ouestions. No sensitive information  ;

is requested under this regulation.

12. Estimated Annualized Burden to the Federal Government. The NRC already performs maintenance inspections and maintenance evaluations. The maintenance rule will strengthen the basis for-the inspections and evaluations, but will not require additional inspection activities. The focus of the NRC inspections will change but the burden is expected to remain the same as '

previously. Therefore, there will be no increased burden to the Federal government for information collection activities related to the maintenance rule in 6 50.65. -

13. Estimate of Burden. The industry burden is divided into two sub-categories, industry implementation (initial one-time burden) and  ;

industry operating (or continuing) burden.

Lmolementation:

The tasks and associated levels of effort shown 'n i Table I were -i considered (based on the proposed implementation of NUMARC 93-01) as part of the efforts of nuclear power plant licensees for implementation.

Some of these tasks and levels of effort are described in NUMARC 93-01;  :

others are considered to be-inherent _in the implementation of the maintenance rule. .

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TABLE 1 IAA E S RElATED TO_.l!iPLDifiTAT10fl 0F

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! IMPLEMEf1 TAT 1011 ACTIVITY LEVEL OF Eff0RT PER PLANT Documentation of SSC Selection 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, total Process to identify SSCs Under the Scope of the Maintenance Rule (Section 13.2)'

Maintenance Rule Scoping: 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> / system Establish Performance Criteria, Place SSCs Under 550.65(a)(1) or '

(a)(2) and Provide Basis (Section 13.2.1)

Initial Evaluation of 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> / system -

SSC Performance {,

Establish Initial Goals and 425 hours0.00492 days <br />0.118 hours <br />7.027116e-4 weeks <br />1.617125e-4 months <br /> / system Monitoring Criteria for items Placed Under 950.65(a)(1)  ;

It is estimated that on the average 20 systems would be analyzed at each plant. Approximately two-thirds of the burden is attributable to

, information collections. Total burden varies depending on the quality of the current maintenance program and is calculated for marginally satisfactory plants at 100%, satisfactory plants at 88%, and good plants '

at 70% of the following burden calculation: [(175 + 200 + 425 hours0.00492 days <br />0.118 hours <br />7.027116e-4 weeks <br />1.617125e-4 months <br />) x

• 20 systems + 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />) x 2/3 effort attributable to information collections. All burdens listed below are in units of hours.

1

-Cittaaty No. of Burden Total -

Plant.1 ner Plant Rurden Marginally Satisf actory 15 11,390 -170,850 Satisfactory 72 10,050 723,600 ,

Good 23 8,040 184,920 Total-Imolementation Burden: 1,080,000. hours (9,818. hours average per j plant) l

' Refers to sections in l1UMARC 93-01.

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i Section ]3.3 of NUMARC 93-01: Documenta1 ion of P.gtformance against Gl ais. Changes to_.Roll A h panded_Qata Collection. Data Analysis.

Trendina. Casise Analysis, and Procrampl qa,1yJj,1 a All three categories of plants would require additional s+aff for ,

necessary documentation. it was a;sumed that_one additional staff person would spend two-thirds of his time on these information collection activities.

f smber ji , of Plants Burden oer Plant Total Burden ,

110 1,400 155,000 Mc.1jiq 13.4 of_NUMARC 93-01: Documentation of Preventive Maintentqq.q Proaram it was assumed that one-third of a staff person's time would be devoted -

to related information collection activities for satisfactory and good plants. Marginally satisfactory plants would require two-thirds of a staff person's time.

Cateaory No. of Burden Total Plants per 01 ant Burden  ;

Marginally Satisfactory 15 1,400 21,000 .

Satisfactory and Good 95 695 66,000 Total 87,000 Sec tioq_lL}.c of NUMARC 93-01: Periodic Assessments it was assumed that two-thirds of a staff person's time would be needed for information collections associated with feedback and corrective actions.

