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1 ST.
LUCIE i
i MAINTENANCE RULE i
f BASELINE INSPECTION i
NOTEBOOK COPY FOR:
BILL HOLLAND l
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BINDER 96-485 PDR a
ST LUCIE UNITS 1 AND 2 MAINTENANCE RULE 8/30/96 BASELINE INSPECTION PLAN NOTEBOOK CONTENTS TAB A INSPECTION PLAN TAB B MAINTENANCE RULE BASELINE INSPECTION GUIDANCE / CHECKLIST Pre-inspection Checklist Inspection Prep-week Checklist Entrance Meetino Checklist Master Inspection Checklist Baseline Inspection Database Input Sheet TAB C RELATEbINSPECTIONPROCEDURES/ DOCUMENTS TAB D PLANT / STAFF DATA / SITE MAP / SALP TAB E MAINTENANCc RULE BASELINE INSPECTION REPORT OUTLINE l
TAB F STRUCTURAL INSPECTION GUIDANCE TAB G INSPECTION FINDING FORM & ENFORCEMENT GUIDANCE TAB H Maintenance Rule Coordinator TAB I Expert Panel TAB J Scope of Rule 50.65(b)
TAB K Periodic Evaluation and Balancino 50.65(a)(3)
TAB L Assess Safety Impact of Takino SSCs Out of Service 50.65(a)(3)
TAB M Plant Operators TAB N Goal Settina and Monitorina 50.65(a)(I)
TAB 0 Preventive Maintenance 50.65(a)(2)
TAB P Emergency Diesel Generator TAB 0 PRE-INSPECTION REQUESTED ITEMS LIST TAB R RISK INSPECTION GUIDANCE TAB S MAINTENANCE RULE NRR OBSERVER CONDUCT
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TAB A INSPECTION PLAN i
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C MEMORANDUM FOR:
Distribution FROM:
William E. Holland, Reactor Inspector (Team Leader)
Maintenance Branch Division of Reactor Safety Region II i
SUBJECT:
INSPECTION PLAN FOR ST. LUCIE UNITS 1 AND 2 MAINTENANCE RULE 1
BASELINE INSPECTION Enclosed is the inspection plan for the Maintenance Rule Baseline Inspection at St. Lucie Units 1 and 2 that will be conducted during the period of September 16 through 20, 1996. The enclosed information is being forwarded to team members and NRR observers, and includes the inspection scope, background, inspection methodology and guidance, schedule, team composition, and site logistics.
An entrance meeting with the licensee will be held Monday morning, July 16, 1996 at 9:00 a.m.
The formal exit meeting with the licensee is planned for Friday, July 20, 1996. A pre-exit review meeting will be held Thursday afternoon, July 19, 1996 at 2:00 p.m. (tentatively) at which time the team will discuss issues with NRC management to be presented at the exit meeting.
Related plant and inspection information will be contained within the Maintenance Rule Baseline Inspection Notebook under several Tabs. These notebook tabs will be provided the first day of the preparation week (September 9, 1996). The information contained in these Tabs will be provid.ed only to team members and observers.
Enclosure:
As stated Distribution:
AFGibson, RII JRJohnson, RII SCBlack, NRR H0Christensen, RII KDLandis, RII RPCorreia, NRR DMVerrelli, RII RDGibbs, RII WCBearden, RII JLColey, RII WGRogers, RII JLShackelford, NRR TABergman, NRR RKFrahm, Jr NRR WScott, NRR DRTaylor, RII/NRR MMiller, SRI, St.Lucie
l id ENCLOSURE 8/29/96 St.Lucie Unit 1 and 2 Maintenance Rule Baseline Inspection
.I.
Inspection Objective The purpose and objective of the MR Baseline Inspections are to verify compliance with all parts of the Maintenance Rule at all licensed commercial reactor sites. The " Maintenance Rule Baseline Inspection Guidance" and Inspection Procedure (IP) 62706 will be used during the baseline inspections which are scheduled to be accomplished within two years.
The results from the baseline inspections would also serve as valuable information for NRR license renewal activities for any plant considering or applying for a renewed license.
II.
Backaround The "ommission issued the Maintenance Rule (MR) 10 CFR 50.65 on July 10, 1991, to become effective in 5 years.. As directed by the Commission, the first 2 years of the 5-year period were used by the staff to develop and issue regulatory guidance and the remaining 3 years for licensees to implement the guidance and for the staff to develop and issue inspection guidance. The staff's expectation has been that all licensees will be in full compliance on the effective date of the Maintenance Rule, July 10, 1996, without exception.
This inspection plan along with the referenced inspection procedures provides i
guidance to the inspection team to conduct the Maintenance Rule Baseline Inspection.
Related inspection review / question sheets are included in several Tabs of the inspection plan notebook to assist each inspector in completing their assignments.
Supporting documents and references to the Maintenance Rule are included within Tabs of the inspection plan notebook.
III.
Inspection Scope The maintenance rule baseline inspections will be Regional Team Inspections which are under the Inspection Program described in MC 2515. These Regional Team Inspections are scheduled to be performed at all operating reactors.
The team will use the guidance contained in the following documents to conduct this inspection: Tab 8, " Maintenance Rule Baseline Inspection i
Guidance / Checklist," Tab C "Related Inspection Procedure / Documents" which includes (IP) 62706, " Maintenance Rule," and various inspection review / question sheets which address each. portion of the maintenance rule and i
are contained in several Tabs of the inspection plan notebook.
During the first phase of the inspection (preparation week), the team will follow the guidance contained in related Tabs of the inspection plan notebook that address preparation week activities. Appropriate maintenance rule plant 1
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informatiori will be available as requested by the team leader as outlined in Tab Q, " Pre-inspection Requested Items List." The following general areas will be covered during the preparation week:
(1)
Review plant procedures to familiarize the team with plant layout
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configuration, organization structure, and methods used by the licensee to implement the maintenance rule.
This review will include a verification and validation of the licensee's Maintenance Rule program as compared to 10 CFR 50.65, NUMARC 93-01, and Reg Guide 1.160.
Follow the guidance contained in Tab B " Maintenance Rule Baseline Inspection Guidance / Checklist" and various other review / question sheets.
(2)
The team will independently review the plant UFSAR, E0P, and IPE/PRA to become familiar with SSCs that potentially should be included within the scope of the maintenance rule.
These reviews will be used on site to validate the licensee's scoping activities.
(3)
The team will be briefed by the SRI /RI regarding licensee performance for the past two years.
In addition, team members will independently review the St.Lucie Plant Issues Matrix to brainstorm selection of specific SSCs for review.
Based on recent events, the backup shutdown facility will get priority consideration when selecting SSCs.
(4)
The team leader will select, with input from the team members, several SSCs that are within the scope of the Maintenance Rule and assign SSCs to inspectors to develop their individual inspection plans to complete the on-site vertical slice type inspection. Team members will review available data on the assigned SSCs durint, this phase of the inspection.
(5)
Each team member will attend PRA Briefing Session on Tuesday, September 10, 1996 (Facilitator: Walt Rogers and/or Jeff Shackelford).
(6)
Each team member will develop individual inspection plans for the SSCs assigned and furnish a copy of the individual inspection plan to the team leader on or before September 13, 1996.
(7)
The team leader will complete applicable portions of the Master Inspection Checklist, Inspection Prep-week Checklist, and finalize the Entrance Meeting Checklist.
During the on-site phase of the inspection, the team will follow the gJidance contained in related Tabs of the inspection plan notebook that address on-site week activities.
During the on-site week the team will:
(1)
Assess the licensee's Maintenance Rule program using a deep vertical slice technique to accomplish the inspection objectives.
The term " deep vertical slice" refers to the in-depth review of selected SSCs, and completing a verification and validation process to ensure each SSC selected meets all aspects of 10 CFR 50.65 as described in IP 62706.
(2)
Assess the Maintenance Rule functional areas of the assigned SSCs looking for any programmatic weakness.
Concentrate on performance 2
O issues as previously identified in plant records to validate implementation of the Maintenance Rule.
(3)
Perform a detailed walk-down of each assigned SSC using IP 62706 as a reference document and other inspection guidance, including checklists and data sheets provided as tabs in the inspection plan notebook.
- Also, during observations of selected structures, inspection guidance provided in Tab F, " Structural Inspection Guidance" to assist in reviewing the structural area.
(4)
The team leader will tract and ensure completion of the Maintenance Rule Baseline Inspection and indicate same in the applicable portions of the Master Inspection Checklist.
IV.
Plant Specific Information St. Lucie Units 1 and 2 are C-E PWRs. The plants are located on Hutchinson Island near Jensen Beach, Florida (approximately 40 miles weubrm6 North of West Palm Beach, FL.).
These plants are operated by Florida Power and Light Company.
Plant background information including current Systematic Assessment of Licensee Performance (SALP) insights and plant data are provided in Tab D of the inspection plan notebook.
V.
Inspection Schedule The team will prepare for the inspection during the week of September 9 - 13, 1996 at the NRC Region II Office in Atlanta, Georgia. The team leader will work with team members to assure necessary additional materials are provided in addition to those provided by this plan. Team members should plan on participating in discussions with the team leader prior to the preparation week to discuss team assignments and final logistical plans.
Each team member should ensure that his/her organization has submitted a good guy letter j
through RII to St.Lucie (with a copy to the team leader) to allow for j
unescorted access prior to arrival for the inspection.
St.Lucie normal working hours are Monday through Friday, 7:30 a.m. to 4:00 p.m.
Appropriate team support and licensee participation has been coordinated beginning Monday, September 16, 1996.
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Week of September 9 - 13, 1996 In-office review A detailed St.Lucie Maintenance Rule document -aview will be conducted by the inspectors in the Region II Incident Response u ter (29th floor) beginning at 9:00 a.m on September 9,1996 under the direction of Bill Holland, Team i
Leader.
Prior to the preparation week, RII requested specific documents to be provided by the licensee for use by the team members. During this preparation phase, a review of the licensee's scoping process for Maintenance Rule SSC(s)
I inclusion will be conducted. Also, team members will review the site's
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Maintenance Rule procedure and related programs to become familiar with the processes and procedures used by the licensee to implement other requirements of the maintenance rule.
Each team member will attend a PRA Briefing on September 10, 1996.
Detailed inspection plans for areas assigned will be developed by the inspectors during this period.
The individual team member's inspection plan is to be provided to the team leader on or before September
.13, 1996.
Week of September 16 - 20, 1996 On-site Inspection Team members not currently badged should arrive onsite at 7:30 a.m., September 16, 1996 for site specific training, badging and completion of other administrative requirements for unescorted access.
The normal expected time to complete the site specific training and badging is approximately one hour.
The team meeting area will be inside the protective area and has been identified as a area within the Service Building.
The team leader will meet with team members in this area approximately 8:30 a.m. (prior to the entrance meeting). The following team activities will be conducted on Monday, September 16, 1996:
entrance meeting, pre-entrance and daily team meetings, overall plant tour (if desired), specific tours of selected SSCs (if desired),
and a licensee presentation on the Maintenance Rule Program. The entrance meeting will be conducted at 9:00 a.m. on September 16, 1996 in a conference room in the Service Building after badging is completed.
A team overview of the detailed inspections plans, last minute directions from the team leader and any related modifications will be conducted that morning as directed by the team leader. After the entrance meeting, the licensee will present their overview of implementation of the Maintenance Rule. The presentation should last approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The on-site inspection will commence thereafter.
Details of the daily, pre-exit and exit meetings are discussed in the next section. An internal NRC pre-exit meeting will be conducted at 2:00 p.m.
(tentative) on September 19, 1996. The exit meeting with the licensee will be conducted at 1:00 p.m. (tentative) on September 20, 1996.
Plan on departing the site after the exit meeting.
Please inform the team leader of your travel itinerary for all trips.
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Week of September 23 - 27, 1996 Report Preparation
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The team will prepare inspection report input for the areas inspected. This task will be conducted in the individual inspector's office unless the team leader requests otherwise.
Individual team member's report input should be I
received by the team leader on or before September 25, 1996 (Wednesday i
afternoon,c.o.b.).
After the report is organized, compiled, and developed by the team leader, and concurred on by the inspectors, the report will be l
reviewed by appropriate NRC regional management, changes incorporated by the i
team leader, and forwarded to HQ for review.
The report will be issued as a regional report.within 30 days of the inspection exit (by October 20,1996).
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J VI.
INSPECTION MEETINGS' (1)
INTERFACE AND COORDINATION MEETINGS Daily debrief meeting with the licensee (5:00 p.m. tentative) by the team leader.
Other team members, on occasion, may attend this meeting as coordinated with the team leader.
