ML20128B456
| ML20128B456 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/1993 |
| From: | Shao L Office of Nuclear Reactor Regulation |
| To: | Minners W NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| FRN-57FR55286, RTR-REGGD-1.160, RTR-REGGD-XX.XXX, TASK-DG-1020, TASK-RE 57FR55286, NUDOCS 9302030066 | |
| Download: ML20128B456 (7) | |
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- l;E January 22,-1993
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MEMORANDUM FOR: Warren Minners, Director Division of Safety Issue Resolution Office of Nuclear Regulatory Research .$
FROM: Lawrence C. Shao, Director Division of Engineering I
w Office of Nuclear Regulatory Research co
SUBJECT:
TRANSMITTAL OF A PROPOSED PUBLIC COMMENT #*
PACKAGE REGARDING IMPLEMENTATION GUIDANCE Q FOR THE MAINTENANCE RULE, 10 CFR 50.65 g The proposed draft Regulatory Guide (DG-1020) and the accompanying Industry Guideline (NUMARC 93-01, Revision 2A, July 9, 1992) for Monitoring the Effectiveness of Maintenance at Nuclear Power Fiants do not explicitly address time dependent age-related degradation in SSC, that are within the overall scope of the maintenance rule. These documents do not provide guidelines for evaluating the effectiveness of maintenance programs to include passive SSC, such as reactor coolant pressure boundary components and other "long lived" components (that may degrade with time and compromise safety and may not experience failures) such as " pipes" and " cables". We believe that these deficiencies can be addressed through the following considerations:
- Risk significant and important* SSC, (generally include "long lived" passive structures and components of interest) should be treated under paragraph (a)(1) of the maintenance rule with established goals to manage age-related degradation.
- "Short lived" active components identified for preventive maintenance and condition monitoring program and treated under paragraph (a)(2) of
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the maintenance rule should be evaluated for maintenance effectiveness to manage age-related degradation.
The inclusion of the aforementioned considerations in the NRC/ Industry Guidelines will help achieve greater harmonization and the integration of the maintenance rule and the license renewal rule.
- determined deterministically and based upon design and operating experience; expert's opinion; existing codes, standards and regulatory instruments.
4 9302030066 930122 PDR REGGD XX.XXX C PDR
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-Warren Minners Ourispecific comments on.the draft R.G. DG-1020 and the Industry Guideline, NUMARC 93-01, are provided in Enclosures 1 and 2 respectively. ;
Please contact Jit Vora of my staff for additional information and/or clarification. He can be reached at 492-3854.
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- t wrence C. Shao, Director Division of Engineering, RES
Enclosures:
As stated cc:- E. Beckjord T. Speis J. Heltemes 9
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o Enclosure 1 Comments on Draft Regulatory Guide DG-1020 Monitoring the Effectiveness of Maintenance at Nuclear Power Plants A. Introduction A.1 Eagg 1. Line 7:
Definition of " effective maintenance" should be included.
A.2 Eage 1. Line 10: Mentions " safety equipment". However, the overall scope of SSC -goes beyond " safety equipment". Recommend consistency.
A.3 Pace 2. Line_2: What is meant by " unacceptably degraded"?
Recommend definition or provide explanation.
B. Discussion B.1 Pace 4. Para _ graph 1:
This-paragraph should be expanded to include-the treatment of passive structures and components associated with the reactor coolant pressure boundary, parameter trending, and maintenance effectiveness to manage age-related degradation effects.
B.2 Paag_5. Lines 2&3: Definition of " safety significance" should be included.
C. Reculatory Position Refer to the comments provided on NUMARC. report # 93-01,-Revision 2A, dated July 9,1992, " Industry Guidelines for Monitoring the' Effectiveness of Maintenance at Nuclear Power Plants." (Enclosure 2)
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- 0. Imnlementation 0.1 Eage 5. Last Line: Revise the last line to read as follows:
" submittal for construction permits, operating licenses, and. license renewal (as appropriate)-
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APPENDIX A-AA.1 Pace A-1. Line 16: Definition of phrase " safety-significant" should be provided.
AA.2 Pace A-1. Line 17:
What is meant by." minimize the likelihood of-failure?" An explanation or definition would be of interest.
