Text

Insp Repts 50-361/96-14 & 50-362/96-14 on 961020-1115.No Violations Noted.Major Areas Inspected:Maint,Summary of Plant Status,Insp Scope & Observations & Findings
	ML20135D682
Person / Time
Site:	San Onofre
Issue date:	12/06/1996
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20135D674	List: ML20135D671; ML20135D682;
References
	50-361-96-14, 50-362-96-14, NUDOCS 9612100090
	Download: ML20135D682 (41)
	v • d • e

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ENCLOSURE ,

U.S. NUCLEAR REGULATORY COMMISSION I

REGION IV .;

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Docket Nos.: 50-361 l

50-362

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Licensa Nos.: NPF-10

NPF-15

Report No.: 50-361/96-14 ,

50-362/96-14

Licensee: Southern California Edison Co.

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Facility: San Onofre Nuclear Generating Station, Units 2 and 3

Location: 5000 S. Pacific Coast Hwy.

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San Clemente, California

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Dates: October 20 through November 15,1996 I

Inspectors: C. J. Paulk, Reactor Inspector i

Maintenance Branch

J. E. Whittemore, Reactor Inspector

, Maintenance Branch

j Approved By: Dr. Dale A. Powers, Chief, Maintenance Branch

Division of Reactor Safety

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Attachment: SupplementalInformation

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9612100090 961206

PDR ADOCK 05000361

O PDR

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EXECUTIVE SUMMARY

San Onofre Nuclear Generating Station, Units 2 and 3

NRC Inspection Report 50-361/96-14:50 362/96-14 l

During a review of the " Monthly Maintenance Rule Program Performance Update for

Risk-Significant Systems," issued on August 19,1996, the resident inspector identified

approximately 15 structures, systems, or components that had not met the licensee

established performance criteria. An unresolved item was opened for NRC followup on this l

issue. This specialinspection was conducted to evaluate the unresolved item. )

Maintenance

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The f ailure to set goals and monitoring requirements for 13 structures, systems, or l

components that exhibited performance at levels less than the established i

performance criteria is an apparent violation of 10 CFR 50.65(a)(1)(Section M1.1). l

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The failure to establish performance criteria for the control room smoke exhaust '

system is an apparent violation of 10 CFR 50.65(a)(2)(Section M1.1).

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The f ailure to demorstrate that the use of standard performance criteric of two

functional failures over two fuel cycles for reliability consistent with the

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assumptions of the probabilistic risk assessment is an apparent violation of 10 CFR

50.65(a)(2). (Section M1.2). .

j An assessment of the Maintenance Rule program and implementation of goal setting

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evaluations was thorough and in-depth for the failure to document goals. However,

the assessment did not address the fact that adequate goals and monitoring

requirements were not established prior to July 10,1996, as required by the

Maintenance Rule (Section M7).

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Report Details I

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j Summary of Plant Status

i ?,oth units were operating at full power during the inspection period. j

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. II. Maintenance

M1 Conduct of Maintenance (62706 and 92902)

M 1.1 Maintenance Rule Goal Settina

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i During a review of the monthly " Maintenance Rule Program Performance Update for

? Risk-Significant Systems," issued on August 19,1996, the resident inspector

l identified approximately 15 structures, systems, or components that had not met

j the licensee established performance criteria. An unresolved item was opened for

NRC followup on this issue. This specialinspection evaluated the unresolved item.

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a. Insoection Scope

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The inspectors reviewed the following documents to determine if performance goals

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and monitoring requirements had been established for those structures, systems,

i and components identified in the licensee's July 10 and August 19,1996, monthly

! status reports as either failing to meet the performance criteria or as having a trend

[ that would result in failure to meet the performance criteria before the next

evaluation period

l * 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants;"

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Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at%

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Nuclear Power Plants," Revision 1;

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l * NUMARC 93-01," Industry Guideline for Monitoring the Effectiveness of l

l Maintenance at Nuclear Power Plants," Revision 0;

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i' * SO123-XV-5.3," Maintenance Rule Program implementation," Revision 0,

TCN 0-3;

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j * SO123-XIV-5.3.2," Determination of Maintenance Rule Performance I

l Criteria," Revision 0;

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SO123-XIV 5.3.6," Goal Setting for the Maintenance Rule," Revision 0; the

San Onofre Nuclear Generation Site's " System Engineer's Notebook for the

Maintenance Rule"; and,

a the action requests listed in the attachment,

b. Observations and Findinas

The inspectors noted that most of the action requests, which were completed after

July 10,1996, contained Maintenance Rule evaluations which determined if

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performance goals and monitoring requirements should be set for systems,

I structures, and components whose performance was below the licensee established

performance criteria. Within several of the documents reviewed, the inspectors

observed statements that indicated that the performance goals were to regain

satisf actory performance by eventually meeting performance criteria as

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demonstrated through normal operation, surveillances, and preventive maintenance '

activities. While acknowledging that the ideal was to always have performance at ,

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levels that met or exceeded the performance criteria, the inspectors noted that, as

, discussed in joint NRC and industry forums, when performance dropped below the

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performance criteria, corrective actions were to be taken to correct the cause and

prevent recurrence, in order to accomplish that end, performance goals and

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monitoring requirements were to be established commensurate with safety to

measure the effectiveness of the corrective actions and to demonstrate, within a

certain time period, that the root causes were corrected.

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Through discussion with licensee representatives, the inspectors noted that the

licensee staff considered that the re-achieving performance by meeting the

previously established criteria was a satisfactory goal under 10 CFR 50.65. The

inspectors also determined that performance goals and monitoring requirements

which met the requirements of 10 CFR 50.65 were eventually established, but were

characterized as performance thresholds. The inspectors noted that the licensee

had not documented any performance goals or monitoring requirements in

accordance with 10 CFR 50.65 prior to July 10,1996. The inspectors found that

the only documentation of performance goals and monitoring requirements that met

the requirements of 10 CFR 50.65 were in corrective action documents (action

requests) or in evaluations in support of the action request activities, which were

not established prior to July 10,1996,

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During a debriefing session on October 25,1996, with licensee management and

supervision having 10 CFR 50.65 responsibilities, the inspectors explained the

requirements for goal setting in accordance with 10 CFR 50.65 and

NUMARC 93-01. The licensee subsequently submitted additionalinformation in the

October 31,1996, letter and attachments (see Section M8.3). The licensee

expressed the opinion that no violations had occurred; they were only untimely in

documenting the goals.

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The following discussion addresses those systems and components identified in the

unresolved item.

b.1 Unit 2 Turbine-Driven Auxiliary Feedwater Pumo

On June 25,1996, the licensee representative identified that the Unit 2

steam turbine-drivr;n auxiliary feedwater pump had experienced three

repetitive functioaal failures during the last 3 years. This performance did

not meet the cr8t eria of less than three functional failures or three repetitive

failures within a monitoring period. Because the turbine-driven auxiliary

feedwater pump was included in the scope of 10 CFR 50.65, the licensee

initiated Action Request 960601178to evaluate the failures to determine if

goal setting, in accordance with 10 CFR 50.65(a)(1), was required.

