ML20137M439

Summary of CRGR 970207 Meeting 301 Re Proposed Rev 2 to RG 1.160, Monitoring Effectiveness of Maint at Npps. List of Attendees Encl

ML20137M439
Person / Time
Issue date:	04/03/1997
From:	Ross D Committee To Review Generic Requirements
To:	Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
RTR-REGGD-01.160, RTR-REGGD-1.160, TASK-*****, TASK-RE NUDOCS 9704080087
Download: ML20137M439 (39)

Text

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- UNITED STATES s

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066 4 001 April 3, 1997 MEMORANDUM T0:

L. Joseph Callan Executive Director for Operations C

QLO FROM:

Denwood F. Ross, Jr., Chairman Committee to Review Generic Requiremen.,

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 301 The Comittee to Review Generic Requirements (CRGR) met on Friday, February 7,

~1997, from 10:30 a.m. to 12:00 noon. A list of attendees is provided in.

B. Boger and R. Correia (NRR) presented for CRGR review and endorsement the pro)osed Revision 2 to Regulatory Guide (RG) 1.160, which endorses' Revision 2 to 4UMARC 93-01, " Industry Guideline For Monitoring The Effectiveness Of Maintenance At Nuclear Power Plants" (April 1996 version), and provides certain clarifications.

No new requirements are either intended or being imposed by this RG: it only provides an acceptable method for implementing the Maintenance Rule. Although the existing RG 1.160. Revision 1 and NUMARC 93-01.. Revision 1, are sufficient for implementing the Maintenance Rule, experience based on nine plant site visits conducted between September 1994 and March 1995, and public and industry coments, have indicated that in certain instances more specific guidance may L,e hel)ful. The draft version of 1

the proposed revision of RG 1.160 was issued for pu)lic comment on September 11. 1996, as DG-1051.

In the proposed revision the staff has addressed the public coments submitted, the comments received from the industry during Maintenance Rule baseline inspections, as well as those received during two public meetings held on October 15. 1996, and January 9.

]

1997.

The CRGR made several comments on the technical aspects of the aro)osed revision to RG 1.160.

Specifically, the Committee noted that tie RG and NUMARC-83-01 are tied to one another; neither complete without the other, therefore, the Federal Reaister notice must include a comment to that effect.

Furthermore, the Comittee recognizes this ue as a rather sensitive point

/

which places a greater burden on the inspection guidance.

The Comittee

/ '/

strongly recommended that the staff must ensure that the relevant NRC Ins-)ection Procedures stand alone.

The Comittee specifically commented on

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lacc of clarity of (even seemingly conflicting statements in) Section 9.4.5 of NUMARC 93-01 and recommended that the staff include a clarification in the /)[25 j RG. As a resul+ the staff added a new Section 1.8 to address this.

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e 080009 9704080087 970403 h

[h/77 PDR REVGP NRCCRGR

'D7 MEETINO301 P!"t s

l P-L. Joseph Callan,

Following the staff's satisfactory incorporation of the Committee's comments, the revised generic letter was endorsed for issuance on February 13, 1997. contains the details.

In accordance with the E00's July 18, 1983, directive concerning " Feedback and Closure of CRGR Review." a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decision making.

Questions concerning these meeting minutes should be referred to Raji Tripathi (415-7584).

Attachments: As stated cc:

Commission (5)

SECY J. Lieberman OE E. Halman, ADM H. Bell, OIG K. Cyr. OGC J. Larkins. ACRS Office Directors Regional Administrators. RI/RII/RIII/RIV CRGR Members '

B. Boger. NRR Distribution of CRGR Minutes 301 CentralFTiew/att..

PDR (NRC/CRGR) w/o att.

CRGR SF CRGR CF S. Treby E. Jordan J. Mitchell S. Black R. Tripathi A. Thadani R. Correia T. Bergman G. Holahan i

S:\\CRGR\\ MINUTES.301 CRGR:AE0 0

EOD RTripath*/a D oss 4/ 2 /97 4/

97 i

s L.. Joseph Callan,

4 Following the staff's satisfactory incorporation of the Committee's comments.

the revised generic letter was endorsed for issuance on February 13, 1997.

j contains the details.

In accordance with the ED0's July 18, 1983, directive concerning " Feedback and 1

Closure of CRGR Review " a written response is required from the cognizant j

. office to report agreement or disagreement with the CRGR recommendations in these minutes.

The response is to be forwarded to the CRGR Chairman and if-l there is disagreement with the CRGR recommendations, to the ED0 for decision making.

Questions concerning these meeting minutes should be referred to Raji Tripathi (415-7584).

1 I

LAttachments:

As stated cc:

Commission (5)

SECY J. Lieberman, OE E. Halman. ADM H. Bell, OIG 4

K. Cyr. 0GC J. Larkins, ACRS Office Directors Regional Administrators, RI/RII/RIII/RIV 1

CRGR Members B.-Boger NRR e

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, to the Minutes of CRGR Meetina No. 301 Attendance List February 7,1997 CRGR Members NRC Staff D. Ross B. Boger B. Sheron (for F. Miraglia)

S. Black C. W. Haughney (M. Knapp)

R. Correia J. Mur)hy T. Bergman D. Dam)1y A. Serkiz C. W. Hehl G. Holahan CRGR Staff R. Tripathi

< of the Minutes of CRGR Meetina No. 301 Proposed Revision 2 to Reaulatory Guide 1.160

'"Monitorina the Effectiveness Of Maintenance At Nuclear Power Plants" February 7. 1997 TOPIC CRGR review and endorsement of the proposed Revision 2 to Regulatory Guide (RG) 1.160. which endorses Revision 2 to NUMARC 93-01. " Industry Guideline For Monitoring The Effectiveness Of Maintenance At Nuclear Power Plants" (April 1996 version), and provides certain clarifications.