Team meeting (4:00 p.m. each day) - each member of the team should BE PREPARED to BRIEFLY discuss findings (i.e. concerns, problems, 4
strengths) from the day's inspection.
Findings are to be documented j
(see Tab G) and given to the team leader each day prior to discussing them at the team meeting. A notebook will be maintained by the team leader containing each team member's findings. These finding sheets will assist during the pre-exit meeting with NRC management and during development of the inspection report.
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(2)
NRC INTERNAL PRE-EXIT MEETING To be conducted September 19 at about 2:00 p.m.
To be attended by region and headquarters management.
Team members should generate a written five to ten minute (approximate) presentation on their findings and provide a copy to the team leader at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the pre-exit meeting. This presentation should address the following topics: inspector, areas (SSCs) inspected, findings with a brief summation, conclusion related to the effectiveness of the Maintenance Rule in the area inspected.
Also, each team member should be able to answer questions from NRC management on the inspector's finding sheets and their presentation.
(3)
EXIT MEETING Each team member shall prepare written exit notes for their areas inspected. Where more than one team member inspects or assists in reviewing an area, the team leader will designate which inspector is responsible for preparation of the written notes.
Each inspector will review his/her notes with the team leader for integration into the exit presentation. The team leader will present the inspection findings /results at the exit meeting with the licensee on Friday, September 20, 1996.
Licensee questions will be handled by the team leader. On an as needed bases, the team leader will call on an inspector to address an issue. Only at that time should an 5
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inspector address a question from the licensee.
Questions that get too involved will be deferred until after the exit.
Team members should thoroughly discuss concerns with the licensee's contacts (and the team leader) during the:
inspection so that all that is necessary at the exit is a brief summary of the deficiencies, strengths, unresolved items, and observations, i.e. NO SURPRISES FOR THE LICENSEE OR THE NRC AT THE EXIT.
Findings are identified as discussed in NRC Manual Chapter 0610.
l The exit meeting is tentatively scheduled for 1:00 p.m. on September 20, 1996-Make travel arrangements accordingly.
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e VII. Team Members and Inspection Assianments Team Leader - Bill Holland, RII/DRS/MB (404) 331-5544 Team Member - Ron Gibbs, RII/DRS (404) 331-0346 SSCs assigned (vertical slice): Unit (s) *, (System (s) *, Train (s) *,
Structure (s) *, and Component (s)
- Selected programmatic reviews (i.e., scoping, assessm<iints, etc).
Team Member - Bill Bearden, RII/DRS (404) 331-5572 SSCs assigned (vertical slice): 5Jnit(s) *, System (s; *, Train (s) *,
Structure (s) *, and Component (s)
- Selected programmatic reviews (i.e., scoping, assessments, etc).
1 Team member - Jim Coley, RII/DRS (404) 30-2776 SSCs assigned (vertical slice): Unit (s) *, System (s) *, Train (s) *,
Structure (s) *, and Component (s)
- Selected programmatic reviews (i.e., scoping, assessments, etc).
Team member (PRA) - Walt Rogers, RII/NRR (301) 415-2682 Assigned:
PRA/IPE assessment on the following SSCs
- Selected programmatic reviews (i.e., risk ranking, expert panel, etc).
Team member (PRA) - Jeff 3hackelford, NRR (301) 415 Assigned:
PRA/IPE assessment on the following SSCs
- Selected programmatic reviews (i.e., risk ranking, expert panel, etc).
Observers:
NRR/HQMB observer - Tom Bergman, NRR/HQMB (301) 415-1021 j
NRR/HQMB observer - Ron Frahm, Jr., NRR/HQMB (301) 415-2986 1
NRR/HQMB observer - Don Taylor, RII/NRR (540) 894-5421 NRR PRA Contractor - Steve lyde Specific unit (s), system (s), train (s), structure (s), and component (s) i will be identified by the team leader during the preparation phase of the inspection and assigned to each inspector. These selected inspection samples will be designated based on current and historical performance, risk significance, and appropriate distribution of samples to cover both safety and non-safety related elements.
Inspection Review / Question Sheets will be used by each inspector to complete each assigned inspection area.
In addition, general inspection guidance for the inspection of structures is contained in Tab F, " Structural Inspection. Guidance' and for risk is contained in T R, " Risk Inspection Guidance." The NRR/HQMB observer expected conduct is contained,in Tab S, " Maintenance Rule NRR Observer Conduct."
After inspection assignments have been made by the team leader, each inspector will use the appropriate guidance, checklist, and data sheets contained in several Tabs in the inspection plan notebook to complete the assignment.
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VIII. Loaistics The St. Lucie :;ne is approximately 40 miles North of West Palm Beach, FL.
Team members should make travel arrangements that support arrival at the site by 7:30 a.m. Monday, September 16, 1996. A map to the site is provided as Tab D.
The major airport nearest to the plant site is Palm Beach International l
Airport. Motels in the area include the following: Holiday Inn, Hutchinson Island, Jensen Beach, FL - (407) 225-3000; Courtyard by Marriott, Hutchinson Island, Jensen Beach, FL - (407) 229-1000. Team members shall submit their request for orders, make their own motel and travel reservations and notify the team leader of their agenda. The per diem rate for St. Lucie depends on which county your lodging is in.
For St. Lucie County the per diem is $52 for lodging and $26 for M&IE (Total-$78).
For Martin County the per diem is $66 for lodging and $30 for M&IE (Total-$96).
Travelers need to coordinate their travel plans to limit the number of rental cars going to/from the plant.
At least two NRC travelers should be traveling to/from the plant in each rental car. Team members should arrive and depart at times suitable to support the team's objectives, possible after hour meetings, and to the inspectors liking provided they remain cognizant of rental car use and coordinate their schedules with the team leader.
IX.
Inspection Documentation During the inspection, all potential findings will be documented and provided to the team leader on a copy of the Inspection Finding Form include as Tab G.
These completed forms are expected to be given to the team leader prior to discussion at the daily team meetings.
NRC Manual Chapter 0610 contains general guidance with regard to written input for the final inspection report. An outline of the final inspection report has been provided as part of the inspection plan notebook Tab E, " Maintenance Rule Baseline Inspection Outline."
In addition, the Maintenance Rule Team Inspection conducted at Palo Verde in July 1996, will be used as an example report.
Each team member will be given the responsibility for writing assigned sections of the report and documenting the findings related to the SSCs the inspector was assigned to perform a vertical slice.
Draft inspection report input should be submitted to the team leader on or before September.25, 1996, which is the Wednesday following the inspection (exit).
Please provide input l
in a word perfect 5.0 or 5.1 file, via e-mail to Bill Holland (E-mail, WEH).
X.
RITS Information Inspectors Inspection Report Number:
50-335/96-13,50-389/96-13 l
IMI Code: IENG l
IPE Code: RT Inspection Procedure: Reference IP 62706 1
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l TAB B NAINTENANCE RULE BASELINE INSPECTION GUIDANCE / CHECKLIST I
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Checklists:
i Pre-inspection Checklist i
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Preo-week Checklist Entrance Meetina Checklist i
l Master Inspection Checklist i
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Baseline Inspection Database Input Sheet l
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Pre-Inspection Checklist
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The team leader should ensure that the following tasks are completed:
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- 1. Region to send notification to licensee with proposed inspection 8
j agenda which includes requests to have them provide an initial briefing on their program.
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- 2. Ask licensee to send copies of maintenance rule program basis document and procedures for review prior to the inspection.
- 3. Add names of HQ and other region team members to the good guy letter
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- 4. Notify resident inspector
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- 5. Coordinate with Rich Correia (Email "RPC" or 301-415-1009) of the reliability and maintenance section, NRR, and the NRR project manager 4
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- 6. Make travel arrangements, provide information to all team members:
N a.
Hotel l
N b.
Submit travel requests
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Airline reservations 4
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an. Verify that all team inspectors have completed site access training d maintenance rule training.
8.
Assemble all documents and assign team members the following tasks:
scoping, operating experience review, risk determination, plant design and licensee's organization and staffing.
i 9.
Assign team member (s) to prepare a briefing on the plant design features, the licensee's organization and key plant staff members. This briefing will be presented to the team during the prep week.
(This might be a good job for the PM or resident inspector)
- 10. Assign team member (s) to review industrywide operating experience that could apply to this licensee and plant specific operating history to assemble a package of SSCs and their associated events.
This information will be used during the inspection to verify that the licensee's operating experience program has identified appropriate industrywide operation experience and that they have taken the industrywide operating experience into account when setting goals or
.taking corrective action under (a)(1) of the rule and when performing the periodic evaluation ur.* r (a)(3) of the rule. This review should include the following types of documents.
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NRC Bulletins b
Information Notices 1
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'c. Generic Letters 3
d.
10 CFR Part 21 reports e.
INP0 NPRDS data f.
NRC inspection reports I
g.
SALP reports h.
LERs I.
morning reports i-11.
Review available documents (FSAR, MEL, Q-list, E0Ps, LERs, etc.)
and prepare a list of SSCs that should be within the scope of the rule. -
a.
The licensee's FSAR may be used to identify safety related SSCs and non-safety related SSCs that are relied upon to mitigate accidents and transients.
b.
Review E0Ps to identify non-safety related SSCs.
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Review the plant specific and industrywide operating experience events identified by previous reviews to identify non-safety rclated SSCs (1) whose failure could have prevented safety-related SSCs from fulfilling their. intended function or (2) whose failure could cause a scram or safety system actuation, i
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Preo-Week Checklist The team leader should ensure that the following tasks are completed:
- 1. Review inspection plan item by item and decide who will do what.
- 2. Brief the team plant design features, the licensee's organization and key plant staff members.
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- 3. Review licensee's maintenance rule basis documents and procedures to become familiar with the licensee's methods for implementing the rule.
- 4. Review the proposed outline for the inspection ano decide what type of input will be required from each of the team members.
- 5. Brief the team on the results of the review to identify industrywide operating experience that could apply to this licensee and plant specific operating history to assemble a package of SSCs and their associated events.
If these reviews have not been completed, have the team work on it during the prep week.
- 6. Brief the team on the results of the scoping review.
If the scoping list was not completed, have the team work on it during the prep week.
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Entrance Meetina Checklist j
G cep pogatAG,
- 1. I am Bill Holland. the team leader for this inspection. "ith x = :
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- 2. We have ke[aroYMsi$n' in sheet which already has the NRC staff members listed.
Please add your names, title or position exactly as you want it to appear in the inspection report.
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- 3. We are here b verify that you have implemented the maintenance rule in accordance with 10 CFR 50.65.
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- 4. The inspection process will be similar to the process =F r
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- " ^ ' ' A Ag r + 5. : EWwi. 3 Mr pMrce c^ "id in IP 62706, and the inspections conducted to date.
The major inspection activities should include the following, but not necessarily in the
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i following order:
- a. We would like to meet with responsible licensee maintenance rule
>g9 personnel and have them give us a presentation on how the rule was f(f implemented at this site and have them walk us through a their procedures and any computer programs they are using to implement the rule.
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- b. We will review your scoping for the rule using our sample list.
- c. We will meet with expert panel members to discuss your risk determination process and any other maintenance rule activities that the expert panel was/is involved in.
- d. We will review your plans, procedures and schedule for performing the periodic evaluation and the latest periodic evaluation, if you have performed one.
- e. We will also review the process and procedures you have established for balancing reliability and availability under the
- rule,
- f. We will review your process and procedures for evaluating the safety impact of taking SSCs out of service for monitoring or preventive maintenance.
Au'O d, we willielect a sample'of (a)(1)
- g. Fv, i.6
'2-and (a)(2) SSCs for detailed review of goals, performance criteria, corrective actions, trending, etc. We will need to interview the system engineer or other person (s) assigned responsibility for the system.
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- 5. I will provide feedback to your staff on a daily basis (either am or pm). When we have completed our inspection we will hold an exit meeting to discuss our preliminary results. E " :J e..~rning : ;^^d " -^ S is a s e... : C : '..;: -:
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- 6. We will need a contact person who can help us get documents and j
arrange meetings with your members of your staff.
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- 7. We will also need to the use of an office or conference room for the duration of the inspection M / cat 2r.r p o w /.vs ou r o p X co s-R S.*T o/t, A W J o/Z #f THE JoUTN -Cr/vic.T fg
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J Master Inspection Checklist:
To determine if the licensee has implemented the maintenance rule in accordance with 10 CFR 50.65 the team leader should ensure that the following inspection checklist items are completed. General and specific guidance are provided in IP 62706.
Inspectors should record any findings, observations, strengths, weaknesses, or apparent violations on a separate piece of paper.
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- 1. Have licensee representatives brief the team on the methods they used to implement the rule.
