ML20128F052
| ML20128F052 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/1992 |
| From: | Rothberg O NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Baer R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| NUDOCS 9212080241 | |
| Download: ML20128F052 (21) | |
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NOV 2 51992 lepiW.TLN FDR:
Robert L. Baer, 011cf Engineering Icsues Inarch Division of Safety Issue Resolution Office of liuclear Bcqulatory psamh muc0GH:
Prank 01erny, Section leader B Engincering Issues Bran 1 Division of Safety Issue Resolution Office of !!uclear Regulatory Researt:h FTot4:
Osen Rothberg, Task Manager Engineer 1rg Issues Branch Division of Safety Issue Resolution Office of 11uclear Rcqulatory Researth SUIL7ECT:
RETOPJ OF MEETDIG WITI !DMC AND 11UCLEAR DES'IRY REFRESDEATIVES Off OClOBER 19-21,1992 'IO DISCUSS 11Ut%RC'S VERIFICATIOt1 NID VALIl%TIOli (V&V) PROGRN4 FOR DE DESTRY IMPID4DTI'AT10!! CUIDWCE FOR DE 1RDf1DW3CE IUII (10 CTR 50.65) me:rbers of the NRC staff atterdM meetirgs at On October 19, 20, ard 21,1992, 11UMAIC headquarters with representatives of !GNC, EPRI, Dif0, and several nuclear utilities. 'Ihe purpose of these meetirgs was to continue discussions on the verification ard validation of IURRC'S proposed guidance document, IURRC-93-01, Revision 2A, July 9,1992, " Industry Guideline for Monitorire the Effectiveness of Mair3mance at liuclear Power Plants." Pm/lous noctirgs were held on August 19-20 ard Septenber 29-30.
Please refer to my meetirg reports to you dattd August 27, 1992 and October 20, 1992 respectively.
11UMARC sent a letter to J. SnicIck, DEDO dated October 14, 1992 to outline the V&V prtgram status ard lessons learncd through Septe:rber 25, 1992.
Die meeting agerda sheets are attached in enclosure 1.
Walt Smith of le nRC chaired the rectirg. Although a number of program descriptions ard haMouts were provided for discussion, most of this material was returned to I M ARC by the 11RC participants because it is preliminary and not ready for distribution.
'Ibe recting on the afternoon of October 19 was held for the purpose of discussirg progress on the detemination of risk significance of SSCs by various rethods includirg probabilistic risk assessment (PPA).
Vie discussion of PBA methods to identify risk significant SSCs continued on
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Conclusions were; an understaMing of the PBA nodel is regaired October 20.
by the investigators, there are renenclature problems between the PFA ard maintenance perspectives, ard all methods give "similar" results. - After related discussions of software, expert panels, and the guidance provided r
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g lbbert L. Baer thusfar, the overall conclusion was that "rethod 2," as described in ITJ1%RC We IU%RC 93-01, couplcd with " expert opinion" kould be the best approach.
It was also concluded guidance is to be rodified to reflect this conclusion.that there is a recC to train p rethods.
The participating utility representatives gave renorts on their prcgress inOne identifyirg SSCs within the scope of the rule ard risk significant SSCs.
conclusion is that the chtahwes in the plants are not integrated and are of lirdted capability with respect to identification of perfonynce history at This is minly due to the fact that plant eqaipwnt data is the system level.
ccepiled at the cxrponent level.
Some utility representatives reported that their verification aM validation efforts revealed that actual performnce of the selected systems ard trains Their realizations resulted frtra was much different than had been thought.
havire to evaluate systeWtrain perfomance as opposed to irdividual corponent In two reports presented, both utility representatives noted perforrance.
that paor systeWtrain performnce, taken from an availability perspective, was due to inadequate root cause deteminations of failed equignent ard We licensees detemined resultire inappropriate or ineffective maintemnce.
that this firding was beroficial ard the insights gained from the systeytrain perspective sould give them a much clearer picture of the effectiveness of their raintenance activities.