No new requirements are either intended or im)osed by this RG: it only provides an acceptable method for implementing the Maintenance Rule.

The intent of the original Regulatory Guide 1.160 (issued June 1993) and the endorsed industry guidance document. NUMARC 93-01. Revision 1 (May 1993 version), was to provide general guidelines to the licensees in implementing the Maintenance Rule (10 CFR 50.65).

In January 1995. Revision 1 to the RG was issued to reflect the amendment to 10 CFR 50.65(a)(3) that changed the requirement of performing the periodic evaluation from annually to once per refueling cycle, not to exceed 24 months between evaluations.

Although the existing RG 1.160. Revision 1, and NUMARC 93-01. Revision 1. are sufficient for implementing the Maintenance Rule, experience based on nine plant site visits conducted between September 1994 and March 1995, and public and industry comments, have indicated that in certain instances more specific guidance may be helpful.

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The draft version of the proposed revision of RG 1.160 was issued for public comment on September 11, 1996 as DG-1051.

In the proposed revision the staff has addressed the public comments submitted, the comments received from the industry during Maintenance Rule baseline inspections, as well as those received during two public meetings held on October 15, 1996 and January 9.

1997.

BACKGROUND 1

(1)

Memorandum dated January 30, 1997 from A. C. Thadani to D. Ross. (hand-delivered to the CRGR staff on January 31. 1997). " Request for Review and Endorsement of the Proposed Revision 2 to Regulatory Guide 1.1.60,

' Monitoring the Effectiveness of Maintenance at Nuclear power Plants' "

l This review material (CRGR Item No.153) was distributed to the members (e-mailed and Fed Ex'd to Bill Hehl) on February 4. 1997.

The attachments are as follows-i 1.

Proposed Regulatory Guide 1.160. Revision 2. " Monitoring The Effectiveness Of Maintenance At Nuclear Power Plants" 1

NRC's endorsement of NUMARC 93-01 was not to be regarded as the endorsement of the references contained therein.

i 2.

Response To CRGR Charter Questions 3.

Draft Regulatory Guide 1051 (Proposed RG 1.160. Revision 2) 4.

Staff Evaluation of Public Comments on DG-1051 5.

Note from Gary M. Holahan to Bruce A. Boger dated August 14. 1996 6.

Note from Gary M. Holahan to Bruce A. Boger dated January 21, 1997 (ii)

E-mail from R. Tripathi to the CRGR members, dated January 17. 1997, and subsequent distribution of the following background material:

1.

NEI guidance document NUMARC 93-01. Revision 2. dated April 1996 (the document to be endorsed by the Reg. Guide) 2.

Maintenance Rule Guideline Book (The Blue Book) 3.

SECY-95-265. dated November 1, 1995 4.

Note from Gary Holahan to Ashok Thadani. "NUMARC-01 Rev. 2.

' Guidance for Maintenance Rule'." dated June 10. 1996, expressing his disagreement on proposed endorsement of the subject guidance document. (A) contains the presentation material used by the staff at the meeting.

ISSUES /0UESTIONS Note: In the context of background material Item (i) attachments 5 and 6. and background material Item (ii)(4), on February 4th, at the CRGR Meeting No. 300. Brian Sheron (NRR) had indicated that there are no outstanding differences within NRR.

Footnote 6 in the draft proposed RG 1.160 may be an " interim partial resolution" of some of Gary Holahan's concerns.

The Committee made several comments on the technical aspects of the proposed revision to RG 1.160.

Speci fically, o

The Committee noted the s)onsoring Division did not seek concurrence of Division of Engineering (JE): the last DE had concurred was Revision 0 of the subject RG.

e On Page 9: Definition and role of Maintenance Preventable Functional Failure (MPFF) - consistency in using MPFF as a measure of reliability, is not clear.

The Committee noted that this may present enforceability

problems, e

On Page 10. Section 1.5. " Monitoring Structures":

The Committee commented that it should be clearly stated that the licensees performing inspections under ASME Sub Sections IWE/IWL. as endorsed in 10 CFR 2

I 1

~50.55(a), will get' full credit.

In response. the staff identified an

.)

' existing sentence in this section, "... Consistent with the intent of the rule.. licensees should use their existing structural monitoring programs (e.g., those required by other regulations or codes) to the maximum i

extent practical..." which satisfies the Committee's' recommendation.

e Page 12: In reference to Section 1.7.2. the Comittee agreed that manually-initiated scrams ARE important; however, also casually noted that this definition is different than that used for the INP0 Safety System Performance Indicator.

e the Committee note that the RG and NUMARC 83-01 are tied to one another; neither complete without the other, therefore, the Federal Register 1

notice must include a coment to that effect.

Furthermore, the Committee recognizes this tie as a rather sensitive pcint which places a greater burden on the inspection guidance. The Committee also recomended that the staff must ensure that the relevant NRC Inspection Procedures stand alone.

e' The Comittee specifically commented on lack of clarity (even conflicting statements) of the Section 9.4.5 of NUMARC 93-01, and l

recommended that the staff include a clarification in the RG.

(The staff added a new section 1.8 to address this.)

There was a discussion on the use of the verbs "should" and "must." The i

e Committee asked the staff to clarify its intent when using the latter in the text of the proposed revision recommending that when appropriate, 4

specific citation of the Maintenance Rule be included.

Atachment 2(B) contains the red-line/ strike-out version of the RG. as endorsed by the CRGR.