- 2. Interview the Maintenance Rule coordinator using the Maintenance Rule Coordinator Questions provided as a guideline.
(TAB H)
- 3. Interview the Expert Panel regarding risk determination process using the Expert Panel Questions as a guideline.
(TAB I)
- 4. Review the licensee's scoping activities by comparing the inspectors sample list of SSCs with the licensee's list of SSCs that are included within the scope of their program using the (b) Scope of the Rule Review.
Question the licensee's representatives about any SSCs that were on the inspectors sample list but were not included within the licensee's program.
(TAB J)
- 5. Review the licensee's plans and procedures for performing the periodic evaluation and for bal:ncing reliability and unavailability using the (a)(3) Periodic Evaluation and Balancing Questions.
(TAB K)
- 6. Review the licensees process and procedures for assessing the safety impact of taking SSCs out of service for monitoring or preventive maintenance using the (a)(3) Safety Assessment Questions.
(TAB L)
- 7. Interview plant operations staff about their knowledge of the rule and their responsibilities for implementing various aspects of the rule using the Plant Operators Questions.
(TAB M)
- 8. Select a sample of (a)(1) and (a)(2) SSCs for detailed review of goals, performance criteria, corrective actions, trending, etc.
For each system selected, interview the appropriate system engineer using the (a)(1) Goal Setting and Monitoring Questions (TAB N) or the (a)(2)
Preventive Maintenance Questions.
(TAB 0)
- 9. If the emergency diesel generators are selected for review, the Emergency Diesel Generator Questions should be filled out in addition to the (a)(1) or (a)(2) data sheet.
(TAB P)
- 10. Record appropriate information on the Baseline Inspection Database Input Shebt.
(NEXT PAGE) 1
4 Easeline Inspection Database Input Sheet Record the following data for each maintenance rule baseline inspection.
Fill out a separate data sheet for each unit at a multi unit site.
Provide a copy of the data sheet to the Reliability and Maintenance Section, HQMB, DRCH, NRR attention Rich Correia, Mail Stop 0-10A19 or Email to RPC.
The data from each baseline inspection will be compiled in a database (DBASE III) which will be made available to NRC staff.
1 Inspection Report Number:
So -2ITMc-XJ. ' Jb-789/[Ilf-/7 Inspection dates from:
9 / /t/ 94 to:
9/EC/96.
P1 ant Name:
3/
ZgCAT Unit Number h or 3):
NRC Region:(1, 2, 3, 4) 2 Team Leader:
tw&L/ ism E.
A @tt/7h y Telephone #: Go+) 77/-I.r+#
Plant Status Description (operation, shutdown, startup, etc.):
Q M Mh Plant Mode number:
Total Number of structures and systems:
Number of systems under the scope of the maintenance rule:
Number of structures under the scope of the maintenance rule:
i Number of additional structures or systems identified by the NRC which should be included within the scope of the rule:
List of addttional structures and systems identified by the NRC which should be included uithin the scope of the rule:
4 Number of risk significant systems:
Number of risk significant structures-1
e 4
Is a living PRA maintained (yes or no):
How often is the PRA data updated?
?
l What risk determination Methods are used? (RRW, RAW, 90%CDF, Fussell/Veseley, i
etc.)
j
)
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What online risk evaluation methods are.used? (matrix, CAFTA, RMQS, PSAM risk monitor,etc.)
1
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How many SSCs were categorized under.(a)(1) of the rule?
List the (a)(1) SSCs:__
Attach a copy of any notices of violation which were issued.
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l TAB C RELATED INSPECTION PROCEDURES / DOCUMENTS l
l IITSPECTION PROCEDURE 62706 l
NRC INSPECTION REPORT 50-528/96-09; 50-529/96-09; 50-530/96-09 SELECTED LISTING OF NRC INFORMATION NOTICES l
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NRC INSPECTION MANUAL NoMB INSPECTION PROCEDURE 62706
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MAINTENANCE RULE PROGRAM APPLICABILITY: 2515 SALP FUNCTICML AREA: MAINTENANCE (MAINT) 62706-01 INSPECTION OBJECTIVE To verify the implementation of 10 CFR 50.65, "the maintenance rule" (Ref.1),
after the effective date, July 10, 1996.
62706-02 INSPECTION REQUIREMENTS Verify Imolementation of the Maintenance Rule. Perform the following reviews to verify the licensee's implementation of the maintenance rule (i.e., the rule),
certain requirements of the station blackout rule (ref. 2), and Generic Letter 94-01 (ref. 3) following the guidance in Regulatory Guide 1.160 (ref, 4) and NUMARC 93-01 (ref. 5).
02.01 Goal Settina and Monitorina. 50.65(a)(1). Verify that the licensee has implemented goal setting and monitoring as required by paragraph (a)(1) of the rule. The licensee is required by the rule to perform the following:
a.
Monitor the performance or condition of structures, systems, and components (SSCs) against licensee established goals, in a manner sufficient to provide reasonable assurance that such SSCs, defined in 10 CFR 50.65(b), are capable of fulfilling their intended functio. s.
n b.
Establish goals commensurate with safety and, where practical, take into account industry-wide operating experience.
Take appropriate corrective action when the performance or condition of.
c.
an SSC does not meet established goals.
Preventive Maintenance. 50.65(a)(2). For those SSCs that are within the 02.02 scope of tha rule but are not monitored under paragraph (a)(1) of the rule, verify that the licensee has demonstrated the following:
Performance or condition of an SSC is being effectively controlled a.
through the performance of appropriate preventive maintenance such that the SSC remains capable of performing its intended function; or, Issue Date: 08/31/95 62706 hO h
~k
j.
F-b.
The SSC is inherently reliable and has low safety significance; j
Uesiafuso, prev:ntiva taintenance may not be rIquirsd (i.e., perform j.
corrective maintenance only).
i i
02.03 Periodic Evaluation. 50.65f a)(3), birify that the licensee is performing i
the evaluations and assessments required by paragraph (a)(3) of the maintenance rule.
1 i
a.
The licensee shall evaluate performance and condition monitoring ut"f ties, associated goals, and preventive maintenance activities at least every refueling cycle, provided the interval between evaluations does not exceed 24 months.
The evaluations shall take industry-wide l
operating experience into account, wh:re practical.
b.
The licensee shall make adjustments where necessary to ensure that' the objective of preventing failures of SSCs through maintenance is appropriately balanced against the objective of minimizing unavailability 1
of SSCs due to monitoring or preventive maintenance activities.
l c.
The licensee is expected to assess the total plant equipment that is out of service and determine the overall effect on the performance of safety functions of performing monitoring and preventive maintenance activities.
02.04 Scone of the Rule. 50.65(b).
Verify that the licensee has identified j
those SSCs that are required to be within the scope of the maintenance rule, as j
defined in paragraph 50.65(b) of the rule.
02.05 Iffgetiveness of Emeraency Diesel Generator Maintenance Activities, f
V6rify that the maintenance program for emergency diesel generators satisfies the l
commitments made by licensees in response to:
1 a.
" Loss of All Alternating Current Power," and, if applicable.
2 i
b.
Generic Letter 94-01, " Removal of Accelerated Testing and Special l
Reporting Requirements for Emergency Diesel Generators."
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62706-03 INSPECTION GUIDANCE f
i General Guidance i
Inspection Reauirements. All inspection requirements listed in Section 02, do j
act have to be performed during each inspection. If NRC management decides that a complete review of the impicantation of the maintenance rule is required, then 4
all inspection items in the inspection requirements section should be performed.
However, NRC management may also decide that only selected inspection items need be perfomed. The items selected for review will depend on the intended scope of the inspection and the resources allotted for the inspection.
In addition, 4
i inspectors should also note that, despite the fact that they are listed under the inspection requirements; i.e.,
they may not be explicitly stated in the maintenance rule.
Rather, these items may be derived from Regulatory Guide 1
-1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," or l
NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," which are optional and, therefore., would not apply to i
those licensees who implement the rule using other methods.
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62706 Issue Date: 08/31/95 I
_ _ _ _ _ _ _ _ _ - _ _ - ~ - _. - - _-----_
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Anolicability. The insp;cticn precedure is applicable to SSCs that are uithin Ene sc:p ci tis rulo as defined in 10 CFR 50.65(b); those SSCs that ara cutside 4
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this scope are excluded.
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Imolementation Guidance. Except when the licensee proposes an alternate method for complying with specified portions of the maintenance rule, the methods described in Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," (Ref. 4) will be used to evaluate the effectiveness of maintenance activities of licensees who are required to comply with the maintenance rule. The Regulatory Guide 1.160 will also be used to evaluate the effectiveness of emergency diesel generator maintenance activities associated with compliance with 10 CFR 50.63 (more information on emergency diesel generator testing is contained in Generic Letter 94-01). This regulatory guide endorses NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," (Ref. 5) and provides methods acceptable to the NRC for complying with the maintenance rule. The inspector should become familiar with Regulatory Guide 1.160 and NUMARC 93-01 before initiating this inspection. The inspector should also be aware that licensees may use methods other than those described in Regulatory Guide 1.160 and NUMARC 93-01 to satisfy the requirements of the maintenance rule.
Where other methods are used, the licensee must demonstrate that those methods satisfy the requirements of the rule.
Where a licensee implements the rule partly in accordance with Regulatory Guide 1.160 and NUMARC 93-01, and partly in accordance with other methods, the licensee must i
demonstrate that those other methods meet the applicable parts of the rule.
During the pilot site visits the NRC review team noted that the guidance contained in NUMARC 93-01 was used by the licensees at all nine sites.
The lessons learned from these pilot maintenance site visits are provided in NUREG 1526 (Ref. 6).
Differences Between Plants.
Differences in plant design (i.e.,
system boundaries), even among plants tht' have the same nuclear steam supply system (NSSS), can result in significant Ffferences in the number and types of SSCs included under the scope of the.ru For example, the results of the nine site visits to review the early implemen. tion of the maintenance rule indicated that the number of SSCs at each plant varied from 102 to 341 and that the number of SSCs within the scope of the rule varied from 67 to 127.
The number of SSCs within the scope of the rule that the licensee determined to be risk significant (high safety significance) varied from 17 to 44.
Further details are provided in NUREG 1526. The types of goals and monitoring established at different plants may also differ significantly between similar plants. Therefore, the inspector should not put too much emphasis on comparing one. plant to another when evaluating maintenance activities under the rule.
Reauirements vs. Acceotable Methods. The information provided in the specific guidance section of this procedure was derived from information contained in the maintenance rule, (Ref.1) the statements of consideration (SOC) for the rule (Ref. 7 and 8), Regulatory Guide 1.150, and the industry guideline, NUMARC 93-01.
Reference was made to the source document, where possible, in order to help the inspector differentiate between the regulatory requirements and recommendations.
In general, anything that is stated in the rule itself is a requirement. The SOC does not in itself contain requirements but does contain information that could be used to cla'rify the intent of the requirements in the rule.
Information derived from Regulatory Guide 1.160, and its endorsed industry guideline, NUMARC 93-01, provide acceptable methods for complying with the rule, but they are not regulatory requirements.
If the licensee chooses.not to implement the maintenance rule in accordance with the regulatory guide and the industry Issue Date: 08/31/95 62706
_... _ _ _ _ _ _ _. - _ _ _ ~. _ _.. _ _. _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _. _
i j
pideline, th:n the licensee must demonstrato that the alternate methods satisfy l
tid rcquirements of tha rule.
Safety Determination. The rule requires that goals be established cosmiensurate with safety. Implementation of the rule in accordance with NUMARC 93-01 requires j
that a safety (or risk) determination be performed for all SSCs within the scope 1
of the h:le.
This safety determination would then be taken into account when setting goals and monitoring under (a)(1) of the rule and when establishing j
perfomance f.rtteria under (a)(2). Tha safety detemination method recommended i
in NUMARC 93-01 involves the use of an expert panel utilizing the Delphi method of NUREG/CR-5424, supplemented by Probabilistic Risk (or Safety) Assessment (PRA) or Individual Plant Evaluation (IPE) insights, to identify safety-significant SSCs.
These PRA/IPE insights should include the use of risk reduction worth (RRW), risk achievement worth (RAW), and core damage frequency contribution j
(CDF), as recommended in NUMARC 93-01.
j During the pilot maintenance site visits, the NRC review team found that all licensees used an expert panel (or a working group) to make the safety i
significance determinations. These expert panels took PRA or IPE insights into consideration using the methods described in NUMARC 93-01, although there were i
some exceptions. NUMARC 93-01 recommends that all three methods, RRW, RAW and l
CDF, be calculated and provided to the expert panel for its consideration.. One licensee's expert panel, inappropriately, considered only CDF and not RRW or RAW.