One Renoval of SSCs from the scope of the mintenance rule was disW.
proposal was to renove SSCs that proved to be "very reliable" over a lorg i
The IRC staff representatives pointed out that the scope of the period.
raintenance rule is fixed by the rule and does not depend on the performnce The renitoring of SSCs, very reliable or otherwise, sculd vary of SSCs.
We rule does not allow renoval of SSC's fram the accordirg to performnce.
scope of the rule unless the SSC is reroved physically from the plant through rodification or the modification results in such a change to the SSC that it no 2orger meets the criteria that placed it in the rule originally.
We reqairerents of the IGRRC guidance with respect to the effect on safety IG RRC 91-of simultaneous renoval of eqaipet from service was discussed.
06, " Guidelines for Industry Actions to Assess Shutdown l'anagement" is referenced in IGRRC 93-01, although this reference has not been reviesed or endorsed by the IRC. We IURRC guidance was discussed ard several charges These changes i
were stggested to mke the guidance clearer and tore useful.
vill be edited and discussed again.
The relationship of the activities undertaken to satisfy the raintenance rule with respect to license renewal was discussed. IR RRC representatives irdicated that they my contact IRC to arrarge a joint meeting on this subject.
1 NOV 2 51992 RoLert L. Baer J A " lessons-learned" report was received from 13U!VJC on 11ovember 20, 1992, 7his report was presented in draft form at the rectiry On Octdrr 19-21.
A copy is attachcd as enclosure 3.
7he next necting is to be on November 16-19, 1992. A copy of the agerda for this noeting, as well as the atterdance list from the October 19-21 meeting, was recently received from IfJMARC and is attached in enclosum 2.
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Owen Rothberg, Task Manager Ergineering Issues Branch Division of Safety Issue Resolution Office of Nuclear Regulatory Researth
Enclosures:
As stated cc: See Next Page A
9 MAINTENANCE V& V AD HOC ADVISORY COMMITTEE Meeting Agenda October 19,1992 200 p.m. to 5:00 p.m.
PECO presentation Peach Bottom risk significant method determination Discussion regarding approaches to identify risk significant systems at Grand Gulf
- input by EPRI, NRC, and Grand Gulf Discussion of other methods used to determine risk significance
. Results of survey on software Comments and disposition regarding proposed changes to industry maintenance guideline risk significance methodology l
Development of task list and schedule for comparing and reporting the results of l
the PRA/ expert panel approaches to risk significance l
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MAINTENANCE V&V AD HOC ADVlSORY COMM17 TEE Mecthg Agenda October 20 and 21,1992 Repon on risk significant comparison methodology L
Review position paper (attached) on the removal of systems from service (11.23) sq'/
Utility participant repons
)
Identify the method to be used for monitoring p:rformance of all systems and structures identified as within the scope of the rule (93.2)
For risk significant systems, define the performance criteria and goals established for selected systems and their bases (933 and 93.4)
Plant level criteria selected and evaluation of trend performance Trend of operating and standby SSC performance over the last six operating quarters and one shutdown period (12.2.2)
Identify SSCs that contributed to the trend (12.2.2)
Assess acceptability of system performance to the trend including effectiveness of cause determination and corrective action (12.23)
Determine if additional goal setting is appropriate Identify all EOP and nonsafety related SSCs and those that are to be deleted from the rule scope and basis (8.2.13)
Performance of selected standby and operating V&V SSCs Identify benefits to be derived from rule implementation in accordance with the industry guideline (quantify)
Identify the cost estimate of implementation (by paragraph)
INPO identify two problem components in each selected system to each utility participant for evaluation of cause of failure and corrective action in accordance with V&V program plan, paragraph 9.4.4. Utility participant to evaluate for generic and common cause failures.
NRC identify 10 examples from its LER database to identify LER performance indicated as maintenance related per V&V program plan, paragraph 9.4.5. Utility.
participants will verify the failures as maintenance preventable functional failures.