1 BACKFIT CONSIDERATIONS The proposed revision to RG 1.160 does not constitute a backfit as no new requirements are either intended to be imposed or sanctioned.

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~ Attachment 2(A) of the Minutes of CRGR Meeting No. 301 Prooosed Revision 2 to Regulatory Guide 1.160-

" Monitoring' the Effectiveness Of Maintenance At Nuclear Power Plants" February 7,1997 b

Presentation Material Used by the Staff at the Meeting 4

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E

i CRGR MEETING 301 I

RG 1.160, REVISION 2 "THE MAINTENANCE RULE" February 7,1997 Bruce A. Boger Richard P. Correia i

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.a PURPOSE 4

DISCUSS CHANGES FROM RG 1.160 REV 1 TO REV 2 l

AND ADDRESS CRGR QUESTIONS ON REV 2 TO OBTAIN CRGR ENDORSEMENT 6

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2

RG 1.160, REV 0 Endorsed NUMARC 93-01, Rev 0

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Staff, CRGR, ACRS, and Commission all endorsed i

RG 1.160, Rev 0 t

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Issued in June 1993 t

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.k RG 1.160, REV 1 Reflected change in MR to periodic evaluations not i

to exceed 24 months (from Rev 0 not to exceed 12 months) i i

.Still endorsed NUMARC 93-01, Revision 0 i

e Not reviewed by CRGR or ACRS l

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m DG 1051 (PROPOSED RG 1.160, REV 2)

Proposed to endorse NUMARC 93-01, Rev 2, with

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clarifications Clarifications to RG 1.160, Rev 1 Issued for Public Comment 9/15/96 Public Comment Period Ended 11/15/96 Only 3 Public Comments Received s

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RG 1.160, REV 2 1

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l Endorses NUMARC 93-01, Rev 2 with clarifications

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i Address changes to maintenance rule since l

RG.1.160,Rev 1 Explicitly states existing staff positions Editorial clarifications to text i.

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r SPECIFIC CLARIFICATIONS IN RG 1.160, REV 2 Introduction revised to address permanently I

shutdown and defueled plants in accordance with rule change that was effective 8/28/96. Affects l

paragraph (a)(1) of the MR with no expected impact

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on licensees. [NEWIN REV 2]

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Introduction revised to address change in definition l

to safety-related that was made in seismic rulemaking on 12/11/96. Affects paragraph (b)(1) of the MR, no expectod impact on licensees. [NEWIN i

REV 2]

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i SPECIFIC CLARIFICATIONS - CONTINUED Noted that NRC staff endorsement of the safety l

significance ranking process described in NUMARC i

93-01 is limited to the MR. l/N DG 1051] Also notes that a reg guide on use of PRA in regulatory matters may be issued in early 1998, and that RG 1.160 will l

probably be revised to reference that guide at that time. Any backfit issues would be addressed at the j

time of that future revision. [NEWIN REV 21 i

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Noted that the preferred terminology is high/ low l

safety significance versus risk significance. l/N DG i

l 1051]

Modified EDG discussion to be specific to EDGs l

and the SBO. [NEWIN REV 2]

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SPECIFIC CLARIFICATIONS - CONTINUED Scoping l

Could cause (IN DG-1051jf l

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Relied upon to mitigate /EOPs (NEWIN REV2j' Scope by function vs system (NEWIN REV 2]

- Multiple Design Functions [lN DG 1051jf Definition of Maintenance [NEWIN REV 2j' i

Timeliness [NEWIN REV 2]

MPFFs as reliability indicator (NEWIN REV 2]

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SPECIFIC CLARIFICATIONS - CONTINUED t

Monitoring Structures [NEWIN REV 2J Definition of Standby JREV21 j

4 Normally Operating LSS SSCs

- Cause Determinations llN DG 1051J l

l Unplanned Manual Scrams (NEWIN REV 2J I

- SSC-specific performance criteria [NEWIN REV 2]

l SSCs in (a)(1) llN DG 1051)

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ISSUE SHEET "SHOULD" VS "MUST" "MUST" ONLY APPLIES WHEN USING NUMARC 93-01 APPROACH. LICENSEES CAN PROPOSE ALTERNATIVE METHODS TO MEET THE RULE Used "must" in RG to indicate that if not done, l

licensee would be required to demonstrate that l

alternative approach was equivalent.

Pg 7; licensees must periodically balance unavailability and reliability of the EDGs. This is a specific requiremont of the rule [(a)(3)].

l Pg 9, $1.3, licensee must take timely actions.

Derived from rule requirement that can only be in l

(a)(2) if demonstrate effective PM.

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ISSUE SHEET "SHOULD" VS "MUST" Pg 9, g1.4; licensees must demonstrate consistency

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between MPFFs and assumptions in the risk l

analysis. Required only if the licensee voluntarily l

takes the risk approach described in NUMARC 93-l

01. Staff endorsement of NUMARC 93-01 as one I

acceptable method is contingent upon licensees undertaking all the 93-01 activities.

Pg 9, $1.4; adequate technical justification for the a

performance criterion must be provided.

Necessary to meet the requirements of the rule. SSCs can only be in (a)(2) if the licensee demonstrates i

effective PM. In NUMARC 93-01 this is accomplished through performance criteria.

Performance criteria must have a sound technical basis to be valid and conclude that effective PM has been achieved by meeting the performance criteria.

12

ISSUE SHEET - EDGs Reference to RG 1.155; Staff does not consider reference necessary. Licensees do not necessarily l

need to use same criteria as for SBO (RG states "could"). Guidance currently encourages use of i

" existing programs" in implementing the 1

l maintenance rule, which would include licensee activities related to RG 1.155.