(
Another licensee considered CDF and RAW but not RRW.
Several licensees considered the Fussell-Vesely (F/V) importance measure in addition to CDF, RAW, and RRW.
The staff believes that the three methods described in NUMARC 93-01 (CDF, RRW, RAW) should be considered the minimum when making the risk determination unless the licensee had determined that a suitable replacement method such as F/V (or others) is used to replace one of the methods.
Other methods may be developed in the future and could be used to replace either CDF, RRW, or RAW.
It is recommended that licensees use at least three methods. The results of all methods used should be given to the expert panel for consideration.
The team also found that licensees' PRA experts were very knowledgeable and were aware of the limitations of the use of PRA insights. One of these limitations is that all important systems are not necessarily modeled in a PRA. Improvements can also be made in data bases, success criteria (which affect accident sequence emphasis), and human reliability analyses.
The team found.that the use of an expert panel was necessary to compensate for the limitations and assumptions inherent in a PRA and provided a needed experience-based perspective during the safety determination process.
During routine inspections to verify the implementation of the maintenance rule, the inspectors should be familiar with the methods used by the pilot plants, since those methods appear to meet the intent of the rule and the guidance-provided in NUMARC 93-01.
In addition, the inspectors should be aware that the results obtained from any PRA can be highly dependent on the plant configuration and the system reliability and availability data used to perform the calculations.
Therefore, the licensees should reconsider safety-significance l
deterininations whenever the plant design is modified, the PRA is updated, new insights become available from configuration management reviews, or new reliability and availability data become available.
Assianment of SSCs to (a)(1) or (a)(2). Paragraph (a)(1) of the maintenance rule requires that goal setting and monitoring be established.for all SSCs within the scope of the rule except for those SSCs whose performance or condition is adequately controlled through the performance of appropriate preventive 62706
' Issue Date:
08/31/95 i
i
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maintenanco as described is paragraph (a)(2) cf the rule. The industry guideline i
for implementing the rule, NUMARC 93-01, has taken the approach that all SSCs are-l initially placed under paragraph (a)(2) and are nnly moved under paragraph (a)(1) j If experience indicates that the performance or condition is not adequately j
controlled through preventive maintenance as evidenced by the failure to meet a performance criterion or by experiencing a repetitive maintenance preventible functional failure. Therefore, category (a)(1) could be used as a tool to focus i
attention on those SSCs that need to be monitored more closely.
It is possible j
that no (or very few) SSCs would be handled under the requirements of. (a)(1).
l However the rule does not require this approach. Licensees could also take the
' approach that all (or most) SSCs would be handled under paragraph (a)(1) of the j
rule and none (or very few) would be handled under paragraph (a)(2) of the rule.
l Licensees have the option of taking either' approach.
l During the pilot maintenance site visits, the licensees questioned whether the existence of SSCs in the (a)(1) category would be used by the NRC as an indicator 1
of a poor maintenance performance.
The team assured the licensees that NRC management would not consider the existence of SSCs in the (a)(1) category as an indicator of a poor maintenance program nor would it be used in determining the SALP grade in the maintenance area provided the rule requirements were being appropriately satisfied.
The team also cautioned licensee managers that they should not view the number of SSCs in the (a)(1) category as an indicator of performance since that attitude might inhibit their staff members from placing i
an SSC under paragraph (a)(1) when a performance criterion was exceeded or a repetitive maintenance preventible functional failure had occurred. In instances where a licensee believes that there is some doubt about whether a particular SSC should be categorized in (a)(1) or (a)(2), the conservative approach would be to place the SSC in the (a)(1) category. Failure to place the SSC under (a)(1) when preventive maintenance has been shown to be ineffective would be a violation of the rule.
Aooendix B Not Aeolicable to Non-Safety-Rel ated SSCs.
The scope of the maintenance rule (10 CFR 50.65(b)), includes both safety-related SSCs and non-safety-related or balance-of-plant (B0P) SSCs.
As stated in Regulatory Guide 1.160, BOP SSCs may have been designed and built with normal industrial practices that may not have met the criteria in Appendix B to 10 CFR Part 50.
The inspector should understand that it is not the intent of the maintenance rule to require licensees to retroactively apply Appendix B requirements t1 BOP equipment. However, all requirements of Appendix B remain in effect for safety-related SSCs that are within the scope of the rule. Documentation developed for the implementation of this guideline is not subject to the licensee's quality assurance program unless the documentation has been defined as within the scope of the quality assurance program.
Hiah and Low Safety Sionificance. The rule requires that goals be established commensurate with safety. In order to implement this requirement, NUMARC 93-01 established two safety categories: "high safety significance" and " low safety significance." Criteria for placing SSCs in either of these two categories are described in section 9.0 of NUMARC 93-01. However, both the 50C and Regulatory Guide 1.160 use the terms more risk-significant and less risk-significant. For purposes of the maintenance rule classifications, low safety significance should be considered the same as less risk significant.
Likewise high safety significance should be considered the same as more risk significant.
Some licensees may elect to define other safety significance categories or may elect to define more than two categories.
This would be acceptable if the these alternate categories are defined in the licensee's procedures and implemented in a consistent manner.
Issue Date: 05/31/95 62706
Definitions of Structures. Syst-e. Trains and C-enants. The maintenance rule i
refers to structures, systems, components.... The regulatory guide refers to structures, system Ed components and also to structures, systems 9.r components.
For purposes t: the maintenance rule and this inspection procedure, SSC can mean i
structures and/or systems and/or trains and/or components.
The term SSC is l
intended to be inclusive rather than restrictive and is intended to include anything that could be called a structure, system, train, or component including walls, floors, roofs, tanks, sub-systems, trains, sub-components, parts, pumps, valves, motors, pipes, hangers, snubbers and anything else that meets the definition in 10 CFR 50.65 (b).
Renetitive Component Failures.
Duri the pilot maintenance site visits, 3
industry representatives expressed their concern that monitoring functional failures at the component level would be costly and overly burdensome to the industry.
They believe that it would be sufficient to monitor high safety significant SSCs and standby SSCs at the system or train level, and to monitor low safety-significant SSCs normally operating SSCs at the plant level. The NRC staff's concern is that there could be many repetitive component failures that would not cause a performance criteria to be exceeded and therefore would not be subject to a cause determination and monitoring under (a)(1) of the maintenance rule.
This would be especially true for low safety-significant normally operating SSCs that are monitored using plant level performance criteria. The industry believes that these component failures should be resolved using the normal work order process rather than through the maintenance rule.
The NRC staff believes that licensees should use their normal work order process to identify component failures.
However, when component failures do occur, a cause detemination should be performed to establish whether the component is within the scope of the maintenance rule. If the component is within the scope of the maintenance rule, and the failure was e maintenance preventible functional failure (MPFF) of the train or system functior., then corrective action must be taken under the maintenance rule. If the failure is repetitive, then corrective action must be taken and the component must be monitored under (a)(1) of the rule.
The cause detemination should also establish whether there are generic implications to this failure by performing a review to dettmine if the component is used in other applications in the plant. If there is a generic concern, the licensee should consider monitoring all similar components under the maintenance rule.
The cause determination can range from a simple review performed by an individual maintenance supervisor to a formal root cause analysis performed by a licensee's engineering department. The effort expended performing cause deteminations may vary based on the potential safety significance of the failure.
The NRC staff endorsement of NUMARC 93-01, which allows some SSCs to be monitored using plant level criteria, was based, in part, on the understanding that any repetitive component, train, or system level maintenance preventible functional failures (MPFFs) would be identified and would trigger the establishment of-component, train, or system level goal setting and monitoring under (a)(1) of the maintenance rule.
Enforcement. General guidance en enforcement issues is provided in Appendix A to this procedure.
This guidance can be used by the inspector to make a preliminary determination as to whether an activity or plant condition observed by the inspector should be considered a violation of the maintenance rule.
However, the inspector should be aware that the guidance contained in Appendix 62706 Issue Date: 08/31/95
l ",
A dan at canstituto regulatsry policy.
All final decisions regarding violations are made by NRC management.
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l Soecific Guidance i
03.01 eaal Settina and Monitorina 10 CFR 50.65f a)(1). The licensee is required i
i to set goals and monitor the performance or condition for those SSCs handled under paragraph (a)(1) of the rule.
1 i
a.
Monitorina. The rule requires that licensees monitor the performance or condition of SSCs in a manner sufficient to provide reasonable assurance i
that SSCs are capable of fulfilling their intended functions.
It is l
intended that licensees be allowed considerable flexibility in the j
methods used to monitor SSC performance or condition, j
i 1.
Safety Consideration in Monitorina. The statements of consideration l
and regulatory guide 1.160 state that the extent of monitoring may vary from system to system depending on the system's importance to l
safety.
This determination may be quantitative or qualitative.
1 i
Section 9.0 of NUMARC 93-01 provides guidance on various methods for establishing which SSCs are high risk significant.
These methods i
include the use of individual plant examination (IPE) results, l
plant-specific probabilistic risk assessment (PRA), maintenance j
program results, and others. Guidance is also provided on the use i
of risk importance measures such as risk reduction worth, core l
damage frequency contribution, and risk achievement worth.
The licensee may use other methods to determine the safety significance i
of SSCs. Additional guidance is provided under Safety Determination
)
in the general guidance section of this inspection procedure.
l The inspector should verify that the licensee has considered safety when determining the extent of monitoring required. To accomplish this, the inspector should select a sample of SSCs, evaluate the j
methodology used, review the resultant high safety significant SSCs, i
and verify that the licensee's methodology was properly implemented.
f The inspector should verify that the monitoring is commensurate with the safety significance of the SSCs.
2.
Monitorina at the Plant. System. Train. or Component level.
Most monitoring should be done at the plant, system, or train level rather than at the component level.
However, in some cases, especially where a specific component has been identified as the cause of multiple system maintenance preventible functional failures, licensees may determine that it is appropriate to monitor at'the component level.
For all high safety significant systems, and for low safety significant systems used in standby service, monitoring would generally be perfomed at the system or train level.
This monitoring could include parameter (i.e., temperature, pressure, flow, voltage, current, vibration) trending as well as monitoring indicators of system reliability and availability. For systems with multiple trains, monitoring (and goal setting) should be performed at the train level since monitoring at the system level could " mask" or " shadow" single train failures.
Because of plant-specific redundancy and diversity, an SSC failure does not necessarily cause a loss of safety function but could result in unacceptable system or train performance.
Train level monitoring provides a method of Issue Date: 08/31/95 62706
l addressing degraded perfcreance of a single train cv;n th: ugh the
- y:t= function is still available.
Fer purp;ses of monitoring i
under the maintenance rule, any redundant or parallel loop of plant equipment (i.e., pump, motor, fan, compressor, piping and valves) that provides an alternate path for system function could be 1
4 considered a train.
In general, the licensee should follow the conventions for defining trains and systems that were established in j
the plant safety analysis and the PRA.
If there is a conflict, the
(
licensee should use the definition that results in the more conservative monitoring actions. However, it is.not required that all installed spares be monitored as separate trains. For example, i
consider a coolant injection system that has three parallel 505 capacity trains. If both the safety analysis and PRA for this plant assume that there are three trains available, then this system should be considered to contain three trains, each of which should be monitored separately.
If both the safety analysis and the PRA for this plant take credit for two trains, then the third train I
could be considered an installed spare which might not require monitoring at the train level.
If the safety analysis assumed two trains and the PRA assumed three trains (or visa versa), then the conservative approach would be to monitor all three trains individually at the train level.
For low safety significant normally operating systems (i.e., those not used in standby service), monitoring indicators of system reliability and availability alone may be sufficient.
Low safety significant normally operating systems could.also be monitored using plant level performance criteria.
For example the licensee may choose to monitor unplanned scrams or plant capacity factor as an indirect means of monitoring performance of low safety significant normally operating SSCs.
Additional guidance on acceptable methods of monitoring is contained in Section 9.4.2. of NUMARC 93-01.
The inspector should verify that the licensee has established and implemented adequate performance or condition monitoring for SSCs within the scope of the rule.
3.
Performance or Condition Trendina of Systems and Comoonents.
The statements of consideration for the rule indicate that, where failures are likely to cause loss of an intended function, monitoring under (a)(1) should be predictive in nature, providing early warning of degradation.
Therefore, the inspector should expect the licensee to perform trending for all (a)(1) SSCs where it is practical and appropriate.
However, the inspector should also understand that it may not be possible to perform meaningful trending of some SSCs. In addition, NUMARC 93-01 provides guidance for utilizing predictive maintenance, inspection, testing, and performance trending for monitoring performance or condition under (a)(2) of the rule. The inspector should also expect licensees to perform trending for (a)(2)
SSCs where it is practical and appropriate.