Action item closure
Agenda October 21,1992 T[ *
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Removal of systems from the scope of the rule - All o
Simultaneous SSTC removal effects on safety - D. Johnson & G. Czeschin o
Monitoring demand failures - D Worledge o
Counting failures - D Worledge o
Comments on the minutes - All o
Action item review ALL o
SSC Comparison of input to latest computer dump All o
Format for EOP Analysis (T. Jenkms) o Potential changes to Guideline Rev '2a based on lessons learned and other o
reviews and comments Public comment and NRC disposition Internal NRC review including ACRS Risk Significance determination PRA input to expert Panel Clarification of basis for removing SSTC from scope of the rule Clarification of SSCs that perform both an cperating & standby function Definition of standby and operating
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60CLo%tS.E G AHAC FOR V&V OF INDUSTRYMAINTENANCE GUIDE 12NE e
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Meetir4 genda A
Newember 16,17, and 18,1992 November 16,1992 (2:00 p.m. - 6:00 p.m.)
Risk Significant Sub-task Sequoyah results - David Worledge Callaway results - Gary Czeschin Catawba results - Duncan Brewer Millstone results - Tom Galloway Grand Gulf results - Carl Johnson NRC presentation Carl Johnson Proposed rewrite of guideline risk signlucant discussion Summary conclusions and recommendations November 17,1992 (9:00 a.m. - 7:00 p.m.)
November 18,1992 (9:00 a.m.
4:00p.m.)
Summary conclusions from risk signIScant sub task committee Plant Reports 20 Minutes per utDity
- Verification that all gu!deline paragraphs have been addressed Use of qualified expert panel where PRA is incomplete Conclusions Recommendations Overview of at least one system
_ Root cause review of NRC (LERs) and INPO problem component input Plant reports are requested in hardcopy and on 3.5" disk (Wordperfect 5.1) prior to the AHAC Meeting of November 16,1992 f
b Albf C FOR V&V OF INDUSTRY MAINTENANCE GUIDELINE Meeting Agenda (corst;nual)
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November 1617, and 181992 i
l Issoes and poedon papers distributed Monitr42g and goal setting fer Non risk significant repetitive failures Rfek Branch Removal of SSCs from the scope of the Rule - Dan Rains Need for an implementing gu!deline not in regulatory space and the need to expand the guideline document. Dan Rains Normal! zed core damage, sut>-division of systems, use of multiple goah and criteria Dwight Johnson Industrywide experience - Walt Smith Application of shutdown risk considerations to maintenance guldcline (NUMARC 9106)- Jim Enton Recommendations regarding NPRDS application to Rule I
implementation Status of action items - Dan Rains Valfdation of documentation matrix (NUMARC to supply floppy discs)
Schedule of activities to complete r
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h[ITrING A7TENDANCE C m,)
COMMITTEE /SUBCOMMITTEEt Verification & Validation AHAC DATE: Octot>cr 19,1992 TIME: 2:00 p.m-l LOCATION:
Technical Conference Room m -, _ _
NAME ORGANIZATION TELEPHONE David Worledge EPRI (415) 855 2342 Gary Creschin UE - Calla.vay (M4) 676 8430 Earl Page Detroit Edison (313) 586-4266 Howard Whitcomb Detroit Edison (313) 586 1535 Thomas J. Galloway Northeut Utilittes (203) 447 1791 x5042 Greg Kreuger Philadelphia Electric (215)640-6579 Gabor Fodor Northeast utilities 203) 444 5254 Walt Smith NUMARC (202) 872 1280 Dan J Rains NUMARC (202) 872 1230 Owen Rothberg NRC/RES (301) 492 3924 Tom Thurmon Entergy - Orand GtM (601) 437 6792 Tom Stetka NRC (817) 860 8247 Richard CorTela NRC (301) 504 1009 Joseph Solymossy INPO (404) 953 5449 Warren Hall NUMARC (202) 872-1280 Jim Eaton NUMARC (202) 872-1280 Jorge Ramirez (313) 586 13["'
Detroit Edison O
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MEETING MIENDANG
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Verification & Validation AIIAC,,
DATEt October 20,1992 TIME: 9:00 a.m.