1 EELB Concurrence. EELB was involved RG 1.160, l

Rev 0. Changes made in Rev 2 are editorial, and pertain to maintenance rule language not technical aspects to EDGs. EELB concurrence on changes is not necessary.

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Fhos:-

Raji Tripathi'

.To:.

WND2 WNP5.BAB2, WND2.WNP5.SCB i

.Date:.

- 2/14/97 9:01am l

Subject:

CRGR ENDORSEMENT Bruce Boger/Suzie B1ack, NRR

. T0:

SUBJECT:

CRGR EN00RSEMENTLOF THE PROPOSED REV. 2 of REG. GUIDE 1.160 l

On February 7,1997, during'its 301st meeting : the Committee to Review Generic Requirements (CRGR) reviewed the subject Reg. Guide. Subsequently, the.

cognizant NRR staff worked with the CRGR staff to revise the text of this-i 3roposed generic action to address the Committee's comments. On the lith of r bruary, the CRGR staff met with the cognizant staff to review the CRGR e

. recommendations. The staff has developed a red-line/ strike-out version of the

" Reg. Guide incorporating the CRGR recommendations plus other editorial changes. This-version (RG 160.ND9) was received on the morning of February 13th. and it appears to have' addressed most of the Committee's comments.

The~ Acting Chairman, CRGR has accepted the CRGR staff's recommendation to endorse this revisior. subject to the following changes to the newly-added l

Section 1.8 and also recognizing that there are additional changes reflected in this red-line\\ strike-out version (some of them are only editorial and others seem reasonable) which were not the subject of discussion at the CRGR

]

meeting. The CRGR endorsement is, therefore, limited only to the issues discussed at the meeting.

j (Note: This e-mail should be saved as a Wordperfect file to see the Red-lined portions; only those struck-out are noticeable here.)

......1.8 Clarification to Section 9.4.5, MPFFs The third paragraph of section 9.4.5, provides guidance regarding the licensee's options following an W puent failure, and whether, as a result of the licensee's c0rrective N at y actions, subsequent failures would be i

considered MPFFs.

In particulalF.~t s paragraph addresses actions where the I

failure was caused by a design deficiency.

Id ally, 10icensees w6ould make design modifications to eliminate the poorly designed squipment. ~However, if the licensee determines that such an ap3 roach is not cost effective (e.g.,