Number of Plants Burden oer Plant Total Burden 110 1,400' 155,000 I

Total Goeratina Burden: 397,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year (3,609 hours0.00705 days <br />0.169 hours <br />0.00101 weeks <br />2.317245e-4 months <br /> annual average per plant)

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14. Reason for Chance in Burden. These are new requirements for j' which no burden had been previously assessed.  !

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15. Egblication_for Stattitical Use, There will be no publication by

! the NRC of the collected information for statistical use, i

i i B. CotLECll0ft 0F INFORMATI0ff EMPLOYINCLSTATISILCAL METH005  ;

) Statistical methods may be used by licensees for the collection or i analysis of plant information. NRC inspectors are not expected to use i statistical methods in their reviews of licensee documentation. Use of 3

statistical methods is allowed but not required by the maintenance rule

, and its proposed implementing guidance. -

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i NUCLEAR REGULATORY COMMIS$10N Documents Containing Reporting or Recordkeeping.

Requirements: Office of Management and Budget (OMB) Review AGENCY: Nuclear Reguiatory Commission ACTION: Notice of the Office of Management and Budget review of- j information collection. ,

SUMMARY

The Nuclear Regilatory Commission (NRC) has recently submitted to the Office of Management and Budget (OMB) for review the following proposal for the collection of information under the provisions of the Paperwork Reduction Act (44 U.S.C. Chapter 35), j

1. Type of submission, new, revision, or extension: Revision -

2. The' title of the information collection:

10 CFR Part 50.65 - Monitoring the Effectiveness of Maintenance in -

Nuclear Power Plants.

3. The form number if appiicable: Not applicable.

4. How often the collection is required: Collection'is required on a continuing basis as the information becomes available.

5. .Who will be-required or asked.to report: No reporting to-the NRC is required. Holders of an operating license under 10_CFR S 50.21(b) ar 5_50.22 must maintain certain records or data. relating to maintenance... <

6. An' estimate of the total' number of responses: No responses to the NRC aro-required or expected. 110 nuclear power plants will be required-to maintain certain records or data.

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i 7, An estimate of the number of hours needed annually to complete the 1 requirement ce request: 397,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year (3,609 hours0.00705 days <br />0.169 hours <br />0.00101 weeks <br />2.317245e-4 months <br /> average per

. plant ps.r year to maintain records or data) plus a one-time

. implementation burden of 1,080,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> (9,818 hours0.00947 days <br />0.227 hours <br />0.00135 weeks <br />3.11249e-4 months <br /> average per plant) for establishir.g procedures.

8. An indication of whether Section 3504(h), Pub. L.96-511 applies: '

Applicable.

9. Abstract: The Commission amended its regulations in 10 CFR S 50.65.tc require commercial nuclear power plant licensees to it.onitor the effectiveness of maintenance activities for safety significant plant equipment in order to minimize the likelihood of failure and events caused by the lack of effective maintcnance. Licensees are to establish goals for structures, systems, and components (SSCs) covered by 10 CFR:5 S0.65. Thereafter, licensees are to monitor the performance, condition _

L and availability of SSCs to determine the effectiveness of maintenance.- ,

Licensees will be required to periodically evaluate the effectiveness of ,

maintenance activities against established goals, and. maintain records or data of their maintenance, goal setting, monitoring efforts, and )

periodic assessments. No reports to NRC headquarters or regional offices are required.

Copies of the submittal may be inspected or obtained for-a fee from the NRC Public Document _ Room, 2120 t Street, (Lower Level) NW, Washington, DC 20555.

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o Comments and questions can be directed by mail to the OMB reviewer: ,

Ronald Minsk Office of Information and Regulatory Affairs-(3150-0011)

NE08-3019 Office of Management and Budget Washington, DC 20503 Comments can also be communicated by telephone at (202) 395-3084.

The NRC Clearance Officer is Brenda Jo She?'.on, (301) 492-8132.

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Dated at Sethesda, Maryland, this Gday o / 1993, f.

For the Nuclear Regulatory Commission.

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v! ns stud ^d byh_l,

Gerald F. Cdanford, Desi/jnated Sdnior Official for information Resouttes Management i-3 y li -

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