LOCATION:
USCEA Board Room om
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NAME ORGANIZATION TELEPHONE jfark Ring NRC/ Region III
__(708) 790 5602 David Worledge EPRI f415) 835 2342 Dwight J. Johnson Entergy Operations, Inc.
'501y64 3208 Gary Creschin UE Callav ry (314) 676 8430 Rick Branch BG&E. Calvert Qiffs (410) 260-4434 Earl Page Detroit Edison (313) 586 4266 (501) 964 8855
{ Ed f upsa entergy Howard Whitcomb Detroit Edison (I13) 586 1535 Romhs J. Galloway Northeast Utilities (203) 447 1791 i
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I Grt.F ifmitger Philadelphin El,otrio_,_
(31f)E40 (f70 Gabor Fodor Northeast utilit;es 203) 444 5254 Tom Stethe NRC/ Region IV (817) 860 8247 WWt Smith NUMARC (202) 872 1280 Dan J. Rains NUMARC (202) 872 1280 (301) 492 3924 Owen Rothberg NRC/RES Ted Je'nkins TU Electric (817) 897 6022 Roger Murgatroyd Florida Power Corporation (904) 795 6486 Gary Sullins Entergy - ANO, Unit 1 (501) 964 6679 Tom Thurmon Entergy - Grand Gulf (601) 437 6792 CP&L (919) 546 3440 Rfchard L Warden Carl Johnson NRC (301) 492 3548
CO.ND.11'ITEE/SUBCOMMI'ITEE:
Verification & Validation AHAC
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DATE: October 20,1992 TIME: 9:00a.m.
I). CATION:
USCEA Board Rwm NAME ORGANIZATION TELEPIIONE
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Richard Conela NRC (301) 504 1009 Joseph Solymossy INPO (4N) 953 5449 Bob Bauman INPO (404) 951 5337 Crelg R. Treubel Entergy - Grand Outi (601) 437 2127 Warten J. Hall NUMARC (202) 872 1280 Jim Enton NUMARC (601 g 2127 I) 6 e
MEF~11NG ATTENDANCE
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7 COhth111 TEE /SURCOMhilTTEE:
Verification & Validation ARAC
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(.I JATE: October 21,1992 TIhtE 9:00 a.m.
LOCATION:
USCEA Board Room
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NAME ORGANIZATION TELEPIIONE l
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Mark Ring NRC/ Region El (708) 790 5602 David Worledge EPRI (415) 855 2342 Dwight J. Johnson Entergy Operations, Inc.
(531) 964 3208 UE. Callaway (314) 676 8430 Gitry Cr.eschin BG&E - Calvert Cliffs (410) 260-4434 Tjick Branch Ed Rogers Entergy (501) 9M 8855 Iloward Whitcomb Detroit Edison _
(313) 585 1535 Thomas J. Gallcway Northeast Ut'lities (203) 447 1791 x5N2 Gabor Fodor Northeast ut!!1 ties 203) 444 5254
' Tom Stetka NRC/ Region IV (817) 86pB247 Walt Smith NUMARC
_(202) 872 1?.80 Dan J. Rains NUMARC (202) 872 1280 Owen Rothberg NRC/RES (301) 492 3924 Ted Jenkins TU Electric (817) 697 6022 Roger Murgatroyd Flor'.da Power Corporation (904) 795 6486 Gary Sullins Entergy - ANO, Unit 1 (501) 964 6679 Tom Thurmon Entergy - Grand Gulf (601) 437-6792-Richard L Warden CP&L (919) 546 3440 f
Carl Johnson NRC (301) 492 3548 Richard CorTela NRC (301) SM 1009 I
INPO (4N) 953 5449 Joseph Solymossy (404) 951 5337 Bob Bauman INPO Craig R. Treubel Entergy - Grand Gulf (601) 437 2127 l
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NUCLEAR MANAGEMENT AND R($OURCES COUNCIL _,
m0 E@wW W. tote XO. wosnroon. CC 20CG$ 370s (202)b72 CSD uma t.twon November 20,1992
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Mr. James H. Snlezek Deputy Executive Director
' Office of Nuclear Reactor Regulation Regional Operations and Research U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Snlezek:
De purpose of this letter is to pro'Ade you with the second interim lessons learned report (Enclosure 1) from the M:dntenance Rule Industry Guideline Verification and Validetion (V&V) program. Also provided is the major project inilestones (Enclosure 2) and the results achieved by the NUMARC V&V Ad Hoc Advisory Committee (AHAC) participants through October 30,1992.
ne V&V program is being implemented by nine units representing all four principal NSSS suppliers with additional participation by EPRI, INPO, NUMARC, an the Nuclear Regulatory Commission. The V&V program was initiated in May 1992 and is scheduled to conclude with a final NUMARC report in December 1992. The next interim lessons learned report is expected to be issued the week of November 30,1992.