-fsplidyptM{dipaR[p[ prohibitive), t1e licensee has two options f6] Tow'ir@

cost 'of modification is

~~~

M$3f(MedI@jpp$:

(1) Replace or repair the failed equipment.

Then. -fjake adjustments where necessary to the. preventive maintenance program to prevent recurrence of the failure.

Subsequent failures for the same cause due to inadequate corrective or preventive maintenance would be MPFFs, and could be repetitive MPFFs.

j (2) Perform an evaluation that demonstrates that the equipment can be run to failure 6FIdeptidedjsFf6hnahiidj(as described in section 9.3.3).

If the i

eq

~ f gntlan be^ riin tFfai'IU% then the licensee can replace or repair the

- equipment [at[deRidedlperforuijpiM[at{thsigegtsfaildtj. but no-j i

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adjustments to the areventive maintenance program are necessary and subsequent i

failures would not )e MPFFs.....

1 This e-mail formally relays the CRGR endorsement of the attached version.

subject to the staff's incorporation of the above changes.

The cognizant staff is requested to acknowledge this, and re-submit the revised version of the Reg. Guide, reflecting the aforementioned changes, for CRGR records.

If you have any questions. please contact me at 415-7584.

cc:

CRGR Members Brian Sheron Charlie Haughney

. C:

WND2.WNP5.RPC. WND2.WNP5. TAB C

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o' RiWisionl2-f$$5I5198Z i

i Rcri !:- 2 te Regulatory Guide 1.160 i

$Df8ME15N MONITORING THE EFFECTIVENESS OF.

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. MAINTENANCE AT NUCLEAR POWER PLANTS '

i A. INTRODUCTION 1

The NRC published the maintenance rule on July 10,1991, as Section 50.65,

" Requirements for. Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," of 10 CFR Part 50." Domestic Licensing of Production and Utilization Facilities." The NRC's determination' that a maintenance rule was needed arose from the conclusion that proper maintenance is essential to plant safety. As discussed in l

the regulatory analysis for this rule,' there is a clear link betwsen effective

{

maintenance and safety as it relates to such factors as the number of transients and challenges to safety systems and the associated need for operability, availability, and reliability of safety equipment. In addition, good maintenance is also important in providing assurance that failures of other than safety-related structures, systems, and components (SSCs) that could initiate or adversely affect a transient or accident are

)

minimized. Minimizing challenges to safety systems is consistent with the NRC's defense-in-depth philosophy. Maintenance is also important to ensure that design assumptions and margins in the original design basis are maintained and are not unacceptably degraded. Therefore, nuclear power plant maintenance is clearly important in protecting public health and safety.

Paragraph (a)(1) of 10 CFR 50.65 requires that power reactor licensees monitor the performance or condition of SSCs against licensee-established goals in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Such goals are to be established commensurate with safety and, where practical, take into account industry-wide operating experience. When the performance or condition of an SSC does not meet

. established goals, appropriate corrective action must be taken. For a nuclear power

. plant for.which the licensee has submitted the certifications spo9ed in 10 CFR 50.82(a)(1) (i.e., plants undergoing decommissioning), paragraph (a)(1) of 10 CFR 50.65 only-applies!6 hip to the extent that the licensee eh just monitor the performance or condition of all SSCs associated with t"--'----

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'NRC Memorandum to All Commissioners from J. Taylor on " Maintenance Rulemak-ing," June 27,' 1991. Copies are available for inspection or copying for a fee from the l

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NRC Public Document Room at 2120 L Street, NW., Wash.ington, DC; the PDR's mailing i

'. address is Mail Stop LL-6, Washington, DC 20555: phone (202)634-3273; fax (202)634-3343.

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a

maintenance-ofstoringfcontrolling@Wmaintaining spent fuel in a safe condition, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions.'

Paragraph (a)(2) of 10 CFR 50.65 states that monitoring as specified in pParagraph (a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.

Paragraph (a)(3) of 10 CFR 50.65 requires that performance and condition monitoring activities and associated goals and preventive maintenance activities be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months. The evaluations must be conducted taking into account, where practical, industry-wide operating experience. Adjustments must be made where necessary to ensure that the objective of preventing failures of SSCs through maintenance is appropriately balanced against the objective of minimizing unavailability of SSCs because of monitoring or preventive maintenance. In performing monitoring and preventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on performance of safety functions.

l Paragraph (b) of 10 CFR 50.65 states that the scope of the monitonng i

program specified in pParagraph (a)(1) is to include safety-related and nonsafety-related SSCs-as followsd (1)

Safety-related structures, systems, or components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down j

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 guidelines in 10 CFR 50.34(a)(1) or 10 CFR 100.11 guidelines.'

(2)

Nonsafety-related structures, systems, or components:

(i)

That are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures (EOPs): or

'The requirements specific to decommission plants became effective August 28, 1996. See 61 FR 39278, July 19,1996," Decommissioning of Nuclear Power Reactors."

' Paragraph (b)(1) of the maintenance rule was changed in the Final Rulemaking for

" Reactor Site Criteria including Seismic and Earthquake Engineering Criteria for Nuclear Power Plants," December 11,1996. See 61 FR 65157.

2

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L (ii)

Whose failure could prevent safety-related structures, systems, and I

f components from fulfilling their safety-related function: or r

(iii)

Whose failure could cause a reactor scram or actuation of a safety-related system.

- t Paragraph (c) of 10 CFR 50.65 states that the rule provisions are to be implemented by licensees no later than July 10,1996.

4 This Regulatory Guide 1.160 is being revised to endorse Revision 2 of NUMARC 93-01, "Industr Guideline for_ Monitoring the Effectiveness.of Maintenance at Nuclear Power Plants"y(April 1996), which has been updated by the Nuclear Energy Institute. The regulatory guidance is intended to provide flexibility for a licensee to structure its maintenance program in accordance with the safety i

. significance of those SSCs within the scope of the rule.

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- The information collections contained in this regulatory guide are covered by the requirements of 10 CFR Part 50, which were approved by the Office of Management and Budget, approval number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information i