During the pilot maintenance site visits, the team reviewed the monitoring and trending that was being performed for systems, trains, and components and found that there was a great degree of variability among the licensees in the quality and quantity of 62706 Issue Date:
08/31/95
i.
i haMan that tas being perfmeed. Some licens:cs had established.
4.
trending programs that were well integrated into their rule-i programs, while others were doing very little trending of SSCs performance or condition.
In some cases, licensees had existing 1
trending programs that generated equipment performance data that would be very useful when establishing goals and perfomance l
criteria under the rule; however, this data was not always taken into consideration when selecting goals and performance criteria and j
establishing a monitoring program under the rule. Goals should make l
use of existing trending activities where appropriate, and consideration should be given to establishing new monitoring and trending activities that directly address the problem whenever new l
goals are established. Goal setting and trending activities should j
be coordinated and integrated as much as possible so that the l
improvements in performance can be monitored against the goals that had been established. Although trending is not always required for i
every SSC, it should be used.where it is practical and appropriate.
l The failure to perform trending for a specific SSC would probably j
not be considered a violation.
However the failure to perform t
trending of any SSCs would be a regulatory concern.
t j
The inspector should review equipment trending to ensure that it is coordinated and integrated with the goals and performance criteria j
wherever possible.
f 4.
Monitorina Structures.
The rule requires that the perfomance or condition of structures. be monitored in a manner sufficient to i
provide reasonable assurance that those structures are capable of fulfilling their intended function. The SOC for the rule indicate i
that where failures are likely to cause the loss of an intended
(
function, monitoring should be predictive in nature, providing early warning of degradation. NUMARC 93-01, paragraph 9.4.2.4, provides l
examples of structural monitoring activities including non-i destructive examination, visual inspection, vibration, deflection, thickness, and corrosion.
}
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During the pilot maintenance site visits, the NRC review team found that many licensees had not established goals or performance criteria for monitoring structures at their sites. Many licensees assumed most structures to be inherently reliable and therefore did not require monitoring under the maintenance rule despite the fact that there were already ongoing monitoring and preventive maintenance activities for structures at the site.
Many of these structures are monitored during the nor M course of operator rounds, management walkarounds, and inspection by other plant departments in the course of their normal work activities. The team concluded that the existence of these longstanding monitoring activities was inconsistent with the licensee's position that no monitoring is needed.
Licensees should establish performance criteria or goals under the rul'e that take credit for, and build upon, the existing monitoring activities.
Certain structures, such as the primary containment, could be monitored through the performance of established testing requirements such as those contained in 10 CFR 50, Appendix J.
However, other structures, such as auxiliar,y buildings and cooling towers, may be more amenable to condition monitoring.
Other structures could require engineering evaluations to establish Issue Date: 08/31/95 62706
c:nditicn monit ring criteria.
Howev:;r, all structure monitoring programs are expected - to include the establishment of specific 1
j quantitative or qualitativo criteria for monitoring.
I The inspector should review the licensee's program for monitoring i
structures to ensure appropriate perfomance or condition monitoring
}
activities are established. Where practical, and where failures are
-likely to cause the loss of an intended function, monitoring should j
be predictive in nature, providing early warning of degradation.
l S.
Use of Existina Proarans for Monitorina.
Regulatory Guide 1.160 states that it is intended that most activities currently being conducted by licensees, such as technical specifications i
surveillance testing, canibe used to satisfy many of the monitoring requirements. Consistent with the rule, the inspector should allow licensees maximum flexibility in establishing and modifying their monitoring activities.
However, where existing programs are inadequate, new programs may need to be established by the licensee.
Additional guidance on the use of existing programs for monitoring is described in Section 9.4.2 of NUMARC 93-01.
b.
Goal Settina.
Paragraph (a)(1) of the rule requires licensees to establish goals commensurate with safety and, where practical, to take into account industrywide operating experience (OE).
Licensees have a great deal of flexibility in choosing goals and may elect to choose component, train, system, or plant level goals.
These goals may be performance oriented (reliability, availability) or condition oriente~d (such parameters as pump flow, pressure, vibration, valve stroke time, current, electrical resistance). Licensees should document the bases for the goals and any subsequent changes made to those goals.
Guidance on documentation is provided in Section 13.0 of NUMARC 93-01.
The rule specifically states that the goals are to be " licensee established."
Therefore, the inspector should allow licensees maximum flexibility in establishing and modifying their goals.
However, the goals must represent reasonable attempts to establish targets for monitoring the performance or condition of SSCs within the scope of the rule. Licensees should consider the following when setting goals:
1.
Safety Consideration for Goal Settina. The rule requires licensees to establish goals commensurate with safety.
Information on an SSC's contribution to plant safety can be obtained from various sources including the Individual Plant examination (IPE) or probabilistic risk assessment (PRA) results (if available). Section 9.0 of NUMARC g3-01 provides guidance on acceptable methods for establishing safety significance criteria.
This safety determination would then be taken into account when setting goals and monitoring under (a)(1) of the rule. The safety determination method recommended in NUMARC 93-01 involves the use of an expert panel utilizing the Delphi method of NUREG/CR-5424, supplemented by Probabilistic Risk Assessment (PRA) or Individual Plant Evaluation (IPE) insights, to identify high safety significant SSCs.
At a minimum, these insights should include the three methods described in NUMARC 93-01: risk reduction worth (RRW), risk achievement worth (RAW), and core damage frequency contribution (CDF).
- However, licensees may substitute other methods (e.g.,
Fussell/Vesely, Birnbaum) if they can provide similar risk insights.
Additional guidance is provided under Safety Determination in the general guidance section of this inspection procedure.
62706 Issue Date:
08/31/95
The inspectr should select a sample cf SSCs fcr which the licensee 1.a ostth11shed goals and verify, by rcviewing licensso r: cords and 1-speaking with responsible personnel, that safety was taken into p
account when establishing those goals.
i 2.
Industrywide Doeratina Exnerience for Goal Settina.
The licensee should also, where practical, take into account industrywide S'
operating experience when establishing goals.
Industrywide operating experience includes information from NRC, industry, and 1
vendor sources that is generally available to the nuclear industry.
Sources of such information could include NRC bulletins, information i
notices, generic letters,10 CFR Part 21 reports, the INP0 NPRDS system, vendor. service infomation letters (SILs),
technical j
information letters (TILs), significant event reports (SERs),
significant operating experience reports (50ERs), and others. It is intended that licensees make use of these types of information,-
i where practical, when setting goals under (a)(1) of the rule and i
when performing the periodic evaluations required by (a)(3) of the rule.
During the pilot maintenance site visits, the NRC review team noted that most licensees had taken operating experience into consideration in varying degrees when setting goals.
Many i
j licensees' procedures did not have adequate g'uidance for ensuring that operating experience is taken into consideration, where practical, when establishing goals.
The persons responsible for establishing goals at some sites had easy access to the operating experience database; at other sites, the access was limited or
{
cumbersome and could inhibit the use of the data base.
l i
The inspector should review the licensee's procedures to ensure that there is adequate guidance for taking operating experience into account, where practical, when establishing goals is adequate. The inspector should also ensure that operating experience data is accessible to plant staff and that operating experience is collected and factored into goal setting activities in a systematic and i
consistent manner.
i c.-
Corrective Action. Licensees are required to monitor the performance or j
condition of SSCs against the established goals and take appropriate corrective action where the goals are not met.
The SOC clarify that corrective action must also be taken where a clearly declining trend in i
l SSC performance or condition indicates the goals would not be met before the next cycle of monitoring is scheduled.
Where analysis determines that the performance or condition of the SSC is acceptable, the licensee may elect to modify the original goals and continue monitoring. In order i-to establish what would be appropriate corrective action, licensees must i
determine the cause of the failure.
The extent of the cause i
determination should be commensurate with the safety significance of the SSC, or the consequences of the failure, and can vary from a simple cause determination performed by a maintenance engineer to a formal root cause j
determination process that may involve reviews by senior licensee management.
A cause determination is required whenever an SSC exceeds its goal or experiences a maintenance preventible functional failure.
i Licensee activities such as root cause analysis and corrective actions should be documented.
l-l Issue Date: 08/31/95 62706 i
..,.-.r
1 l
The inspect:r sh uld select a samplo of maintcnance monitoring records cnd compare them to the established goals.
Where goals were not met, where a repetitive maintenance preventible functional failure occurred,
)
or where a clearly declining trend in SSC performance or condition is indicated, the inspector should examine the licensee's corrective actions to determine if the root cause was identified, if reasonable corrective j
action was taken, and if an evaluation of the effectiveness of the
{
corrective action was performed.
03.02.
Preventive Maintenance. 50.65(a)(2). The maintenance rule states that i
monitoring of an SSC as specified in paragraph (a)(1) is not required if it has been demonstrated that the performance or condition of the SSC is being effectively controlled through the performance of appropriate preventive i
maintenance so that the SSC remains capable of performing its intended function.
The 50C clarify that licensees are not required to monitor under paragraph (a)(1) of the rule if they have demonstrated that preventive maintenance has been effective or if an SSC has inherent high reliability and availability, as i
discussed below.
I i
a.
Demonstrated Effective Maintenance.
As stated in the SOC, under the terms of paragraph (a)(2), preventive maintenance must be demonstrated to be effective in controlling the performance or condition of an SSC so that the SSC remains capable of performing its intended function.
In order to assure the licensee that preventive maintenance is effective, some evaluation or monitoring process nesd: to be established under paragraph (a)(2).
1.
Performance Criteria. NUMARC 93-01 uses performance criteria as a method of demonstrating satisfactory performance or condition under paragraph (a)(2) of the rule. Where the performance or condition is not adequately controlled, the SSC would generally be dispositioned to paragraph (a)(1). Section 9.3.2 of NUMARC 93-01 recommends that 1
performance criteria should be availability, reliability, or condition.
Since section 12.2.4 of NUMARC 93-01 requires that adjustments be made to balance availability and reliability of high safety significant SSCs, it would be necessary, at a minimum, to establish both reliability and availability performance criteria for j
those SSCs..NUMARC 93-01 also recommends that specific performance criteria be established for:all high safety significant SSCs and for i
low safety significant SSCs that are in a standby (not normally operating) mode.
Plant-level performance criteria could be established for all remaining low safety significant, normally operating SSCs. Performance criteria wop 1d not be required for SSCs determined to be inherently reliable or for those SSCs that contribute little or nothing to safety function and that could be
'The statements of consideration describe the purpose of (a)(2) of the maintenance rule as to provide an alternate approach for those SSCs where it is not necessary to establish the monitoring regime required by paragraph (a)(1). This provision might be used where an SSC, without preventive maintenance, has inherent reliability and availability (e.g., electrical cabling) or where the preventive maintenance necessary to achieve high reliability does not itself contribute significantly to unavailability (e.g.,
moisture drainage from an air system accumulator). NUMARC 93-01, sections 9.3.3 and 10.2, describe an inherently reliable SSC as one that, without preventive maintenance, has high reliability (e.g., jet shields, raceways).
62706 Issue Date: 08/31/95
i.
allowed to run to failure (i.e., perf:;rs corrective maintcnance j,
rather than preventive maintenance).
j I
2.-
Maintenance-Preventable (Functional) Failure.
Section 9.4.5 of I
NL2iARC 93-01 recommends the use of the term " maintenance preventable i
functional failures (MPFFs)" rather than " maintenance preventable failures (MPFs)" as described in the 500, in order to differentiate between failures that cause an SSC to be incapable of performing its i
intended function 'and failures that do not affect an SSC's function.
i There are many possible failures of some SSCs that would not affect 4
the intended safety function of the system.
For purposes of this inspection procedure, the term MPFF will be used. A definition of j
MPFF is provided in Appendix B to NUMARC 93-01.
j 3.
Disnositionina from naraaraoh (a)(2) to naraaraoh faif1).
Section 9.4.4 of NUMARC 93-01 providet guidance on determining when i
dispositigning SSCs from paragraph (a)(2) to paranraph (a)(1). is j
required.
This would generally be required if a performance criterion were not met or if a repetitive MPFF occurred.
An SSC i
could continue to be treated under paragraph (a)(2) after experiencing a single MPFF if the root cause evaluation determined l
the cause of the failure and if the corrective action that was taken j
i prevented recurrence. However if a repetitive MPFF occurred, then i
the SSCs would have to be dispositioned to paragraph (a)(1). Note i
that this requirement applies whether the MPFF occurs to a j
structure, system, train, or component in a system. Any repetitive MPFF of a structure, system, train, or component would require that the structure, system, train, or component be placed under the i
(a)(1) category and subjected to goal setting and monitoring. This requirement exists irrespective of whether the performance criteria are monitored at the plant, system.or train level.