The inspectors noted that the action request was closed on August 28,

1996, on the basis of reaching a determination that goal setting was not

required because only two functional failures were related and the problem

source had been corrected. However, on September 13,1996, after the

resident inspectors identified the unresolved item associated with the f ailure

to establish adequate performance goals and monitoring requirements, the ;

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failures were reevaluated and the licensee determined that the train would be

placed in goal setting as required by 13 CFR 50.65(a)(1). Subsequently, a

component-specific goal (applicable to the trip and throttle valve) that no

additional f ailures occur within one year of the last f ailure was established.

The inspectors found that the failure to set goals and monitoring l

requirements for the Unit 2 steam turbine-driven auxiliary feedwater system

prior to July 10,1996, was an apparent violation of 10 CFR 50.65(a)(1)

(50-361/9614-01:50-362/9614-01). The inspectors also found that the

licensee established the required goals and monitoring requirements on

September 13,1996.

b.2 Unit 3 Safety Iniection Tanks

On July 23,1996, the licensee identified that the Unit 3 safety injection

tanks had been unavailable for 47.99 hours0.00115 days <br />0.0275 hours <br />1.636905e-4 weeks <br />3.76695e-5 months <br />. This exceeded the availability I

performance criterion, and a Maintenance Rule evaluation was required to be

performed. The licensee initiated Action Request 960700871 to develop a

root cause for the undesirable performance and to develop corrective actions

to return the tanks to an acceptable level of performance. The licensee also

identified the tanks as candidates for goal setting in accordance with

10 CFR 50.65(a)(1).

The inspectors noted that the licensee had been calculating availability using

data obtained in an operations procedure for filling the tanks. The calculation

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included the time required to obtain chemist,y samples. The inspectors ,

noted that the licensee determined that including the time for sampling in the

l calculation was not reasonable. As a result, the licenset recalculated the

! availability and concluded that the Unit 3 safety injection tanks satisfied the

availability performance criterion.

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The inspectors found that the licensee properly evaluated and resolved the

question of the availability of the Unit 3 safety injection tanks.

l b.3 Site Diesel-Driven Fire Water Pumo SA2301MP220 1

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l On June 26,1996, the licensee identified that Site Diesel-Driven Fire Water )

j Pump SA2301MP220did not meet its reliability performance criterion as a

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, result of three functional failures during the monitoring period. The separate

events were characterized as failure of the diesel to start on demand for

different reasons. The licensee recognized that the pump may be required to

l be in goal setting, as required by 10 CFR 50.65(a)(1), and initiated Action

Request 960601201 to evaluate the failures.

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The inspectors noted that, according to the action request, on August 16,

1996, the licensee determined th.at goal setting was not required because

the causes of the failures had been determined and corrected. The

inspectors also noted that, on September 17,1996, the licensee determined

that the fire water pump required monitoring and goal setting in accordance

with 10 CFR 50.65(a)(1). The licensee established a performance threshold

(goal) of zero failures to start for the weekly auto-start test through

December 1996.

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l The inspectors found that the failure to set goals and monitoring

requirements for the Site Diesel-Driven Fire Water Pump SA2301MP220 prior

to July 10,1996, was an apparent violation of 10 CFH 50.65(a)(1)

(50-361/9614-01:50-362/9614-01). The inspectors also found that the

licensee established the required goals and monitoring requirements on

September 17,1996.

b.4 Site Electric-Driven Fire Water Pumo SA2301MP222

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On June 28,1996, the licensee determir.ed that the Site Electric-Driven Fire

Water Pump SA2301MP222 failed to meet its availability performance )

criterion of 90 percent. The licensee considered the pump to be in goal

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setting, in accordance with 10 CFR 50.65(a)(1), and initiated Action

i Request 960601362to determine the cause of the pump not meeting its

, availability performance criterion, develop appropriate L.orrective action to

! return it to an acceptable performance level, to establish a period over which

i the performance would be returned to an acceptable level, and to establish

what monitoring would be done to assure satisfactory recovery.

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The inspectors noted that the failure to meet the availability performance

criterion was due to an extended work scope during the annual work

window. Specifically, when the pump was removed for an overhaul, the

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preventive maintenance activities that the licensee deemed necessary

, resulted in a significantly increased work scope.

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On August 15,1996, the licensee initiated, and completed, a Maintenance .

Rule evaluation for this component. The inspectors noted that the licensee

established a goal to meet or exceed the performance criterion over

4 quarters. The inspectors also noted that the pump's availability

performance criterion had been met by the time the Maintenance Rule !

j evaluation was written; however, the licensee intended to continue '

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monitoring the pump's performance in accordance with 10 CFR 50.65(a)(1)

until the next annual maintenance window.

The inspectors found that the f ailure to set goals and monitoring

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requirements for the Site Electric-Driven Fire Water Pump prior to July 10,

1996, was an apparent violation of 10 CFR 50.65(a)(1)(50-361/9614-01;

, 50-362/9614-01). The inspectors also found that the licensee established

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the required performance goals and monitoring requirements on August 15,

1996.

1 b5 East Fire Water Pumo S1-FPW-G-11S

On July 10,1996, the " Maintenance Rule Program Performance Update for

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Risk-Significant Systems (2096)" indicated that the East Fire Water Pump

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had an availability of 84.5 percent over a 4-quarter period. This availability

failed to meet the availability performance criterion of 90 percent. On

July 24,1996, the licensee identified the 4-quarter availability of

84.5 percent met the goal setting requirements of 10 CFR 50.65(a)(1), and

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initiated Action Request 960700894to determine the cause of the

unavailability and to develop a plan to correct the performance.

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On July 24,1996, the licensee initiated a Maintenance Rule evaluation for

the east fire water pump. On September 25,1996, after the resident ;

inspectors identified the unresolved itern associated with the failure to

establish adequate performance goals and monitoring requirements, the

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licensee completed the Maintenance Rule evaluation. The licensee

l determined that the cause of the low availability was an extended work

. scope during its annual maintenance window. The licensee established a

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monitoring goal that the east fire water pump would re-achieve the

availability criterion of 90 percent over 4 quarters after the next annual

maintenance window,

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The inspectors found that the failure to set goals and monitoring

requirements for the east fire water pump prior to July 10,1996, was an

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apparent violation of 10 CFR 50.65(a)(1). The inspectors also found that the

j ' licensee established the required performance goals and monitoring

re,quirements on September 25,1996,

i- b.6 Wetoioe Valve for Unit 3 Intake Structure Saltwater Coolina Tunnel

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l On July 10,1996, the " Maintenance Rule Program Performance Update for

Risk-Significant Systems (2096)" indicated that the wetpipe valve for Unit 3

intake structure saltwater cooling tunnel fire suppression system failed to

meet its availability performance criterion. On July 24,1996, the licensee

, identified the 4-quarter availability of 89 percent potentially met the l

l goal-setting requirements of 10 CFR 50.65(a)(1), and initiated Action '

l Request 960700895 to determine the cause of the unavailability and to

i develop a plan to correct the performance.