- unless it displays a currently valid OMB control number.

B. DISCUSSION QBJECTIVE The objective of 10 CFR 50.65 (referred to hereafter as the maintenance rule i

or.the rule) is to require monitoring of the overall continuing effectiveness of licensee maintenance programs to ensure that: (1) safety-related and certain nonsafety-related SSCs are capable of performing their intended functions and (2) for nonsafety-related equipment, failures will not occur that prevent the fulfillment of safety-related functions, and failures resulting in scrams and unnecessary actuations of safety-

- related systems are minimized.

i DEVELOPMENT OF INDUSTRY GUIDELINE. NUMARC 93-01 The nuclear industry;hiiii developed a document th t prevMM gem n= t:

licensees-fogcring 'm-!:-.:nt:th. o' the m:!ntene::= re!:, NUMARC 93-01,

" Industry Guideline for Monitoring the ENectiveness of Maintenance at Nuclear Power Plants" (May 1993)[thitlprovides"guidanoisito; licensees!(sigarding implenientation)[

'This document is available for inspection or copying for a fee in the NRC Public

- Document Room, 2120 L Street NW., Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555: phone (202)634-3273: fax (202)634-3343.

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v.

n.

thefmainten' rice; rule. This document was prepared by NUMARC. A verification and a

validation (V&V) effort was conducted by NUMARC, with NRC staff observation, to test the guidance document on several representative systems. A number of changes were made to the NUMARC guidance document based on the results of the V&V effort. The NRC staff reviewed this document and found that it provided acceptable guidance to licensees. In June 1993, the NRC staff issued Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

which endorsed the May 1993 version of NUMARC 93-01. In January 1995, the NRC staff issued Revision 1 to Regulatory Guide 1.160 to reflect the amendment to 10 CFR 50.65(a)(3) that changed the requirement for performing the periodic evaluation from annually to once per refueling cycle, not to exceed 24 months between evaluations.

From September 1994 to March 1995, the NRC staff performed a series of

]

nine pilot site visits to verify the usability and adequacy of the draft NRC Mmaintenance Rrule ynspection Pprocedure and to determine the strengths and weaknesses of the implementation of the rule at each site that used the guidance provided in NUMARC 93-01. The findings are described in NUREG-1526, " Lessons Learned from Early Implementation of Tihe Maintenance Rule at Nine Nuclear Power Plants,"'(June 1995). The NRC staff concluded that the requirements of the rule could be met more consistently across the industry if soma additional clarifying guidance werewas adoed to NUMARC 93-01 to address the findings noted in NUREG-1526. The NRC staff met with industry representatives in a series of public meetings to discuss proposed revisions to NUMARC 93-01 that would address the findings noted during the site visits, which raculted ini Revision 2 to NUMARC 93-01 (April 1996)lresulted..from th~ese;meetin@.

PLANT. SYSTEM. TRAIN. AND COMPONENT. MONITORING LEVELS The extent of monitoring may vary from system to system depending on the system's importance to safety. Some monitoring at the component level may be necessary; however, it is envisioned that most of the monitoring could be done at the plant, system, or train level. SSCs with high safety significance and standby SSCs with low safety significance should be monitored at the system or train level. Except as noted in the Regulatory Position of this guide, normally operating SSCs with low safety significance may be monitored through plant-level performance criteria, including unplanned automatic scrams, safety system actuations, or unplanned capability loss factors. For SSCs monitored in accordance with 10 CFR 50.65(a)(1),

' Copies are available at current rates from the U.S. Government Printing Office, P.O.

Box 37082, Washington, DC 20402-9328 (telephone (202)512-2249); or from the National Technical Information Service by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161. Copies are available for inspection or copying for a fee from the NRC Public Document Room at 2120 L Street NW., Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555; telephone (202)634-3273; fax (202)634-3343.

4

-__... _ _. _ _ _ _.y additional parameter trending may be necessary to ensure that the problem that caused the SSC to be placed in the PParagraph (a)(1) category is being corrected.

t USE OF EXISTING LICENSEE PROGRAMS A:'ivn!:0 curr=t!y being 00ndee'ed by !!c== :, cuch : tednic='

emErts rrr!!!rne tet5g, ::: eneeregM te b eMThENRC7 staff eposurages licenseesWU6e to the maximum extent practic51ble$iIstivitiesiduiraintl N M 5 N N N s W [ h ; N JE55$5E ~y s

monitoring requirements. Such activities could be integrated with, and provide the basis for,- the requisite level of monitoring. Consistent with the underlying purposes of the rule, maximum flexibility should be offered to licensees in establishing and modifying their monitoring activities.

-USE OF RELIABILITY-BASED PROGRAMS Licensees are encouraged to consider the use of reliability-based methods for developing the preventive maintenance programs covered under 10 CFR 50.65(a)(2)+l however, the use of such methods is not requireri.

SAFETY SIGNIFICANCE RANKING METHODOLOGY The NRC staff eridorses the use of the SSC safety significance ranking methodology described in Revision 2 (April 1996) of NUMARC 93-01, "!nde tr/

Ge!d:!!= 10- M=!tering the E"e tiv=c:: ef Maint==0 =t Nur!::: Pc=:r P!=te,"

esamegap acceptable method for meeting the requirements of the maintenance

)

7 rule However, because of some unique aspects of the maintenance rule, including the fact that SSCs of standby low safety significance are treated the same as SSCs 6fjhigh safety :!;n!50=t SSGesi nificence, this endorsement for purposes of tfi5^^

0 maintenance rule should not be construed as an endorsement for other applications.

These issues were discussed in SECY 95-265, " Response to August 9,1995, Staff Requirements Memorandum Request to Analyze the Generic Applicability of the Risk Determination Process Used in Implementing the Maintenance Rula.'M SAFETY SIGNIFICANCE CATEGORIES 7The staff is developing draft regulatory guide 1061 (DG-1061), "An Approach for

' Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Current Licensing Basis," that addresses the acceptable criteria for the use of PRAs in risk-informed regulatory matters. The staff anticipates that a future revision to RG 1.160 will reference the guidance in DG-1061 in the area of safety significance rankings. This will assure that the guidance on the use of PRA are consistent with the NRC's guidance in other areas of risk-informed regulation. DG-1061 is expected to be issued for public comment in April 1997, and issued as a final regulatory guide in early 1998.

t 5

i

l l