In cases where a component experiences a repetitive MPFF which becomes evident through the licensee's existing deficiency reporting system or work order process (rather than monitoring against performance criteria established under the maintenance rule), the rule requires that the component be placed under the (a)(1) category and be subject to goal setting and monitoring. Note that this is a requirement only if the failure is truly an MPFF; i.e.,, the failure was maintenance preventible, and it failed the system or train function that put the SSC in the scope of the rule.
Some components in the scope of the maintenance rule have no effect on the maintenance rule functions of a system and therefore would not be considered an MPFF.
- However, even when it is not an MPFF, it is expected that all repetitive component failures be analyzed by the licensee for generic concerns.
For example, even though the repetitive failure of a particular make 2 The SOC states that it is expected that where one or more maintenance preventable failures (or MPFFs) occur on SSCs treated under paragraph (a)(2)...the SSC would be required to be treated under the requirements of paragraph (a)(1) until such time as a performance history is established to demonstrate that performance or condition are once again effectively controlled by an established preventive maintenance regimen. However the 50C is not clear on whether an SSCs must be moved to (a)(1) after the first or second MPFF. This issue was subsequently clarified in section' B of Regulatory Guide 1.160, rev.1 and section 9.4.4 of NUMARC 93-01 which provide guidance on detemining when dispositioning SSCs from paragraph (a)(2) to paragraph (a)(1) is required.
Issue Date: 08/31/95 62706 l
i and model relay may nst be an MPFF in its specific rpplication in e eyeten, it may hav3 the pottntial fcr impacting the system cr-i j.
train function in other systems. Licensees should always consider l
the generic implications of component failures.
Once an SSC's preventive maintenance has been demonstrated effective l
again, it would be acceptable to return to treating the SSC under paragraph (a)(2). Section 9.4.3 of NUMARC 93-01 provides guidance j
~for dispositioning SSCs from paragraph (a)(1) to paragraph (a)(2)..
The inspector should verify that the licensee has established and 1
implemented a monitoring or assessment process for determining if l
the preventive maintenance program is effectively maintaining the i
reliability of those SSCs (except for inherently reliable SSCs i
described below) that are maintained under paragraph (a)(2) of the maintenance rule.
The inspector should review the maintenance history for a sample of SSCs maintained under paragraph (a)(2) to verify that the monitoring or assessment process ensures that acceptable perfcreance or condition of the SSCs is maintained and, where that performance or condition degrades to an unacceptable level or experiences a second maintenance preventable functional i
failure, the SSC is treated under paragraph (a)(1) until such time as the performance or condition improves to an acceptable level.
l The inspector should select a sample of SSCs that experienced 1
maintenance preventible functional failures and review the l-li.censee's actions to determine if they were dispositioned properly.
b.
Preventive Maintenance Not Reauired.
As indicated in the SOC, the purpose of paragraph (a)(2) of the rule is to provide an alternate approach for those SSCs where it is not necessary to establish the monitoring regimen required by paragraph (a)(1).
This includes those SSCs that are adequately controlled by preventive maintenance (described above), those SSCs that are inherently reliable without maintenance (described below), or those SSCs that are low safety significance (described below) and may be run to failure:
1.
Inherent 1v Reliable.
This provision might be used where an SSC, without preventive maintenance, has inherent reliability and availability (e.g., electrical cabling).
It is expected that some structures, such as cable raceways, water storage tanks, and buildings, could be considered inherently reliable.
However, it should be noted that such activities as inspections, surveys, and walkdowns could be considered maintenance activities and, therefore, most SSCs would be subject to some maintenance.
Licensees should document their reasons for concluding that individual or group's of SSCs are inherently reliable.
During the pilot site visits (See NUREG 1526), the inspectors noted that some licensees had made inappropriate use of this category by assuming that many structures were inherently reliable when in fact the licensees had many longstanding inspection and preventive maintenance activities already in place.
The existence of these preventive maintenance activities was inconsistent with the assumption that these st'ructures were inherently reliable.
The inspector should review a sample of SSCs that have been i
detenmined to be inherently reliable, and verify that the licensee's methodology appears reasonable, and that the SSC's condition or performance is acceptable without maintenance.
62706 Issue Date: 08/31/95
.. ~ _ _ _ _ _. _ _ _ _. _ _ _ _ _ _ _
J 4
2.
Run to Failure.
Methods fer determining safety significince are de:cribed in NUMARC 93-01, S:cticn 9.3.3.
SSCs that provide little i
or no contribution to system safety function could be allowed to run i
to failure (i.e.,
perform corrective maintenance rather. than
.preventivemaintenance). Licensees should establish an appropriate methodology for determining safety significance and should use these criteria to identify SSCs that could be allowed to run to failure.
Licensees should document these criteria and their reasons for deciding that individual SSCs could be allowed to run to failure.
The inspector should select a sample of Gre SSCs and evaluate them to verify that the licensee has followed ineir own methodology for detemining safety significance and that these evaluations are reasonable.
03.03.
Periodic Evaluations. 50.65 (a)(3).
The licensee is required by paragraph (a)(3) of the maintenance rule to perfom the following periodic assessments and evaluations:
a.
Refuelina Cycle Evaluation.
The rule requires that licensees evaluate performance and condition monitoring. activities, associated goals, and preventive maintenance activities at least every refueling cycle, provided the interval between evaluations does not exceed 24 months. The SOC states that these activities are to be evaluated in light of SSC reliabilities and availabilities as well as the following:
1.
Goals and Monitorina. For SSCs under paragraph (a)(1), adjustments are to be made to goals, monitoring, or preventive maintenance activities when equipment or performance has not met established goals.
Conversely, the licensee may, at any time, eliminate the monitoring activities initiated in response to problematic equipment performance or industry experience once the root cause of the problem has been corrected and the adequacy of the equipment performance has been confirmed.
On the basis of a review of records and discussions with responsible i
personnel, the inspector should verify that the licensee has reviewed goals, monitoring, and preventive maintenance activities and made adjustments, where necessary.
2.
Preventive Maintenance. For SSCs under paragraph (a)(2), adjustment of preventive maintenance activities may be warranted where SSC l
performance does not meet performance criteria (for those licensees that have implemented the rule using NUMARC 93-01) or is otherwise determined to be unacceptable. SSCs treated under paragraph (a)(2) that experience repetitive maintenance preventable functional i
failures (MPFFs) become subject to the requirements of paragraph (a)(1) or, where this is not feasible, may require other remedial action (e.g., modification or replacement).
On the basis of a review of records and discussions with responsible personnel, the inspector should verify that the licensee has adjusted preventive maintenance activities where necessary and dispositioned SSCs that experienced repetitive MPFFs to the requirements of paragraph (a)(1).
i 3.
Industrywide Operatina Exoerience.
The, maintenance rule also requires that the evaluations shall take into account, where Issue Date: 08/31/95 62706
l' practical, industrywide eparating expericace.
This type of 3
informatien may be available from the licensee's existing cperating experience program.
However the licensee is responsible for o
assuring that the infomation obtained from the existing operating i
experience program is adequate for purposes of the maintenance rule.
Applicable industrywide operating experience should be reviewed and incorporated as appropriate in a reasonable time period considering its safety significance.
Sources like NRC bulletins, Generic Letters, and information notices, TILs, SILs, SERs, SOERs, should be evaluated when received by the plant and then incorporated into the preventive maintenance program, or training program, as appropriate.
l The inspector should verify that the licensee had taken appropr.iate j
action to address industrywide operating experience.
\\
l 4.
Schedule for Periodic Evaluation. During the pilot maintenance site
+ -
visits, the NRC team reviewed each licensee's planned schedule for performing the periodic evaluation.
The team concluded that the periodic evaluation does not have to be performed at any particular time during the refueling cycle as long as it is performed at least one time during the cycle, and the interval between evaluations does i
i not exceed 24 months. For example, one licensee's plans to perform.
l the periodic evaluation on an annual basis would meet the intent of 1
i the rule (assuming that the refueling cycle is longer than one year).
Another licensee's plans to perform the evaluation at the i
same time for both units at a two unit site, even though the j
refueling cycles for the units are staggered, would also meet the intent of the rule.
A third licensee's plans to use ongoing evaluations combined with a higher level summary evaluation i
performed at least once per refueling cycle would also meet the i
intent of the rule.
j The inspector should verify that the licensee performed the periodic i
evaluation at least one time each refueling cycle, not to exceed 24 i
j months between evaluations.
l I
b.
Balancina Unavailability and Reliability. The maintenance rule requires that licensees make adjustments where necessary to ensure that the j
objective of preventing failures of SSCs through maintenance is appropriately balanced against the objective of minimizing unavailability l
of SSCs due to monitoring or preventive maintenance activities.
The 1
. intent of this requirement is to ensure that monitoring or preventive l
maintenance activities do not result in excessive unavailability that would negate any improvement in reliability achieved as a result of the 1-j monitoring or maintenance activity and that deferring monitoring or preventive maintenance to achieve a high availability does not result in low reliability.
l Due to the fact that it might be impractical to perfom this balancing on j
a continuous.(day to day) basis, licensees may establish their own i
schedule for perfoming these reviews and make any needed adjustments to their pr,eventive maintenance activities.
However, at a minimum, the 3
licensee must perform this balancing at least every refueling cycle and i
include an evaluation of this activity as part of the refueling cycle I
evaluation process described above. This process can be qualitative, but j
it should be documented.
t 62706 Issue Date:
08/31/95 4
i i
^
i.
During the pilot maintraance site visits, tha team reviewed the plcns and.
peowdma lic:nsees had d:;veloped fer accomplishing this activity. Two i.
licensees plan to balance unavailability and reliability on an ongoing-basis as an integral part of monitoring against performance criteria under -the rule.
Since performance history, preventive maintenance activities, and out-of-service time are taken into consideration when i
developing the performance criteria, these licensees believe that meeting l
these performance criteria will assure that a satisfactory balance of reliability and unavailability has been achieved. At another site, the licensee plans to accomplish this balancing by calculating the safety (or risk) contribution associated with unavailability of the system due to preventive maintenance activities and the safety contributicn due to the reliability of the SSC.
The licensee would then compare and attempt to balance the contribution to safety from each source to assure consistency i
with PRA/IPE evaluations, The NRC review team concluded that either of these methods could be a reasonable approach to satisfying this requirement of the rule.
However, neither approach had been fully implemented at the time of the site visits and, therefore, could not be fully evaluated.
Additional guidance is provided in NUMARC 93-01, section 12.2.4,
" Optimizing Availability and Reliability for SSCs." The inspector should note that this section limits the need to make adjustments to balance availability and reliability to those SSCs that are high safety significance.
j The inspector should verify that the licensee has implemented a method or process for evaluating maintenance activities and is making adjustments where 'necessary at least every refueling cycle.
The inspector should select a sample of high safety significant SSCs that were subjected to this process and verify that the adjustments made to balance availability and reliability appear to be reasonable.
c.
Assessment of Eauioment Out of Service. In order to minimize outage time and reduce costs, many licensees are increasing the amount of preventive maintenance being performed during power operation. This can result in the simultaneous removal of multiple systems from service, which can result in significant increases in risk during these periods. The NRC is concerned that some licensees may not be adequately analyzing the risk or safety impact associated with these unavailabilities.
The failure to adequately evaluate safety when planning and schecaling maintenance has led to simultaneous unavailabilities of multiple redundant or diverse systems at some sites, possibly leading to unacceptable increases in risk despite the fact that such configurations may not be prohibited by technical specifications.
The technical specifications for most sites were crafted for random failures; voluntary removal of multiple systems from service may not be bounded by worst case single failure assumptions in technical specifications.
The NRC is concerned that risk can -
significantly increase during periods when multiple redundant or diverse systems are unavailable due to preventive maintenance.
To evaluate licensee performance in the interim before the maintenance rule takes effect, the NRC developed and implemented Temporary Instruction 2515/126. This TI recommended that three factors should be considered when evaluating risk. These factors include: the probability of an initiating event such as a turbine trip, lass of offsite power, or e
LOCA; the probability of not being able to mitigate the event using core damage prevention as a measure of successful mitigation; and, the Issut Date:
08/31/95 62706
probability of ett being cblo to c:itigato th2 c:nsequ:nces using couisinnent integrity preservation as a measura of success.
Most PRAs assume that these risk factors are independent random occurrences.
However, on-line maintenance can increase the probability of an overlap
'j in real time with a resulting instantaneous increase in risk.
PRAs include assumptions about unavailability and reliability, but they may not adequately model the intentional, simultaneous removal of redundant or diverse equipment from service for maintenance.