On July 25,1996, the licensee initiated a Maintenance Rule evaluation for

l the Unit 3 valve. On September 23,1996, after the resident inspector j

identified the unresolved item associated with the failure to establish

adequate performance goals and monitoring requirements, the licensee

completed the Maintenance Rule evaluation. The licensee determined that

the cause of the low availability was the sprinkler system being impaired

l while work was being performed on Salt Water Cooling Pump 3P-112.

The inspectors found that the inclusion of the time that the sprinkler system

was not required caused the apparent low availability. The inspectors found

that this system was not required to have been in 10 CFR 50.65

l Category (a)(1).

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l b.7 Control Room Comolex Smoke Exhaust System

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On June 26,1996, the licensee determined that the control room complex

l smoke removal system had not met the required reliability performance

l criteria because of three failures of dampers to reposition on receipt of 3

demand (test) signals. The licensee recognized that the system may be l

required to be in goal setting in accordance with 10 CFR 50.65(a)(1) and )

initiated Action Request 960601224to determine if monitoring goel setting )

was necessary.

On July 26,1996, the action request was closed without written

explanation. On September 20,1996, after the resident inspector identified ;

the unresoled item associated with the failure to establish adeq Jate goals

and monitorina requirements,ihe licensee's expert panel reclassitied the

! control room complex smoke. removal system from a risk-significant

l emergency systern to a nenrisk-significant normal (nonemergency) system.

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Therefore, the sys;em was categorized as (a)(1) for the perit,d July 10

! through September 20,1996, without the performance goals and monitoring

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requirements required by 10 CFR 50.65(a)(1). Additionally, the performance

! monitoring criteria required by 10 CFR 50.65(a)(2) was not provided for the

period September 20 through October 25,1996.

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The inspectors learned, from the meeting minutes, that the licensee was

considering an option to abandon in-place the control room complex smoke

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exhaust system and rely on the control room emergency ventilation system

j for smoke removal. The inspectors did not identify smoke removal

capabilities as part of the design features of the control room emergency

, ventilation system during a review of the Updated Safety Analysis Report.

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The inspectors found that the failure to set goals and monitoring

requirements for the control room complex smoke exhaust system prior to

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July 10,1996, was an apparent violation of 10 CFR 50.65(a)(1)

(50-361/9614-01:50-362/9614-01). Additionally, the inspectors found that

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the failure to provide performance criteria for the control room complex

smoke exhaust system after reclassifying the system as low risk-significant

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was a violation of 10 CFR 50.65(a)(2)(50-361/9614-02:50-362/9614-02).

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b.8 Units 2 and 3 Main Steam Safety Relief Valves

The inspectors observed that the licensee's July 10 and August 19,1996,

Maintenance Rule Monthly Status Reports identified that the Unit 3 main

] steam safety relief valves had not met their reliability performance criteria

l due to repetitive functional failures. The monthly status reports did not

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indicate any failures of the Unit 2 main steam safety relief valves for the past

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12 quarters.

The inspectors noted that, on July 3,1996, the licensee initiated Action

Request 960700160,which indicated a total of five functional failures had

occurred on both units over the past 3 years. The failures were all

characterized as failing to lift within the Technical Specification required

setpoint range. The action request was initiated to determine the cause of

the f ailures and identify appropriate corrective action. l

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The inspectors noted that, on July 18,1996, the initial Maintenance Rule

i evaluation was closed. This evaluation indicated that the combination of

i expanding the Technical Specification allowed setpoint deviation, and

overhauling or replacing affected valves was considered to be adequate

corrective action. The inspectors noted that no performance goals or

monitoring requirements were established. ;

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l The inspectors noted that, on August 28,1996, the licensee initiated

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another Maintenance Rule evaluation, which was completed on

] September 18,1996. The inspectors observed that the licensee established

} a " goal" to re-achieve the performance criterion for functional failures.

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Additionally, the licensee established a performance threshold (goal) of

zero failures for both units' valves daring the next two refueling outages.

The inspectors found that the failure to set goals and monitoring

requirements for the main steam safety relief valves prior to July 10,1996,

was an apparent violation of 10 CFR 50.65(a)(1)(50-361/9614-01;

50-362/9614-01). The inspectors also found that the licensee established

the required performance goals and monitoring requirements on

September 25,1996.

b.9 Unit 2 Core Protection Calculator / Control Element Assembly Calculator.

Channel A

On July 2,1996, the licensee determined that the Unit 2 Core Protection

Calculator / Control Element Assembly Calculator, Channel A, failed to meet

its performance criteria of less than five functional failures in 36 months and

an availability of 98 percent. The licensee considered the channel to be in

goal setting in accordance with 10 CFR 50.65(a)(1) and initiated Action

Request 960700066to determine the cause of the channel not meeting its

availability performance criterion, develop appropriate corrective action to

return it to an acceptable performance level, to establish a period over which

the performance would be returned to an acceptable level, and to establish l

what monitoring would be done to assure satisf actory recovery.

The inspectors noted that the failure to meet the performance criteria was

due to the intermittent f ailure of one component on a circuit board. The !

intermittent problem was seen by the software as a channel trip which was 1

not recoverable by the software. As a result of the intermittent f ailures, the

required maintenance activities caused the availability to drop to

97.4 percent for the 36 months. The inspectors noted that the licensee

identified the failing circuit board and replaced it on April 2,1996.

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On August 12,1996, the licensee completed a Maintenance Rule evaluation

which concluded that the channel had "not had intermittent failures [since

April 1996) . . . The performance of the channel has been improved. l

Availability goal > 99% is expected by January,1997."

On September 20,1996, after the resident inspector identified the ,

unresolved item associated with the f ailure to establish adequate l

performance goals and monitoring requirements, the licensee initiated, and

completed, another Maintenance Rule evaluation for this system. The

inspectors noted that the licensee established a goal to meet or exceed the

performance criterion. To meet that goal, the licensee documented that the

Unit 2 Core Protection Calculator / Control Element Assembly Calculator,

Channel A, would not experience any failures, of the type previously

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experienced, in the next 24 months. Attaining that goal would result in less

than 5 functional failures and an availability of greater than 98 pe. cent.

The inspectors found that the failure to set goals and monitorir.g l

requirements for the Unit 2 Core Protection Calculator /Contro' Element

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Assembly Calculator, Channel A, prior to July 10,1996, was an apparent

violation of 10 CFR 50.65(a)(1) (50-361/9614-01:50-362/9614-01). The

inspectors also found that the licensee established the required performance

, goals and monitoring requirements on September 20,1996.

b.10 Unit 2 Core Protection Calculator. Channel D

On June 28,1996, the licensee determined that the Unit 2 Core Protection

Calculator, Channel D, failed to meet its availability performance criterion of

98 percent. The licensee considered the channei to be in goal setting in

accordance with 10 CFR 50.65(a)(1) and initiated Action

Request 960601359to determine the cause cf the channel not meeting its

availability performance criterion, develop appropriate corrective action to

return it to an acceptable performance leve', to establish a period over which

the performance would be returned to an r.cceptable level, and to establish

what monitoring will be done to assure sotisfactory recovery.