The active partLipation of the NRC working group continues to provide meaningful input. We are confident that this involvement will benefit the NRC, the public, and the industry.
'1 Should you have any questions regarding the enclosed information, please contact a
me or have members of your staff contact Warren Hall, Walt Smith,'or Dan Rains.
Sincerely, 3'
h/>l~h Domas E. Tipton TET/DJR:sp Enclosures Dr. Romas E. Murley, NRR cc:
Mr.- Eric S. Beckjord, RES Mr. William T. Russell, NRR -
- Mr. Clemens J. Heltemes, Jr., RES
~ Mr. Richard P. Correia, NRR -
Mr. Hernan Alderman, ACRS
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Enclosurt 1 SECOND INTERlhi 12SSONSLEARNED REPORT OCTOBER 1992 Summary Lessons Leamed/l%+1 cms DncountereA SOME RISK SIGNIFICANT SYSTEMS ARE NOTINCLUDED IN NPRDS Instrument air, considered by some utilities as risk significant,is not currently regoired to be entered into NPRDS and, therefore, data are not available for coroparison.
UTILITY COMPARISONS OFDATA TO SIMILAR NSSS UNITS
' Hic differences among similar NSSS units are predominantly associated with legitimate differences in design, boundary definition, nomenclature, and vintage as opposed to criteria interpretation.
Comparisons between units has been identifled as time intensive.
However, the comparison of more than one NSSS data set can narrow real differences by driving decisions to be rethought against peer questioning.
DATA HISTORYRETRTEVAL The collection and performance analysis of some systems requires a significant amount of data especially when viewed over a number of operating cycles. Preplanning for the impl.: mentation of the rule will be essential to minimizing resource di'<ution. Utilities should consider what data sources will be required for coll:cting on going operational data prior to the rule effective date of July 1996.. The data collected and the collection time period should be suf6cient to allow a basis for dispositioning SSCs to (a)(1) or (a)(2). One utility with generally good data retrieval capability found that gaps in i
document history caused delays and difficulty in the determination i
of the cause of outages.
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Y7 MODIFICATION OF DATA SYSTEMS TO PROVIDE SYSTEM / TRAIN FOCUS Utility participants indicated many data systems are in existence that emphasize component level data collection. This focus does not adequately reinforce the evaluation of trends at the system and/or train performance monitoring level. This is true because failures at the component level do not necessarily result in an unacceptable loss of function. Additionally, many data bases appear to supply overlapping data as well as ornit data that is needed. Some utilities consider the change in their data systems to be mandatory to meet the performance monitoring aspects of the rule. It appears that these moditications can be rJgnificant in some cases and minor in others, for example:
A primary lesson learned by one utility participant was the inadequa:y of any single plant data base to provide the necessary information to perform evaluations.
A common equipment reference at the system /sub system / function level appears to be needed so that all groups impacted by the Maintenance Rule (PRA, OPS, ENG, etc.) are speaking a " common language."
Need to track data requirements to existing organizational functions to clarify requirements, eliminate redundancy, and ensure completeness.
The current system hierarchal stmeture must be rearsessed to allow.
improved scoping. Logical subdivision of the current systems list from the top down could allow for the number of implied in scope components to be reduced. This approach would be preferable t'o screening each component individually against all criteria. Revising the RCM system selection and boundary definition process based on V&V insights appears necessary.
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1 events like this accentuate the need for good root cause analysis and documentation to support system performance reviews.
DATA IWTIUD'AL TO SUPPORT REPETITIVE FAILURE DETERMINATION
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One utility indicated that the identification of repetitive failures required a data base to be established to accumulate this information. Several other utilities have also identified the need to establish special data bases for this purpose.