Feedback from the TI 2515/126 inspections indicated that significant i
amounts of on-line maintenance were perfomed and that this trend was increasing.
The majority of licensees made efforts to minimize out of i
service time and maximize availability when perfoming on-line maintenance.
Many licensees incorporated PRA insights when scheduling i
and planning on-line maintenance.
The tools used by licensees varied widely in approach and sophistication as did the training that was i
performed and the plant staff awareness of risk insights.
t The maintenance rule addresses both on-line and shutdown maintenance-Under paragraph (a)(3) of the Maintenance Rule, the NRC expects licensees to assess the total impact on plant safety before taking plant equipment j
out of service for monitoring or preventive maintenance. This assessment e
is to be performed on an ongoing basis, not just during the periodic l
assessment performed during every refueling cycle.
This ongoing i
assessment should be performed regardless of plant mode, i.e., whether
(
the plant is operating or shutdown. As stated in the SOC, assessing the cumulative impact of out-of-service equipment on the performance of safety functions is intended to ensure that the plant is not placed in i
safety (or risk) significant configurations.
These assessments do not necessarily require that a quantitative assessa,-t of probabilistic safety be performed.
However the PRA or IPE may provide useful information on safety significance of various SSCs.
The level of sophistication with which such assessments are performed is expected to vary. These assessments may range anywhere from a simple matrix to the use of an on-line living PRA or risk meter.
It is expected that, over time, assessments of this type will be refined as the. technology improves l
and experience is gained.
In order to accomplish these assessments, t
licensees must keep-track of the status (in or out of service) of plant equipment. This status may be kept as a manual list or on a database but must be easily accessible and kept up to date. In order to be useful and accessible the information should be kept in one location and not scattered among several documents (shift logs, status boards, tag out status boards) in various locations. Additional guidance is provided in section 11.0 of NUMARC 93-01.
During the pilot maintenance site visits, the NRC review team found that I
licensees planned to use, or had used, a variety of approaches for assessing the overall effect on the perfomance of safety functions of i
taking plant equipment out of ' service for monitoring or preventive l
maintenance.
It appeared thatc industry is developing a heightened awareness of the importance of managing the risk of perfoming maintenance during power operation.
Many licensees approached the l
problem by developing a matrix that defines which system combinations could be allowed out of service at the same time. An advantage to using the matrix is that it is simple.
However, a disadvantage is that the i
matrix defines a limited number of combinations that may not address all operational situations and say unnecessarily limit operational flexibility. Several licensees are planning to use real time (or near-162706 Issue Date:
08/31/95 L
real time) risk (or safety) monitors that can. calculate the risk changes i
associated with the planned maintCnance activitios. An advantage is that risk monitors can be used to analyze a greater number of possible combinations of out of service systems.
A disadvantage is that it may require specially trained personnel to operate the risk monitcr or to i
i interpret the results.
Both the matrix approach and the risk. monitor I
approach appeared to be reasonable ways of assessing the impact on plant l
safety when taking equipment out of service for monitoring or preventive maintenance. However, the effectiveness of either of these methods could l
not be fully evaluated by the team because the methods had not been fully implemented at the time of the site visits.
i In order to provide additional guidance, INP0 issued " Managing Maintenance During Power Operations" to each of the member utilities on t
February 17, 1995. A copy of this guideline was transmitted in a letter to the NRC from INP0 (Ref.10) on March 1,1995. The NRC staff reviewed l
this guidance and determined that it contained useful information.
In j
addition, NEI plans to add additional guidance to Section 11.0 of NUMARC 93-01 to address this issue.
The inspector should verify, based on a review of licensee records and j
discussions with appropriate personnel, that the licensee has established i
and implemented an ongoing, documented process for assessing the overall i
effect on the performance of safety functict.s before SSCs are taken out of service for monitoring or preventive maintenance.
The inspector L
should verify that the licensee maintains a current status of all SSCs within the scope of the maintenance rule and that the licensee updates this status to indicate when SSCs are in or out of service.
The inspector should select a sample of SSCs from the licensee's list of SSCs I
that have been taken out of service and review the adequacy of the evaluations made by the licensee before taking the SSCs out of service.
03.04 Scone of the Rule. 50.65fb). The scope of SSCs that are required to be i
included within the rule is defined in 10 CFR 50.65(b).
Section 8.0 of NUMARC 93-01 provides additional guidance on.nethods for selecting SSCs to be included in the scope of the maintenance rule. In order to verify that the licensee has correctly identified and documented SSCs at its facility, the inspector should perform the following reviews.
a.
Safety-Related SSCs ner 50.65fb)(1).
The scope of the rule includes safety related SSCs that are relied upon to remain functional during and following a design basis event to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the 10 CFR 100 guidelines. All licensees should have a well-defined list of safety-related SSCs in their final safety analysis report (FSAR), Q-lists, or master equipment lists (MEL).
In general, all SSCs on these lists are safety related and would be included within the scope of the maintenance rule.
However, for convenience, some licensees may. have categorized some SSCs as safety related on their Q-list even though they do not meet the definition of safety related.
These SSCs could be excluded from the scope of the maintenance rule if the licensee can show that these SSCs are truly not safety related.
d
' Issue Date: 08/31/95 62706
---wn-
-u
4 i
\\
1 The inspector should independently review the FSAR, Q-list, er MEL to j
ooled a son,la cf SSCs and then v:rify that the lic nsee has included.
these safety-related SSCs within the' scope of the maintenance rule..
a b.
Non-Safaty. Aelated SSCs That are Relied Unen to Mitiaate Accidents or-Transients ner 50.65fbif2'(1).
The FSAR, the emergency operating l
procedures (EOPs), and the LPE insights describe non-safety-related SSCs needed to mitigate accidents and. transients.
Examples of non-safety-i related SSCs that are sometimes used in the FSAR analysis to mitigate i
accidents include: the condensate storage tank (supply to auxiliary feedwater), the fire-suppression system, and the boric acid transfer j
system used for emergency boration and makeup water to the refueling i
water storage tank.
1 Inspectors may find that some utilities have made design changes that add l
a non-safety related SSC that provides an accident mitigating function.
i Such SSCs should be included within the scope of the rule. The inspector i
may find such information from IPE insights and the E0Ps.
The IPE insights and the licensee's scheduling and planning group may also provide information on when the design change is scheduled to be completed.
For example, at one utility a design change was made which utilized an existing non-safety related diesel generator to provide j
emergency power to a charging pump that provides water flow to reactor coolant pump seals (i.e., to mitigate seal loss of coolant accident j
(LOCA) events) under station blackout conditions.
At other utilities, design changes were made which added a non-safety related diesel generator and an additional offsite power source to address station blackout concerns. In all cases, the affected SSCs provided an accident mitigating function and, therefore, were required to be added to the scope of the rule.
1 During one of the pilot maintenance site visits, the team noted that the i
licensee had excluded the control room annunciators from the scope of the rule. The licensee explained that these control room annunciators were not required for operation of systems required for mitigating accidents because they only served as backups for other plant instruments and controls. The NRC inspectors questioned licensed control room operators i
at the plant who confirmed that these annunciators often gave the first j
indication of an evolving transient or accident.
Based on this confi mation, the inspectors concluded that thess annunciators were l
required for mitigating accidents or transients and, therefore, should be included within the scope of the rule at that site.
j 1
i The inspector should independently review the FSAR, IPE insights, and emergency operating procedures (EOPs) to identify a sample of non-safety i
related SSCs relied upon to mitigate accidents or transients.
The inspector should then compare this list of SSCs with the list of non-safety related SSCs identified by the licensee.
The inspector should i
i review the licensee's determinations and verify that they appear to be reasonable. The inspector should ask the licensee to provide reasonable l
justification for.any SSCs that were excluded from the scope of their program.
J Non-Safety-Related SSCs That Are Used in Emeroency Oneratina Procedures l
c.
j (EOPs) oar 50.65fb)(2)(1).
Paragraph (b)(2)(1) of the maintenance rule i
states that SSCs used in E0Ps are required to.,be included within the scope of the rule. ' However, many. utilities have included more SSCs in their E0Ps than are required by the Emergency Procedure Guidelines. Some j
1[
62706 Issue Date: 08/31/95 i
4
n_.--.
sf thess SSCs were included bec:use they c:uld possibly protect cther cguipamed from being damaged er c:ntaminated in the event, cf an emergency, not because they are relied upon in the licensee's accident analysis. Subsequently, the NRC staff endorsed the guidance contained in section 8.2.1.3 of NUMARC 93-01 which allows the exclusion from the rule l
of those non-safety-related SSCs that do not add significant value to the i
mitigation function of an E0P by providing a significant fraction of the total functional ability required to mitigate core damage or radioactive release. Some examples of SSCs that might be excluded on this basis are I
inttrumentation that provides redundant local information and does not I
i provide a control function, fire-protection system capacity capable of j
supplying only a small fraction of what is required to mitigate the accident, and portable emergency equipment that is available from offsite sources and is not under utility control.
Conversely, if a fire-protection system provides a large fraction of the cooling water supply i
that is required to mitigate the accident, it should be included within J
l the scope of the rule.
j The inspector should independently review the E0Ps to identify a sample of non-safety-related SSCs and verify that they are included within the scope of the rule or were excluded based on the criteria described above.
The inspector should select a sample of SSCs from the E0Ps that were excluded from the rule and verify that the licensee had followed their own methodology for excluding the SSC from the rule and that the exclusion appears to be reasonable.
The inspector should note that some E0Ps reference Abnormal Operating Procedures (A0P) that perform accident mitigating functions.
SSCs in AOPs that perfom accident mitigating functions should be included under the scope of the maintenance rule; SSCs referenced in AOPs that do not provide accident mitigating functions should not fall under the scope of the rule.
d.
Non-Safetv-Related SSCs Whose Failure Could Prevent Safetv-Related SSCs From Fulfillina Their Intended Function as ner 50.65(b)(2)(ii).
To identify failure modes of non-safety-related SSCs that will directly affect safety-related functions, the licensee should investigate the systems and their interdependencies.
A utility should rely on actual plant-specific and industrywide operating experience, prior engineering evaluations such as PRA, IPE, environmental qualification (EQ), and 10 CFR Part 50 Appendix R analyses.
Industrywide operating experience should be used to the extent practical to preclude unacceptable performaNe experienced at a similar plant from being repeated. Examples of such non-safety-related SSCs could include an instrument air system that opens containment isolation vent and purge valves, a fire damper in j
the standby gas treatment system whose failure would impair air flow, ventilation systems that can provide cooling to safety related systems, or a condensate storage water tank that is a source of water.for emergency core cooling systems (ECCS). However, it is not intended that licensees attempt to determine hypothetical failures that could result from system interdependencies that have not previously been experienced or analyzed.
NUMARC 93-01, Section 8.2.1.4, provides additional i
guidance. See paragraph 03.04, step f, below, for exceptions.
The inspector should review records of failures 'of non-safety-related systems and attempt to identify a sample of 550s the failure of which, could prevent a safety-related SSC from fulfilling its intended function.
The inspector should verify that the licensee has included these SSCs Issue Date: 08/31/95 62706
crithin the scope cf tha maintcnance rule.
If it is n3t feasible to ccicct an indeprnd:nt samplo in this uanner, the inspecter sh2uld perf:re a review of the non-safety related SSCs that were identified by the l'
licensee as likely to prevent safety related SSCs from fulfilling their intended function.
The inspector should review the licensee's determinations and verify that they appear to be reasonable, i
l j
e.
Non-Safety-Related $$Cs Whose Failure Could Cause a Scram or Actuation of a Safety Related System as ner 50.65(b)(2)(iii). Licensees are required l
to identify, on the basis of utility-specific and industrywide operating
{
experience, those non-safety-related SSCs whose failure has caused or could cause a reactor scram or safety system actuation.
The licensee j
should consider other engineering evaluations, such as PRA,
- IPE, environmental qualification (EQ), and 10 CFR Part 50, Appendix R, analyses.
The licensee should also consider industrywide operating experience and any event that has occurred at a similarly configured plant. However, the licensee is not required to determine hypothetical i
failures that could result from system interdependencies that have not i
previously been experienced or analyzed.
Examples of transient initiators from the FSAR that are analyzed include turbi.ie trips, loss of l
feedwater, and loss of instrument air.
i l
During the pilot maintenance site visits, the inspectors noted several i
examples of non-safety-related SSCs whose failure had, or could have, j
caused plant trips.
Some of these systems were circulating water, condenser vacuum, extraction steam, non-ESF buses that power reactor i
coolant pumps, radiation monitoring, site grounding system, shield walls i
j that separate the station startup transformers, the plant computer, heat tracing and freeze protection, reactor coolant pump vibration monitoring, l
cathodic protection systems, screen wash water, gland steam, gland seal i
water, generator gas, turbine lube oil, and turbine generator seal oil.
j NUMARC 93-01, Section 8.2.1.5, provides additional guidance.