The inspectors noted that the failure tr. meet the availability performance

criterion was due to a temperature inreut from a reactor coolant cold leg that

had spiked low. The licensee traced the problem to a resistance temperature

detector that had moisture in the termination head causing low resistance

readings. The inspectors noted that the licensee took actions to correct the

moisture problem.

On July 1,1996, the licensee '.:ompleted a Maintenance Rule evaluation that

concluded that the investigat!on required the channel to be in bypass for a

period of time, effecting the availability of the channel. ' The inspectors noted

that the licensee concluder; that the availability goal was expected to be met

by January 1997. .

On September 16,1993, after the resident inspector identified the

unresolved item assoc.ated with the failure to establish adequate

performance goals ar,d monitoring requirements, the licensee initiated, and

completed, another Maintenance Rule evaluation for this system. The

inspectors noted that the licensee established a goal to meet or exceed the

performance criterion. To meet that goal, the licensee documented that the

Unit 2 Core Prot' action Calculator, Channel D, would not experience any

primary coolant resistance temperature detector failures due to a

low-resistance ground in the termination head for 1 year following the ninth

operating cycle.

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The inspectors found that the failure to set goals and monitoring ;

requirements for the Unit 2 Core Protection calculator, Channel D, prior to

July 10,1996, was an apparent violation of 10 CFR 50.65(a)(1)

(50-361/9614-01:50-362/9614-01). The inspectors also found that the

licensee established the required performance goals and monitoring

requirements on September 16,1996.

b.11 Unit 2 Excore Nuclear Instrumentation Loa Power, Channel D

! On June 28,1996, the licensee identified that the Unit 2 Excore Nuclear

Instrumentation Log Power, Channel D, exceeded its performance criteria as !

a result of experiencing seven random functional failures, six repeat l

functional failures, and an availability of 86.2 percent. The licensee j

l considered the channel to be in goal setting in accordance with j

10 CFR 50.65(a)(1) and initiated Action Request 960601337to develop a

l plan to correct the problems with the excore channel, to develop "a

monitoring program (i.e., with documentation) that will demonstrate that

performance is improving over some appropriate time period," to develop a

plan to return the channel to an acceptable performance level, and to

l establish a period over which the performance would be returned to an

l acceptable level.

On September 17,1996, the licensee initiated and completed a Maintenance

Rule evaluation. The licensee documented that the cause of the failures was

most likely the failure of the first-stage amplifier due to a high-energy

transient in the circuit. The inspectors noted that the licensee had

established a goal of no failures of sub-channel linear-gain circuit cards, in

either unit, due to high energy transients over a 12-month period beginning

July 1996. The inspectors considered this " goal" to be ineffective because

there were no means for detecting whether or not the circuit cards had

experienced any high energy transients.

The inspectors found that the f ailure to set goals and monitoring

requirements for the Unit 2 Excore Nuclear Instrumentation Log Power,

Channel D, prior to July 10,1996, was an apparent violation of

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10 CFR 50.65(a)(1)(50-561/9614 01:50-362/9614-01).

l b.12 Unit 3 Excore Nuclear Instrumentation, Channel A

On June 28,1996, the licensee identified that Unit 3 Excore Nuclear

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Instrumentation, Channel A did not meet its availability criterion due

to a detector failure. The licensee considered the char.nel to be in goal

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setting in accordance with 10 CFR 50.65(a)(1) and initiated Action

Request 960601338to determine the cause of poor performance, develop

necessary corrective actions, and determine the length of an improvement

period.

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rhe inspectors noted that the root cause was a gas leak into the detector

through the electrical insulator of the mineral-insulated cables. The licenne

took corrective actions to stabilize the detector output and implemehr #

enhanced monitoring. The licensee intended to replace the detector during

- the ninth refueling outage. The inspectors also noted that, on August 15,

1996, the licensee established a goal of zero failures due to the identified

cause of the detector failure for a fuel cycle, or about 20 months.

The inspectors found that the failure to set goals and monitoring

requirements for the Unit 3 Excore Nuclear Instrumentation, Channel A prior

to July 10,1996, was an apparent violation of 10 CFR 50.65(a)(1)

(50-361/9614-01:50-362/9614-01). The inspectors also found that the

licensee established the required performance goals and monitoring

requirements on August 15,1996.

b.13 Unit 3 Containment Purae Isolation Sianal Radiation Monitor. Channel B

On June 28,1996, the licensee determined that the Channel B monitor for

the Unit 3 Containment Purge Isolation Signal was not meeting the

availability performance criterion of 96 percent. The licensee considered the

monitor to be in goal setting in accordance with 10 CFR 50.65(a)(1) and

initiated Action Request 960601351 to determine the cause of the channel

not meeting its availability performance criterion, develop appropriate

corrective action to return it to an acceptable performance level, to establish

a period over which the performance would be returned to an acceptable

level, and to establish what monitoring would be done to assure satisfactory

recovery.

On October 18,1996, the licensee's Maintenance Rule Program Expert Panel

reached a conclusion that the monitors were no longer risk significant on the

basis of not being included in the probabilistic risk assessment model and not

being considered a source of elevated risk for core damage or a large

radiological release. Upon changing the risk-significance classification to

nonrisk-significant, the monitor was placed in 10 CFR 50.65 Category (a)(2).

. The inspectors noted that the licensee gave the Reliability Engineering Group

30 days to review the applicability of plant level performance criteria or to

provide performance criteria capable of verifying the effectiveness of the

preventive maintenance for the components.

The inspectors found that the licensee's failure to set gtals and monitoring

requirements for the Unit 3 Containment Purge Isolation Signal Radiation

Monitor, Channel B, prior to July 10,1996, was an apparent violation of

10 CFR 50.65(a)(1)(50-361/9614-01:50-362/9614-01). Additionally, the

inspectors found that sufficient information was not available to evaluate the

licensee's actions with respect to establishing performance criteria for the

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Containment Purge Isolation Signal Radiation Monitors; therefore, this is an

j inspection followup item (50-361/9614-03:50-362/9614-03). I

b.14_ Unit 3 Fuel Handlina Buildina isolation Sional Radiation Monitor, ;

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Trains A'and B

On July 11,1996, the licensee determined that the Unit 3 Fuel Handling

Building Isolation Signal Radiation Monitor, Trains A and B, did not meet the

availability performance criterion of 97 percent for both monitors._ The

licensee considered the monitors to be in goal setting in accordance with

10 CFR 50.65(a)(1) and initiated Action Request 960700430to determine

the reason for the failure to meet the criterion, and initiate corrective action.