The maintenance rule requires that goals be established commensurate with safety. In order to implement this requirement, NUMARC 93-01 established two safety significance categories (" risk-significant" and "non-risk-significant." The process for placing SSCs in either of these two categories areh described in section 9.0 of NUMARC 93-01. The statements of consideration for the rule use the terms "more risk-significant" and "less risk-significant." NRC inspection procedure (IP) 62706* uses the terms "high safety significance" and " low safety significance." After discussions with industry representatives, the NRC staff has' determined that the preferred terminology is "high safety significance" and " low safety significance." Some licensees may elect to define other safety significance categories or may elect to define more than two categories, which would be acceptable if these alternative categories are defined in the licensee's procedures and implemented in a consistent manner.

APPLICABILITY OF APPENDIX B TO 10 CFR PART 50 With regard to the scope of the maintenance rule, as stated in pParagraph (b) of the rule, it is understood that balance of plant (BOP) SSCs may have been designed and built with normal industrial quality and may not meet the standards in Appendix B to 10 CFR Part 50. It is not the intent of the NRC staff to require licensees to generate paperwork to document the basis for the design, fabrication, and construction of BOP equipment (i.e., BOP equipment need not meet the requirements of Appendix B to 10 CFR Part 50).

Each licensee's maintenance efforts should minimize failures in both safety-related and BOP SSCs that affect safe operation of the plant. The effectiveness of rnaintenance programs should be maintained for the operational life of the facility.

SWITCHYARD MAINTENANCE ACTIVITIES As noted in the Regulatory Position of this guide, there may be a need to address maintenance activities that occur in the switchyards that could directly affect plant operations. Plant management should be aware of and have the ability to control these activities.

EMERGENCY DIESEL GENERATORS Industry-and NRC-sponsored probabilistic risk analyses (PRAs) have shown the safety significance of emergency ac power sources. The station blackout rule (10 CFR 50.63) required plant-specific coping analyses to ensure that a plant could withstand a total loss of ac power for a specified duration and to determine appropriate actions to mitigate the effects of a total loss of ac power. During the station blackout reviews, most licensees: (1) made a commitment to implement an emergency diesel generator (EDG) reliability program in accordance with NRC regulatory guidance but reserved the option to later adopt the outcome of Generic issue B-56 resolution, and (2) stated that they had or will implement an equivalent program. Subsequently, utilities docketed commitments to maintain their selected 6

i target reliability values (i.e., maintain the emergency diesel generator target reliability of 0.95 or 0.975). Those values could be used as a goal or as a performance l.

criterion for emergency diesel generator reliability under the maintenance rule.

- Emergency diesel generator unavailability values were also assumed in plant-

' specific individual plant examination (IPE) analyses. These values should be 3

compared to the plant-specific emergency diesel generator unavailability data L

regularly monitored and reported as industry-wide plant performance information.

These values could also be used as the basis for a goal or performance criterion under the maintenance rule. _In addition, Eaccordancogl$iragriiph[(a)(3)[o(the

% licensees must periodically balance unavailability and reliability of the EDGs.

C.

REGULATORY POSITION 1.

NUMARC 93-01 Revision 2 of NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of i

Maintenance at Nuclear Power Plants," provides methods that are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.65 with the following provisions and clarifications.

1.1 Scopingojof,the:Relei I

1.1.1 "Could Cause" Criterion 1

During the nine pilot site visits, the NRC staff recognized that some licensees interpreted the words in section 8.2.1.5 to mean that only those SSCs that had l

actually caused a plant scram or safety system actuation needed to be included in the scope of the rule. The NRC staffs position is that the SSCs to be included under the criterion "could cause a reactor scram or actuation of a safety system" should not

}-

be limited to those SSCs that "did cause" or "could likely causef" This position was discussed in NUREG-1526, " Lessons Learned from Early implementstion of the Maintenance Rule at Nine Nuclear Power Plants" (June 1995).5 Licensees should

]'

ineludeconsMej the following SSCs tc[be;within the scope of the rule.

1.

SSCs whose failure has caused a reactor scram or actuation of a safety-related system at their site.

2.

SSCs whose failure has caused a reactor scram or actuation of a safety-related system at a site with a similar configuration.

3.

SSCs identified in the licensee's analysis (e.g., FSAR, IPE) whose failure would cause a reactor scram or actuation of a safety-related system.

The only exception to items 2 and 3 above would be 2.= a licensee iidho;has demonstrated by an analysis (e.g., FSAR, IPE) and by operational 7

f 4

-experience that the design or configuration of an SSC is fault-tolerant through i

redundancy or installed standby spares such that a reactor scram or actuation

. of a safety-related system is implausible, in these cases, the licensee may i

e exclude the SSC from the scope of the rule.

j 1;1.2 ' SSCs Rolied Upon To Mitigate Accidents Gjir Transients Q5r Used in EOPs P:r:gr:ph (b)(2)(!) Of the re! ine!ed:: 5 :=p th n= cf 'y re!:ted SSC:

}

Sd up= t :-Mig t: ::-:!d:nt: er tr=:!=t: er th:t ::: ur-d M Emerg=r/

^^^reth; Pr~~-ere.Monsafetykelsted 88Ca[tNetWrblied Upon16"mitigati i

$f9ME5045$X2XI[ NUMARC 93-01 pr=ghcludof{igMscope[6fM aboidenhiViransients%tstWuosdKEggs

d:: OddM:= grid =::Z1 that only those SSCs that provide a significant fraction of the mitigating function need to be included in thefscopei6f thilfsis. The NRCistaff considers this rhet.- te 5 !ede net =!y th::-dnSeanTil0 ifs 5di^iliat are Sir 5Etly used to address the accident or

~ transient or exhiliillfU55 fin the EOPsleidiwithin;th(Ecop6Mih6]FQld, but :!:0 thesee(iii SSCs whose use is impSdnecessety and that provide a significant i

fraction of the mitigating function. Examples of SSCs that should be considered include communications and emergency lighting systems, which are necessary to t

successfully mitigate accidents and transients and to use the EOPs, although they l

may not directly address the accident or transient or not be explicitly mentioned in the i

EOPs.

1 b

1.1.3 Seeping 4y-Function Versus System The rule provides r^qu! remet: for "thich tre6 =, cyttem: =d =mp==t i

critade't6^ determine which?SSCs must be included in the scope of the rule.

i XitsfrisiiVel97lis5ns55EM59~^p5hr= the :=p:ng u.u...u,J= = = f= t!=Usel functiorial basisitciidetermine which^SSCi niiustitidilncidd6dTihWiiiopid~6f Mislei.

E I

T650s,'the liceEs'5555/iin{55ln5TalfjE5%56tl6EsW6r~fieU7hS'5dii5h~d" include pithin the scope of the maintenance rule only those functions and associated SSCs that fulfill the functions that meet the scoping criteria of the rule.

1.1.4 Systems with Multiple Design Functions For systems that have multiple design functions, the NRC staff's position is -