1 j
The inspector should review licensee event reports, available operating i
history information, PRA insights, and other engineering evaluations to identify SSCs that have actually caused, or could cause a scram or safety system actuation and should verify that those SSCs had been included in l
the licensee's maintenance rule program. The inspector should note that i
because a system is very reliable, or contains redundant trains, or i
because operator action could prevent a scram are not reasons for excluding SSCs from the scope of the rule. These considerations are not j
included in paragraph (b)(2)(iii) of the rule and therefore should not be l
considered when making scoping determinations.
l f.
SSCs Outside the Scope of the Maintenance Rule.
Unless they meet the i
criteria described above, the following categories of SSCs are generally I
outside the scope of the maintenance rule:
fire protection systems, seismic class II SSCs installed in proximity to seismic class I SSCs, j
security systems, and emergency facilities described in the emergency plan.
Further guidance is provided in section 8.2.1.6 of NUMARC g3-01.
4 1
The inspector should not expect that these SSCs would be included within
?
the scope of the maintenance rule because maintenance requirements for these categories of SSCs are covered in other regulations.
i SwiMhvard Activities.
Regulatory Guide 1.160 s monitoring efforts under the maintenance rule,,tates that the scope of l
g.
as defined in 10 CFR i
j 50.65(b), encompasses those SSCs that directly and significantly affect 62706 Issue Date:
08/31/95 2
i plant cperations, regardicss sf which organizaticn actually perfoms the main'snam.s activities.
Maintenance activities performed by corporate u
maintenance or contractor personnel (rather than plant personnel) are not i
excluded from the scope of the rule. Since maintenance activities that l
are performed on SSCs in the switchyard can directly affect plant i
operations, electrical distribution equipment out to the first inter-tie with the off-site distribution system (i.e., equipment in the switchyard) i should be considered for inclusion under the scope of the maintenance rule.
Plant management should be aware of, and should have the ability to control, these activities even.if the switchyard is offsite, i
j The inspector should verify that the appropriate SSCs in the switchyard l
are included within the scope of the maintenance rule.
i h.
Safety Systems with Non-safety Functions.
Examples provided in Section 8.2.1 of NUMARC 93-01 illustrate that some safety-related systems may perform safety-related as well as non-safety-related functions. In such cases, the components that perform only a non-safety-related function may i
not necessarily come under the scope of the rule. For example, the non-i safety-related function of an ECCS could be to fill the safety injection i
The inspector should not expect that these SSCs with non-safety-related functions will necessarily be included within the scope of the maintenknee rule by the licensee.
1.
Documentation. The licensee's process for reviewing and selecting SSCs shall be documented. The licensee shall also develop and maintain an up-to-date status that identifies all those SSCs selected for inclusion within the scope of the rule..This status could be maintained using a manual list, electronic database, or other methods.
The licensee's process must include provisions that take into account modifications or changes to the plant that could result in SSCs being added to or deleted from the scope of the maintenance rule.
NUMARC 93-01, Section 13.2, provides additional guidance on documenting the SSC selection process.
The inspector should verify that the licensee has developed adequate documentation and has established a process to control this activity.
i Summary for 03.04. Stone of the Rule 50.65(b). stens a throuah 1.
If the inspector identifies one or more significant examples, or several minor examples; of failures to identify SSCs required to be within the scope of the rule, the inspector should examine the licensee's process and procedures to determine why.
they were not included.
The results of the pilot maintenance site visits demonstrated that licensees were able to identify most of the SSCs that were within the scope of the rule. The number of additional SSCs that the NRC team concluded should have been included within the scope of the rule were: zero at two sites, one at four sites, three at one site, four at one site, and fifteen at one site. Most of these were in the category of nonsafety related SSCs whose failure could cause a reactor scram or safety system actuation.
03.05. {ffectiveness of Emeroency Diesel Generator Maintenance Activities. The inspection requirements and guidance given in preceding sections of this inspection procedure apply to all SSCs within the scope of the maintenance rule, including the emergency diesel generators. However, Regulatory Guide 1.160 does provide additional specific guidance for emergency diesel generators.
Issue.Date: 08/31/95 62706
.4
4.
a.
Tarvet Reliability Values as Goals or Performance Criteria. The station i'
iniacsout rule (10 CFR 50.63) requires each licensee to perform plant -
specific coping analyses to ensure that a plant can withstand a total l
loss of ac power for a specified duration and to determine appropriate actions to mitigate the effects of a total loss of ac power. - Most licensees endorsed the program embodied in NUMARC 87-00 (Ref. 9) and i
subsequently docketed commitments to maintain a target EDG reliability l
value of either 0.95 or 0.975. These target values sg.uld be used as the basis for gaali or as nerformance criteria for EDG reliability under the i
maintenance rule (10 CFR 50.65).
In addition, as part of their plant-specific coping analyses, licensees were allowed to use plant-specific data concerning unavailability due to maintenance. This unavailability
]
due to maintenance, assumed in a plant-specific individual plant l
examination (IPE) analysis, could also be used as the basis for gaals. or oerformance criteria for EDG availability under the maintenance rule.
i l
The inspector should verify that the licensee has either (1) incorporated i
these commitments into its maintenance program as goals or performance criteria or (2) established an alternate method of meeting licensee commitments to the station blackout rule and the requirements of the j
maintenance rule.
j b.
Early Imolementation of the Maintenance Rule for Emeraency Diesel l
Generators. Generic Letter 94-01 allows licensees to remove accelerated 4
testing and special reporting requirements for emergency diesel
. generators from the technical specifications or other docketed f
commitments and still satisfy commitments made in response to the station i
blackout rule (10 CFR 50.63) earlier than the effective date of the i
maintenance rule, July 10, 1996.
This is accomplished by electing to l
implement the provisions of the maintenance rule and associated i
regulatory guidance (RG 1.160) for the emergency diesel generators, including all requisite support SSCs (cooling water, instrument air, l
etc.).
If the decision is made to remove these commitments, then the l
effectiveness of maintenance of the emergency diesel generators would be j
subject to inspection under the provisions of the maintenance rule
'i beginning within 90 days of the issuance of. the license amendment or the l
granting relief from a docketed commitment or the effective date of the rule, July 10, 1996, whichever occurs first.
For licensees that have elected early implementation of the maintenance i
rule as described in Generic Letter 94-01, the inspector should verify the licensee has implemented all requirements of the maintenance rule and the associated regulatory guidance within the schedule described above.
62706-04 RESOURCE ESTIMATE Completion of this inspection procedure is expected to take, on the average, 480 inspector hours [four inspectors for three weeks (one week prep, one week onsite, one week documentation)).
62706-05 REFERENCES
- 1. 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (the maintenance rule) 62706 Issue Date: 08/31/95
2.,,10 CFR 50.63, ' Loss of All Altcrnatsi Current Power,' (station blackout rusop 4
l 3.
Generic Letter 94-01, " Removal of Accelerated Testing and Special Reporting g
Requirements for Emergency Diesel Generators" 4.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.160, " Monitoring the j
Effectiveness of Maintenance at Nuclear Power Plants," June 1993 3
i 5.
Nuclear Management and Resources Council, NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," May 1993, (NUDOCS accession number 9308180091) 6.
NUREG 1526, " Lessons Learned From Early Implementation of the Maintenance Rule at Nine Nuclear Power Plants," June 1995 7.
U.S.
Nuclear Regulator Commission, " Monitoring the Effectiveness of i
Maintenance at Nuclear Power Plants," Federal Reaister, Vol. 56, No. 132, Wednesday July 10, 1991, pages 31306 to 31324 i
8.
U.S.
Nuclear Regulator Commission, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Federal Reaister, Vol. 58, No. 53, Monday i
March 22, 1993, Pages 15303 to 15305 9.
Nuclear Management and Resources Council, NUMARC 87-00, Revision 1,
" Guidelines and Technical Bases for NUMARC Initiatives Addressing Station I
Blackout at Light Water Reactors, August 1991"
- 10. Letter from Zack T. Pate to James M. Taylor dated March 1,1995, transmitting the guideline, " Managing Maintenance During Fower Operations" END 9
i 4
Issue Date:
08/31/95 62706
l-i 1
App:ndix A I'
ENFORCEMENT GUIDANCE i
The maintenance rule is broad-based and performance-oriented; its goal is to ensure that licensees monitor and assess the effectiveness of their maintenance activities in order to ensure that SSCs will be capable of performing their l
intended functions. One factor in the Commission's decision to promulgate the rule was a belief that a need existed to broaden the Commission's capability to i
take timely enforcement action when maintenance activities fail to provide reasonable assurance that safety-significant SSCs are capable of performing their j
intended functions.
4' The form and philosophy of the rule allows (encourages) " maximum flexibility" for licensees in establishing their programs to meet the intent and requirements of 3
I the rule.
Within these broad requirements, enforcement action would be l
appropriate for licensees who have inadequately implemented aspects of the rule or whose performance demonstrates a continuing ineffectiveness of maintenance 1
activities.
4 l
Escalated enforcement would be appropriate where there was a f ailure to deal in i
I good faith to implement the requirements of the rule or where significant failures of SSCs could have been prevented through effective implementation of the maintenance rule.
i l
The inspector should be aware that the maintenance rule does not supersede any existing requirements, such as those contained in 10 CFR Part 50 (including 4
Appendix B and other sections) or a licensee's technical specifications. These requirements remain in efnct for maintenance activities. When preparing notices i
of violation for maintenance activities, the inspector should consider citing i
against the requirements of the maintenance rule whenever a licensee has violated i
a specific requirement of the maintenance rule, such as those described in the j
examples listed above.
However, where maintenance problems are caused 'by licensee activities not specifically related to maintenance rule, it' may be 4
preferable to cite against the requirements of Appendix B or the plant technical specifications.
Examples of such violations could include failure to take i
corrective action or failure to follow documented procedures or instructions.
I Examoles of Activities That Would Be_ Violations of the Maintenance Rule:
i l
1.
Fai'ure to include safety or non-safety related SSC (as defined in 10 CFR l
50.65 (b)(1) and (2)) within the scope of the program would be a j
j violation.
2.
Failure to establish gnis for SSCs in (a)(1) would be a violation.
i Establishment of goals that are inconsistent with safety significance or industry experience would be a violation.
i i
3.
Failure to establish a monitoring program that adequately supports the j
goals set under 10 CFR 50.65 (a)(1).
The monitoring program must be sufficient in scope and frequency to adequately support a determination i
i as to whether SSCs are meeting their assigned gotis.
Lack of such a I
monitoring program would be a violation.
l 4.
Failure to evaluate the results of monitoring activities such that a goal
)
is exceeded without timely licensee knowledge of appropriate corrective action being taken would,be a violation.
Issue Date: 08/31/95 A-1 62706, App. A t
4 y
5.
Failure to take timely or appropriate currective actitn wh:n a goal is exceeceo.
kapetitiva failures due to inappr priate er ineffective corrective action could be considered a violation under this rule for all i
SSCs within the scope of this rule or a violation of 10 CFR 50 Appendix 8 for safety-related SSCs.
5.
Failure to analyze maintenance preventable failures of SSCs covered under (a)(2) would be a violation.
Failure to develop a rationale or dustification for continuing to cover an SSC under (a)(2) after it has experienced a repetitive ~ maintenance preventable failure would be a y
violation.
4 j
7.
Failure to perfom the required periodic assessment for the activities described under (a)(3) would be a violation.
I 8.
Failure to reasonably balance reliability and unavailability due to monitoring / maintenance activities would also be a violation.
9.
A failure to 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 technical specifications or 10 CFR 50 Appendix B.
Er-les of Activities That Would Not Necessarily Be Violations of the l
Maintenance Rule:
i 1.
. 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.
2.
It is intended that licensees be allowed flexibility when establishing goals and not be subject to enforcement on goals selection as long as these goals are reasonably based on safety significance 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 reasonably based on safety significance and industry operating experience.
3.
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 #3 and #4 above).
4.
Since the rule states that, in performing monitoring and preventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on perfomance of safety functions, the failure to perform this assessment would not be a violation.
However, where this failure to perform a safety assessment contributed to the severity of another violation of the regulations, or er erbated the consequences of an accident, the failure to perform a safety assessment could be taken into account as a mitigating factor in any escalated enforcement action.
5.
Deficlencies in records and documentation would not in themselves be subject to enforcement. However, if they contribute to an 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, j
.f2706, App. A A-2 Issue Date: 08/31/95 l
l