The Maintenance Rule evaluation initiated by the corrective action program

stated that goals were established. However, the inspectors did not identify

any specific performance goals or monitoring requirements documented in

the action request, evaluation, or in the licensee's Maintenance Rule

equipment data base. On October 18,1996, the licensee's Maintenance

Rule Program Expert Panel reached a conclusion that the monitors would be

classified as nonrisk-significant except during movement of irradiated fuel in

the fuel building. The inspectors noted, or. the basis of the minutes of a

meeting of the expert panel on October 18,1996, that the panel's

conclusion was reached on the basis that the monitors were not included in

the probabilistic risk assessment model and not considered a source of

elevated risk for core damage or a large radiological release.

Upon changing the risk-significance classification to nonrisk-significant, the

monitors were placed in 10 CFR 50.65 category (a)(2). The inspectors noted

that the licensee maintained an availability monitoring criteria that would

apply only during those times that the monitors were required to be operable

to support fuel movement.

The inspectors found that the failure to set goals and monitoring

requirements for the Unit 3 Fuel Handling Building isolation Signal Radiation

Monitor, Trains A and B, prior to July 10,1996, was an apparent violation of

10 CFR 50.65(a)(1) (50-361/9614-01:50-362/9614-01).

b.15 Common Control Room Comolex Isolation Sianal Radiation Monitor.

Channel B

On June 28,1996, the licensee determined that the Common Control Room

Complex Isolation Signal Radiation Monitor, Channel B was not meeting the

availability performance criterion of 97 percent. The licensee considered the

monitor to be in goal setting in accordance with 10 CFR 50.65(a)(1) and

initiated Action Request 960601352on July 1,1996, to determine the

cause of the channel not meeting its availability performance criterion,

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develop appropriate corrective action to return it to an acceptable

performance level, to establish a period over which the performance would

be returned to an acceptable level, and to establish what monitoring would

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be done to assure satisfactory recovery. However, the inspectors noted that

the evaluation for failure to meet the performance criterion was not

performed.

The inspectors noted that, on August 16,1996, the expert panel decided to

lower the availability performance criterion to 93 percent. The licensee's

expert panel made this change on the basis of revised surveillance

requirements and the allowance of appropriate margin for maintenance

activities. However, no performance goals or monitonng requirements were

established.

On October 18,1996, the licensee's Maintenance Rule Program Expert Panel

reached a conclusion that the monitor was no longer risk significant because

it was not included in the probabilistic risk assessment model and not

considered a source of elevated risk for core damage or a large radiological '

release. Upon changing the risk-significance classification to nonrisk-

significant, the monitor was placed in 10 CFR 50.65 Category (a)(2). The

inspectora found that insufficient information was available to evaluate the

licensee's actions with respect to establishing performance criteria for the ,

'

Common Control Room Complex Isolation Signal Radiation Monitor Channel

l B because the expert panel allowed the reliability engineers 30 days to

determine if plant level performance criteria were appropriate. Therefore,

this was identified as an inspection followup item (50-361/9614-03;

50-361/9614-03).

The inspectors found that the f ailure to set goals and monitoring

requirements for the Common Control Room Complex isolation Signal

Radiation Monitor, Channel B, prior to July 10,1996, was an apparent

l violation of 10 CFR 50.65(a)(1)(50-361/9614 01:50-362/9614-01).

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c. Conclusions

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The f ailure to set performance goals and monitoring requirements for 13 structures,

systems, or components that exhibited performance at levels less than the

established performance criteria is an apparent violation of 10 CFR 50.65(a)(1)

l (50-361/9614-01:50-362/9614-01). The failure to establish performance criteria

for the common control room complex smoke exhaust system is an apparent j

violation of 10 CFR 50.65(a)(2)(50-361/9614-02:50-362/9614-02). The !

evaluation of the licensee's actions for evaluating the applicability of plant level

criteria for the common control room complex isolation system and the containment

purge isolation system is an inspection followup item (50-361/9614-03:50-

362/9614-03).

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M1.2 Reliability Monitorina

a. Inspection Scope

The inspectors used 10 CFR 50.65, " Requirements for Monitoring the Effectiveness

of Maintenance at Nuclear Power Plants"; Regulatory Guide 1.160, " Monitoring the

Effectiveness of Maintenance at Nuclear Power Plants," Revision 1;

NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants"; SO123-XV-5.3," Maintenance Rule Program

implementation," Revision 0, TCN 0-3; and, SO123-XIV-5.3.2, " Determination of

Maintenance Rule Performance Criteria," Revision 0, to review the performance

criteria that the licensee had established for monitoring structures, systems, and

components,

b. Observations and Findinas

implementation of 10 CFR 50.65 using the guidance contained in NUMARC 93-01

required that safety be taken into account when setting performance criteria and

monitoring under 10 CFR 50.65(a)(2). This safety consideration would then be

used to determine if the structures, systems, and components should be monitored

at the train or plant level.

In addition to determining which structures, systems, and components were within

the scope of 10 CFR 50.65, the licensee's expert panel established the

risk-significance ranking, performance criteria, and goals. The panel also assigned

the structures, systems, and components into categories in accordance with

10 CFR 50.65(a)(1), and (a)(2).

To meet the requirements of 10 CFR 50.65, Section 9.3.2 of NUMARC 93-01

recommended that risk-significant structure, system, and component performance

criteria be set to assure that the availability and reliability assumptions used in the

risk-determining analysis (probabilistic risk assessment) were maintained. The

licensee selected performance criteria, percent availability for risk-significant

functions, that reflected previous successful performance. A performance criterion

for reliability of two functional f ailures in two fuel cycles was selected for most risk-

significant functions, j

The licensee had not performed any studies or analyses that demonstrated the

performance criteria used for reliability preserved the assumptions used in the

probabilistic risk assessment. The inspectors noted that there was no relationship

established between the criteria and any failure probability assumptions in the i

probabilistic risk assessment since the number of function demands or operating j

times were not tracked. Thus, widely different actual function reliability estimates ;

(probability of failure upon demand to start, or, af ter starting, f ailure to run) could i

result from the same number of functional f ailures in a given time period if the

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number of demands or required run times were different. This is an apparent i

d

v;olation of 10 CFR 50.65(a)(2)(50-361/9614-04:50-362/9614-04).

c. Conclusions

The licensee failed tc demonstrate that their use of a standard performance criteria

of two functional failures over two fuel cycles for reliability preserved the

assumptions of the probabilistic risk assessment. This is an apparent violation of

10 CFR 50.65 (50-361/9614-04:50-362/9614-04).

M7 Quality Assurance in Maintenance Activities (92902 and 62706)

a. Inspection Scope

The inspectors reviewed Action Request 960901036," Maintenance Rule and l

tr.plementation of Goal Setting Evaluations," dated October 30,1996 This action I

request was written by the Nuclear Oversight Division and included as an

attachment to the October 31,1996, letter.