AA.3 Pace A-1. Line 33; it is suggested that the performance criteria are to be established-in rare cases at component levels. In real world, for maintenance effectiveness-performance criteria are generally- -
established at component level, especially for fluid-mechanical-systems and for long-lived passive structures and components. Recommend deleting the words "in rare cases."
AA.4 Eage A-5 Lines 20&21: Substitute the word "should" for "could" and delete the words "with some exceptions".
AA.5 Pace A-6. Lines 1111 6.7.&B:
Recommend deleting _the statements (1) "The full....from-the rule and (2) The staff worked closely with NUMARC....would be addressed."
AA.6 Pace A-7. Paraaraph-6.21 Relation to Other Existina or Proposed Reauirements: _
The. Integrated Plant Assessment (IPA) to manage age-related. degradation unique to' license renewal (10_ CFR Part 54) is related to maintenance effectiveness. In order to achieve greater harmonization and the-integration of the maintenance rule and the license renewal _ rule, the following elements-sho.ild be considered for_ inclusion in DG-1020.
-1. Risk significant and other important-structures-(long-lived) and components-(i.e. those identified deterministically-based upon design and operating experience, expert's opinion, existing codes and standards, and.
regulatory instruments) should'be treated under paragraph (a)(1) of the maintenance rule with established' goals to manage age-related degradation.
f: 2, Shurt-lived active components identified for preventive maintenance and condition monitoring program and treated under paragraph (a)(2) of the maintenance rule should be evaluated for mair.tcrance effectiveness to manage age-related degradation.
APPENDIX B AB.1 Eaae B-o. Line 16: add, "and mitigation of age-related degradation."
AB.2 Pace B-9. Line 19:
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add reference to 10 CFR Part 54.3. It is relevant to maintenance.
E.S.4, Pace VI. Figure 1.
Block 9.4.1 (a)(1)
Establish Goals:
Risk significant and important SSC, (generally include "long-lived" passive-structures and components) should be treated under paragraph (a)(1) of the maintenance rule with established goals to manage age-related degradation.
SSC, (generally include "short-lived" active components) identified for preventive maintenance and condition monitoring program (no numbered block above 10.2.1 in Figure 1) and treated under paragraph (a)(2) of the maintenance rule should be evaluated for maintenance effectiveness to manage age-related degradation.
9.3.1, Establishina Risk Sianificant Criteria.
Page 14. Lines 4&5:
Recommend deleting this paragraph.
a
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Enclosure 2
-Comments on Industry Guideline For Monitoring the Effectiveness Of Maintenance at Nuclear Power-Plant NUMARC 93-01. Revision 2A. July 9.1992 -.
Exqc.utive Summary E.S.1, Pace IV. Line 34: after 12.0) add "and mitigation of age-related degradation."
E.S.2, Page VI. Fiaunq l Diamond 9.3 3:
Revise it to read "is condition or performance acceptable?"
E.S.3, Paae IV. Fiqure 1.
Blocks 9.4.4:
Include a footnote that the root cause analysis should include as appropriate, determination of degraded conditions.
E.S.4, Eaae VI. Fiaure 1.
Block 9.3 1:
Supplemental consideration needs to be_ ,
made for inclusion of "long-lived" passive structures and components, such as, reactor coolant pressure boundary SSC,, '
cables and containment penetrations.
Block 9.3.1 should: be expanded to include ,
important SSC, determined deterministically, . "
based upon design and operating experience, expert's opinion, and existing codes and standards and regulatory instruments .
E.S.4, Page VI. Fiaure 1.
Block 9.4.1. (a)(1) Establish GLah:
Risk significant and important SSC, (generally include "long-lived" passive
, structures and components) should be treated under paragraph (a)(1) of the maintenance rule.with established goals to 1 manage age-related degradation. !
SSC, (generally include "short-lived" active-components) identified for preventive maintenance and condition monitoring program (no numbered block above 10.2.1 in Figure 1) '
. =. - - .. . . - -
-and treated under Saragraph_(a)(2) of the maintenance rule siould be evaluated for maintenance effectiveness to manage >
age-related degradation.
9.3.1, Establishino Risk Sjgnificant criteria.
Pace 14. Lines 4&S:
Recommend deleting this paragraph.
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