NO BENEFlT IN COST AVOIDANCE FOR SOME UTILJTIES Direct significant savings in power replacement costs due to improved maintenance as a result of the Malatenance Rule are not expected at some utilities because of the existing effectiveness of their programs. However, initial costs to implement the rule will be incurre<! because of the generic application of the rule.
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f IbfPROVED APPLICATION OF RESOURCES Identification of risk significant systems v.ill provide better focus for maintenance resources and improved scheduling. His improvement in redirecting resources under some RCM progrann has reduced, added, and modified maintenance programs. Although untested, this redirection of resources is expected to improve perfonnance.
POTENTIAL APPLICATION 10 LICENSE RLNDVAL The potential exists for taking credit for hiaintenance Rule performance monitoring to reduce prescriptive Ucense Renewal requirements. Demonstrated performa'.cc and risk r.ignificance determination could reduce the need for unnecessary analytical justification of aging mechanisms.
OPPORTUNITY FOR TESTING SCOPE REDUCTION Early reported results of the V&V participants indicate that many valves and penetrations that are locally leak rate tested have not failed since 1985 and as such, based on the performance aspects of the Maintenance Rule, testing frequency could be extensively reduced.
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Enclosurr 2 MAIN 7ENANCE VERIFICATION AND VALIDA710N PROGRAM PLA AND COST ESTIMATING BASELINE MALOLLPliDIECT MILFHOEM1TA11LS October 1992 litaintulhialorficatiLY&V Procram Identify all structures. systems, and components (SSCs) that are witida the scope 1.
of the Maintenance Rule. (Complete)
Compare the selected SSCs between common NSSS participants and assure t 4-2.
differences are valid. (In Process)
Compare the selected SSCs between all participating plants and assure the 3.
differences. (In Proecss)
Identify the method for identifying risk significant criteria for the selection of risk 4.
significant SSCs. (Complete Will test PRA and Expert Panel methods and identify observations relative to the use of reliability approaches to maintenance
' Identify the criteria selected for the determination of risk significant SSCs.
5.
(Complete)
Establish plant level criteria and target trends. (In Process) 6.
Identify and verify the methodology for evaluating the performance of standby 7.
systems that are risk significant or non risk significant. (In Process)
Develop the criteria for the selection of the SSCs that the V&V program will 8.
address and recommend a candidate list. (Complete)
Select the SSCs that will be addressed in the V&V program. Note that only a sample of SSCs will be selected with results extra;x> lated to all SSCs. (Com 9.
Identify all SSCs included in EOPs. (In Process) 10.
Identify EOP categories to be recommended.(or deletion from the scope of the Maintenance Rule. (See lessons learned / problems encountered, September 1992 11.
Evaluate the performance (over the last three refueling cycles) of risk and non-12.
risk significant SSCs that are normally in the standby mode and establish the ty 4
and value of goals that are appropriate. (In Process)
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_Malor Protect Milestones Interim lessoas learned reports September through November 1992 Reg Guide issued in Federal Register November 1992 for public comment i
Completion bf industry V&V program December 1992 NRC receipt of public comments January 1993 NRC resolution of public conunents March 1993 Present ACRS/CRGR package - resolve May 1993 comments Reg Guide issued by Federal Register June 1993 notice NUMARC sponsored workshops July / August 1993 NRC pilot inspection program 1994 1995 Industry full implementation July 1996 Future Aethitln V&V program scheduled for completion December 1992.
Public comments on NRC Regulatory Guide to be provided in January 1993.
Based on V&V results/ industry input:
Revise guidance where appropriate; and Suggest (or petition) changes to Maintenance Rule.
Program must be implemented in sufficient time to meet the full implementation date July 10,1996.
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COMMrTTEE/ SUBCOMMITTEE:
Verification & Validation AHAC ns DATE: October 21,1992 TIME: 9:00 a.m.
LOCATION:
USCEA Board Room NAME ORGANIZATION TELEPHONE Wanen J. Hall NUMARC (202) 872 1280 I
NUMARC (202) C721280 J
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