!

b. Observations and Findinas *-

The inspectors noted, during review of Action Request 960901036," Maintenance ;

Rule and Implementation of Goal Setting Evaluations," dated October 30,1996, I

that the licensee's Nuclear Oversight Division concluded that, as the result of

ineffective project management and management oversight, goals were not fully

documented. The inspectors noted that the assessment included contributing

factors for the lack of documentation. One factor was that management redirected

the efforts of the members of the project team. Another was that management

replaced members of the project team and did not include key organizations.

Another was that management did not empower the project team to ensure the

project schedule was met. A fourth was that management was not effective in

communicating with the project team, therefore, management was not aware of the

significance of the scheduling and implementation delays in a timaly manner.

The team found that the ineffectiveness of management oversight contributed to

the failure to adequately establish performance goals and monitoring for those

structures, systems, and components whose performance was less than the criteria

set by the licensee.

Additionally, the inspectors found that, while adequate performance goals and

monitoring were not estab?ished, the licensee did not document those goals that

had been established. Also, the assessment did not address the concerns, as

discussed above, that adaquate goals and monitoring requirements were not

established prior to July 10,1996, as required by 10 CFR 50.65.

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c. Conclusions

The inspectors found that the assessment completed by the Nuclear Oversight

Division was in-depth and probing. The assessment was focused on the failure to

document goals. The assessment, however, did not address the fundamental

concern that adequate goals and monitoring requirements were not established prio,

to July 10,1996.

M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Unresolved item 50-361/9609-03:50-362/9609-03: failure to establish

performance goals and monitoring requirements for structures, systems, and

components in acr. olance with 10 CFR 50.65. This item identified approximately

15 structures, syuems, or components that apparently failed to meet the

established performance criteria and the licensee had not established any monitoring

goals on July 10,1996.

l

This report documents the inspection effort to address the unresolved item. The '

specifics are discussed above. The unresolved item is closed.

M8.2 (Closed) Violation 50-361/9501-05: selection of improper maximum interpass

temperatures. The inspectors verified the corrective actions described in the

licensee's response letter, dated May 22,1995, to be reasonable and complete. No

OTHER DOCUMENTS

Technical Specification 3.3.8, Containment Purge isolation Signal

Technical Specification 3.3.9, Control Room isolation Signal

Technical Specification 3.3.10, Fuel Handling isolation Signal l

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Updated Final Safety Analysis Report Sections 9.2.4,11.1,11.5,15.7 j

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ENCLOSURE 2

EGM 96-002

ENFORCEMENT GUIDANCE MEMORANDUM

INTERIM GUIDANCE FOR 10 CFR 50.65

THE MAINTENANCE RULE

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[ W .j UNITED STATES

NUCLEAR REGULATORY COMMISSION

g WASHINGTON, D.C. 20559 0001

%,

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August 21, 1996

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EGM 96-002

! MEMORANDUM T0:

i Hubert J. Miller, Regional Administrator

Region I

!

Stewart D. Ebneter, Regional Administrator

Region II

A. Bill Beach, Regional Administrator

Region III

L. Joe Callan, Regional Administrator

Region IV

Roy Zimerman, Associate Director for

Projects, NRR ,

Ashok C. Thadani, Associate Director for ;

'

Inspection and Technical Assessment, NRR

Elizabeth Q. Ten Eyck, Director, Division of

Fuel Cycle Safety and Safeguards, NMSS

Donald A. Cool, Director, Division of

Industrial and Medical Nuclear Safety, NMSS

John T. Greeves, Director, Division of Waste

nagement PgGS

FROM: Jo

'] f. . Vngk

h . G ay,,A trector

0 ic of Enfo nt

SUBJECT:

ENFORCEMENT GUIDANCE MEMORANDUM INTERIM GUIDANCE F

10 CFR 50.65 - THE MAINTENANCE RULE

This Enforcement Guidance Memorandum (EGM) is being issued to provide interim

enforcement guidance for evaluating issues that may be identified during

maintenance rule inspections of licensee facilities. ,

have been developed in close coordination with the Division of ReactorThe enclose

Controls and Human Factors of NRR.

The guidelines in the attachment are intended to provide guidance to the NRC

staff to facilitate consistent categorization of severity levels for failing

~

to comply with the requirements of the maintenance rule. It is important to

note that these guidelines are not currently contained in the Enforcement

Policy and are, therefore, not controlling.

applying the definition in Section IV of the Policy for:They should be used to assist in

significant regulatory concerns (for Severity Level II violations) (2)(1) instances o

significant regulatory concerns (for Severity Level III violations), or (3)

more than of minor concern (for Severity Level IV violations).

It is recognized that maintenance issues can overlap with other issues such as

quality assurance and operability. For some enforcement considerations, other

issues relative to the case may result in another enforcement approach being

taken.

In some cases, the issues can be categorized by either result or the

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root cause. For example, in some instances, the root cause may be more

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Multiple Addressees

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significant

hold true. than the result, whereas in other circumstances, the opposite m

In deciding whether to use the enclosed guidance or the existing

Supplement I to the Policy, the selection should normally b

provides the higher severity level and the clearer message.e whichever

The form and philosophy of the rule encourages " maximum flexibility" for

of the rule.in establishing their programs to meet the intent and requirements

licensees

Within these broad requirements, enforcement action would be

rule or whose performance demonstrates a continuing ineffe

maintenance activities.

Escalated enforcement would be appropriate where there was a failure to make

reasonable efforts to implement the requirements of the rule or where

implementation of the maintenance rule.significant degradation of SSCs

The following presents general

guidance that is more fully expanded in the examples in the attachment: l

.

A single violation would be a Severity Level IV violation

NOTE:

In considering whether to make a citation for a violation

involving a relatively isolated, low safety significant SSC,

consider the flexibility in the rule; the risk significance of the

SSC; the reasonableness of the licensee's efforts to implement the

rule, including consideration of its and industry's prior

operating experience; and the licensee's corrective action. If

the licensee has acted reasonably, a citation might not be

warranted.

.

A single violation involving a high safety significant SSC that '

causes a plant transient that would have been prevented by

effective implementation of the maintenance rule would be a

Severity Level III violation. Supplement I, Example C.9, provides !

that equipment failures caused by inadequate or improper

maintenance that substantially complicates recovery from a plant

!

transient is considered a Severity level 111 violation or problem.

Multiple examples of maintenance failures that demonstrate a

" programmatic

Level breakdown," would normally be considered a Severity

III violation. This is consistent with Supplement I,

Example C.7, which provides that a breakdown in the control of

licensed activities involving a number of violations that are

related that collectively represent a potential carelessness

toward licensed responsibilities is considered a Severity Level

til violation or problem.

Multiple examples of maintenance failures of high safety

significant SSCs that cause a plant tratisient or complicate the

recovery from a plant transient, indicate a programmai.ic breakdown

in implementation of the requirements of the rule and would be

considered a very significant regulatory concern and should be

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considered for issuance as a Severity Level II violation or

problem.

The maintenance rule does not supersede any existing requirements, such as

.

those contained in 10 CFR Part 50 (including Appendix 8 and other sections) or

a licensee's technical specifications, These requirements remain in effect

!

for ma h tenance activities. When preparing notices of violation for

maintenance activities, the maintenance rule should be used for citations

whenever a licensee has violated a specific requirement of the maintenance

rule. When a set of facts indicates that there are violations of both the

maintenance rule and another NRC regulation, cite both requirements with only

,'

one " contrary to." However, where maintenance violations are caused by

licensee activities not covered by the maintenance rule, cite against the

'

requirements of Appendix B or the plant technical specifications. Also,

i please note that the failure to perform the safety assessment provided for in !

i 10 CFR 50.65 (a)(3) requires special attention. This is addressed in Part A, '

,

Paragraph D in the attachment.

Because the maintenance rule takes a performance based approach to inspecting

licensee maintenance operations (a relatively new technique with limited

i

enforcement experience in these types of performance based inspection

activities), it is anticipated that the guidance provided in the attachment

will require modification as more inspections are completed and further

i experience is gained. It is estimated that a minimum of six months.will be

required until sufficient information can be collected. At that time, the

Office of Enforcement expects to revise the Enforcement Policy by adding

further guidance to the supplements, after consulting with the Commission.

'

Additional enforcement guidance has been provided in EGM 96-001, dated

July 3, 1996, which established a Maintenance Rule Enforcement Review Panel

'

that will meet periodically to review enforcement issues that are disclosed

during the performance of maintenance rule and other routine NRC inspections.

i This should contribute to the consistency of enforcement actions in this area.

.

l e.: J. Milhoan, DEDR

! H. Thompson, DEDS l

W. Russell, NRR

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J. Goldberg, OGC

F. Gillespie, NRR

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ATTACHMENT 1: MAINTENANCE RULE VIOLATIONS

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I.

Examples of Activities That Would Be Violations of the Maintenance Rule:

A. Failure to include safety related 2

f

or non-safetv related structures,

systems, and components -(SSCs) (as defined in 10 CFR 50.65 (b)(1) and

(2)) within the scope of the program.

1.

Severity Level III - violations involving, for example:

a.

Failure to include one or more SSCs, where they should i

clearly be included within the scope of the rule, that as a

result of the failure to include the SSC: 1) complicates the l

recovery from a plant transient or 2) in the case of high

safety significant SSCs, causes a plant transient )

example applies and indicates programmatic failures (if this i

involving high safety significant SSCs, then a violation at 1

Severity Level 11 should be considered).

b.

Failure to include multiple SSCs within the scope of the

rule which indicates a pro

requirements of the rule. grammatic failure to implement the

2.

Severity Level IV - violations involving, for example:

a.

Failure to include an SSC within the scope of the rule.

l

B.

Failure to establigh goals for SFCs in (a)(1) or performance criteria i

for SSCs in (a)(2) . Establishment of goals that are inconsistent with

4

'All safety related SSCs should be clearly defined in the licensee' s

quality

scope ofassurance the rule. program and should be identified and included within the

,

2

8ecause of the flexibility in the rule, special consideration needs to

be

from given

the to determine

scope of thewhether

rule. a non-safety related SSC was properly excluded

SSCs. In determining whether10 CFR 50.65

a violation (b)

occu(2) governs

rred, non-safety

consider the related

reasonableness of the licensee's actions in evaluating industry-wide and plant

experience and existing analyses (e.g. FSAR, IPE, etc.) to identify events

that would indicate that a particular non-safety related SSC should have been

included within the scope of the rule. Since licensees are not expected to

consider hypothetical scenarios, it is possible that some SSCs (with no

history of ind"stry-wide and plant experience of failures) that were excluded

from the scope of the rule, may fail and cause an event. The failure to

include such an SSC in the scope of the rule prior to the first failure of the

SSC or event would _n_gl be considered a violation. However, the licensee would

be expected to include the SSC within the scope of the rule following the

first failure of the SSC.

3

The licensee has the option under (a)(2) of the rule to demonstrate that

the performance or condition of the SSC is being effectively controlled

through the performance of appropriate preventive maintenance such that the

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safety significance or industry experience, where practical, are not

considered sufficient goals to meet the rule and would also be j

violations.

'

1.

Severity Level III - violations involving, for example:

a.

A single failure to establish a goal for an SSC under (a)(1)

or a performance criterion under (a)(2) that: 1) complicates

the recovery from a plant transient or 2) in the case of

high safety significant SSCs, causes a plant transient (if

this example applies with more than one failure and

indicates programatic failures involving high safety

significant SSCs, then a violation at Severity Level II

should be considered). )

'

b.

Multiple examples of failures to establish either goals for

SSCs under (a)(1) or performance criteria under (a)(2) that

indicate a programatic failure to implement the maintenance

rule.

c. Multiple examples of the failure to take industry-wide

operating experience into account when establishing goals or

performance criteria, where industry-wide operating

experience was readily available, that indicate a '

programatic failure to meet this requirement of the rule'.

2.

Severity Level IV - violations involving, for example:

a. A single failure to establish a goal for any SSC under

(a)(1) or a performance criterion for any SSC under (a)(2).

C.

Failure to establish a monitoring program (this would include the

failure to take timely and appropriate corrective action in the

evaluation of monitoring activities) that adequately supports the goals

set under 10 CFR 50.65 (a)(1) or the performance criteria set under 10

CFR 50.65(a)(2). The monitoring program must be sufficient in scope and

,

SSC remains capable of performing its intended function. NUMARC 93-01 uses

the establishment of performance criteria to accomplish this. The licensee

also has the option of not establishing goals or performance criteria if a

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determination is made that low safety significant SSCs are inherently reliable i

or could be allowed to run to failure. However this determination must be

made and documented in advance of the failure.

' Evidence that industry-wide operating experience was taken into

consideration is not required for every goal. However, if multiple examples

of goals and performance criteria are reviewed where industry-wide operating

experiences are readily available and examples are not found where the

licensee can demonstrate that they were taken into consideration, then the

licensee's program indicates a programatic failure.

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meeting their assigned goals or performance criteria. fr

1.

Severity Level III - violations involving, for exagle:

a.

A single failure to establish a monitoring program that

adequately supports a goal set under (a)(1) or a performance

criterion under (a)(2) that: 1) complicates the recovery

from a plant transient or 2

in the case of high safety

significant SSCs, causes a p)lant transient (if this exa

applies with more tF*n one failure and indicates

programmatic failures

involving high safety significant !

SSCs, then a violation at Severity Level II should be

considered). !

b. I

Multiple failures to establish a monitoring program that

adequately supports a goal set under (a)(1 or a performance

criterion under (a)(2) that indicate a prog)rammatic failure

to implement the requirements of the maintenance rule.

c.

A failure to establish a monitoring program that adequately

supports a goal set under (a)(1) or a performance criterion ,

under (a)(2) that results in repetitive maintenance i

preventable functional failures (MPFFs)3

2.

Severity Level IV - violations involving, for example: i

a. !

A single failure to establish a monitoring program that

adequately supports a goal set under (a)(1) or a performance

criterion under (a)(2).

D.

Failure to take timely and appropriate corrective action (this would

include evaluation of monitoring activities) when a goal

or performance criterion is exceeded. Repetitive failures due to

inappropriate or ineffective corrective action could be considered a

violation under this rule for all SSCs within the scope of this rule or

a violation of 10 CFR 50 Appendix B for safety-related SSCs.

1.

Severity Level III - violations involving, for example:

a.

A single failure to take timely and appropriate corrective

action when a goal or performance criterion for an SSC is

exceeded (failed) which 1) complicates the recovery from a

plant transient or 2) in the case of high safety significant

5

Maintenance Preventible Functional Failures (MPFFs) are defined in

NUMARC 93-01, Appendix B, as the failure of an SSC within the scope of the

Maintenance Rule to perform its intended function, where the cause of the

failure of the SSC is attributable to a maintenance-related activity. The

staff has endorsed the use of MPFFs as a tool for monitoring SSC maintenance

performance in Revision 1 of Regulatory Guide 1.160 (January 1995).

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SSCs, causes a plant tranc,ient (if this example applies and

indicates programmatic failures involving high safety

significant SSCs, then a violation at Severity Level II

should be considered).

b.

The failure to evaluate the results of monitoring activities

which results in repetitive MPFFs.

c.

Multiple failures to take timely and appropriate corrective

<

action when a goal or performance criterion is exceeded

-

(failed) that indicates a programmatic failure to implement

the requirements of the maintenance rule.

'

2.

Severity Level IV - violations involving, for example:

a.

A single failure to take timely and appropriate corrective

action when a goal or performance criterion is exceeded i

(failed).

E.

Failure to make a reasonable effort to identify and determine the cause

of MPFFs of SSCs covered under (a)(2) would be a violation.Failure to

develop a rationale or justification for continuing to cover an SSC

under (a)(2) after it has experienced a repetitive MPFF would be a

violation.

1.

Severity Level III - violations involving, for example:

a.

Multiple failures to make a reasonable effort to determine

the cause of MPFFs of SSCs covered under (a)(2).

b.

Multiple failures to develop a rationale or justification

for continuing to cover these SSCs under (a)(2) after they

have experienced a repetitive MPFFs that indicate the

programmatic failure to implement the requirements of the

rule.

2.

Severity Level IV - violations involving, for example:

a.

A sincle failure to make a reasonable effort to determine

~

the cause of a MPFF of an SSC covered under (a)(2).

b. The failure to develop a rationale or justification for

continuing to cover that SSC under (a)(2) after it has

experienced a repetitive MPFF.

F.

Failure to perform the required periodic assessment for the activities

described under (a)(3) would be a violation.

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1.

Severity Level III - violations involving, for example:

a.

The failure to perform any required periodic assessment

w'nich indica.ted a programmatic failure to meet the

requirement of the rule.

2.

Severity Level IV - violations involving, for example:

a.

The failure to include a review of performance and

monitoring activities and associated goals and preventive

maintenance activities (i.e., all (a)(1) and (a)(2)

activities) in the periodic assessment.

b.

Completing this assessment in an untimely manner'.

c.

The failure to take industry-wide operating experience into l

~

consideration when performing the periodic assessment.

<

G.

Failure to periodically (once per refueling cycle, not to exceed 24

months between evaluations) balance reliability and unavailability due

to monitoring / maintenance activities would be a Severity Level IV

violation.

H.

A failure to develop, implement or adhere to any of the procedures

developed by a licensee to implement the rule may be a violation and

could be assessed as a violation of the licensee's technical

specifications or 10 CFR 50 Appendix B. I

1.

Severity level III - violations involving, for example:

a.

A single failure to develop or follow procedures involving

the maintenance of an SSC that 1) complicates the recovery

from a plant transient or 2 in the case of high safety

significant SSCs, causes a p)lant transient (if this example

applies and indicates programmatic failures involving high

4

safety significant SSCs, then a violation at Severity Level

11 should be considered).

b. The failure tc develop or follow procedures that results in

repetitive MPFFs.

c. Multiple examples of failures to develop or follow

.

procedures that indicate a programmatic failure to implement

the requirements of the maintenance rule.

2. Severity Level IV - violations involving, for example:

a. A single failure to develop or follow procedures.

'At least one assessment during each refueling cycle provided the

interval between assessments does not exceed 24 months.

]

.

I

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II.

Examples ofRule:

Maintenance Activities That Would Not Necessarily Be Violations of the l

A.

A failure to meet a licensee developed goal under (a)(1) would not

be subject to enforcement action as long as appropriate corrective

action had been taken when the goal was not met.

8.

It is intended that licensees be allowed flexibility when

establishing goals and not be subject to enforcement on goal

selection as long as these goals are reasonably based on safety

and industry operating experience. The NRC does not intend to

second guess the details of these goals. However the NRC will '

review these goals to ensure that they are reasona,bly based on

safety and industry operating experience.

C.

The details of the monitoring program would not be subject to

enforcement action as long as the monitoring was sufficient to .

!

adequately support the goals and provided for an evaluation

whenever a goal was exceeded (See example of violations C and D

above).

1

D.

Since the rule states that, in performing monitoring and i

preventive maintenance activities, an assessment of the total )

plant equipnent that is out of service should be taken into

account to determine the overall effect on performance of safety

functions, the failure to perform this assessment would not be a

violation of 10 CFR 50.65(a)(3). However, licensees are expected

to perform this assessment.

If the inspector finds that a licensee is not performing this i

i

assessment using the methods detailed in NUMARC 93-01, Section 11,

or equivalent methods, then the inspector should consider this to

be an issue that should be referred for resolution to NRC !

management and the Maintenance Rule Enforcement Review Panel, '

established by EGM 96-001.

In a case where this failure to perform a safety assessment i

contributed to the seve-ity of another violation of the

regulations, or exacerbated the consequences of an event or .

!

transient, the failure to perform a safety assessment could be

taken into account as an escalating factor in any escalated

enforcement action.

In addition,out

equipment theoffailure

servicetothat:

consider the overall impact of taking

(1) exhibits a pattern supporting a

programmatic issue, (2) causes the initiation of a plant trip or a

transient with the potential for a trip, or (3) demonstrates the

potential for a high risk system configuration is of significant

regulatory concern and should be considered for enforcement

action. Depending on the circumstances, the enforcement related

action (enforcement conference, Demand for Information, Order,

etc.) should be utilized to focus the licensee on the need to

__ __ _ . _ . - . . . . _ _ _ _ _ . . _ . _ . - - - _ _ . _ . . _ - _ . _ _ . . - _ _ . . . _ . . _ _ . . _ . . _ . _

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modify its maintenance activities because of its demonstrated I

failure to consider the overall safety impact of removing

equipment from service. l

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E. Deficiencies in records and documentation would not in themselves J

be subject to enforcement. However, if they contribute to an 1

inappropriate action or inaction to correct the. performance of an

SSC, these record or documentation deficiencies may be cited as -

contributing factors in an enforcement action.

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