that some design functions may be within the scope of the maintenance rule while others may be outside the scope of the rule. Failures of components that affect a design function that is within the scope of the maintenance rule would require corrective action and monitoring under the rule. For example, the components (piping, pumps, and valves) in the high-pressure coolant injection system (HPCI) that are needed to perform the design function (injection of high-pressure water into the reactor) would be included within the scope of the rule because this is a safety-n related function of the' system. However, the components that are only used for tes@ pt p ::: (e.g., test loop, sample valves, bypass valves) might be excluded from the scope (!.., i' th:y & n~' m :t =ct5:r :^^^5g citet tech = ^^u'd eur 8

l t

I.

i failweef - - ' '" -

'-'-d of the rulelif;the critena 1

~ {MpMM fallsi&!6ffWetde@p^doTriiWmeetinnothierlicoping ^i1Is sr5 j

SSC)%causelfiese~56mpond not required for the coolant injection function of HPCl.

t 1.2 Definition Of Maintenance I

For Mpurposes of the maintenance rule, maintenance activities are these-as described in the " Final Commission Policy Statement on Maintenance of Nuclear Power Plants."' This definition is very broad and includes all activities associated l

with the planning, scheduling, accomplishment, post-maintenance testing and return-to-service activities for surveillances and preventive and corrective maintenance.

These activities are considered maintenance regardless of which organization performs the activity (e.g., maintenance, operations, contractors). This definition is referenced in NUMARC 93-01. Some licensees have questioned the guidance i

_ because in Seection 9.4.5 of NUMARC 93-01 an example of a failure that is not an kWDl8fM05Ib5SMWWj (MPFF) is " failures due to operational

' errors...}" The operational errors referred to in that example are those that are not associated with a maintenance activity.

An example of an operator action that would not be an MPFF would be i

- improper closure of a valve while filling a tank that results in a pump trip followed by 4

i a reactor trip. An example of an operator action that would be an MPFF would be where an operator failed to reopen a suction valve for a pump following post-maintenance testing and the closed suct'on valve causeed, pump failure during a subsequent demand.

i l

1.3 Timeliness NUMARC 93-01 states that activities such as cause dete#minations and moving SSCs from $h((a)(2) to th((a)(1) categoi9;must be performed in a " timely" manner. Some f

licensees have requested that the NRC staff provide a specific period that would be considered " timely." To be consistent with the intent of the maintenance rule to provide !! en ::: flexibilityito liceiisees, the NRC staff does not consider that-it weeld be-appropriate tu provide a ' specific tinieliness criterion. Licensees mustR@

undertake and accomplish activities associated with the maintenance rule in a r

manner commensurate with the safety significance of the SSC and the complexity of the issue being addressed.

1.4 MPFFs AMs Asn Indicator 06f Reliability NUMARC 93-01 states that performance criteria for high :':t/ !gn5 nt SSCs3f high'safet(significance, should be established to assure that reliability and availability assumptions used in the plant-specific safety analysis are maintained or adjusted.

NUMARC 93-01 further al lows the use of MPFFs as an indicator of reliability. The i

'53 FR 9430, March 23,1988.

9

e t

e maintenance rule requires that the performance of SSCs be monitored commensurate with safetyd howeverj the maintenance rule does not require that the assumptions in the safety analysis be validated. Where4L;icensees[sMd choose to use their safety analysiss as described in NUMARC 93-01, - "--- must be able to demonstrate how the number of MPFFs allowed per evaluation period is consistent with the assumptions in the risk analysis. For standby SSCs, et : mW-"m this would requirefitgmininisimj a reasonable estimate of the number of demand '^ -"'

during that time period.-h th00- inc'encec ber jf a licensee desires to establish a reliability performance criterion that is not consistent with the assumptions used in the risk analysis, adequate technical justification for the performance criterion must be provided.

bs too small to be effectively monitored and trended as required by the rul

. (For some SSCs, "- --" ---" " an MPFF performance criterion that ic p

cases, the licensee should establish performance or condition monitoring criteria that can be monitored and trended so that the licensee can demonstrate that maintenance is effective.'

1.5 Monitoring Structures The maintenance rule does not treat structures differently from systems and components. Experience with the rule and NUMARC 93-01 during the pilot site visits and the initial period following the effective date of the rule indicated that specific guidance for monitoring the effectiveness of maintenance for structures was needed as structures present a different situation than d(systems and components. The primary difficulty in implementing the rule for structures using NUMARC 93-01 idiis in establishing appropriate ' riteriaNperformance erderie-and Mwhen to monitoE~

c 4

structures under pgaragraph (a)(1) instead of pgaragraph (a)(2).

performance criteria or goals, or )9;c[ondition monitoring. While it is ac MaintenanceThs effectiveness 6f;mainiensince can be monitored by going j

)

~

use performance criteria or goals, most licensee have found it more practical to use condition monitoring. With certain exceptions (e.g., primary containment), structures do not have unavailability, and rarely Feesivehavis demands pheciedjon their safety significant functions (e.g., maintain integrity under all relevant design basis events) malsineDivijcKmakeiis; reliability monitoring impractical. While attematwootjj

- performance critena and goals could be established, most licensees have elected to

)

use condition monitoring.

i An acceptable structural monitoring program for @6; purposes of the i

maintenance rule should have the following attributes:

y Consistent with the NUMARC 93-01 approach for systems and 1

)

components, most structures would be monitored in accordance with pgaragraph (a)(2), provided there is not significant degradation of the structure.'

e 10 s

~

,v-r

-n

4

(.X c

l 4

M" TWconditionTdf^alAll structures within the scope of the rule would be hesiiissedjeNSically cur;;!!!:d tc

^:- th: 00nd!!!0n Of th: etre:'ere.

^

The appropriate frequency of the

' should be i

commensurate with the safety significance of the structure and its condition.

Aj Licensees should evaluate the results of the i

i to determine the extent and rate of any degradation of the structures.

j Deficiencies should be corrected in a timely manner commensurate with 4

their safety significance, their complexity, and other regulatory requirements (e.g., ALARA).

4d A structure should be monitored in accordance with pgaragraph (a)(1) ift eithiir (1) degradation is to the extent that the structure may not meet its design basisy or (2) the structure is degrading such thatj if the 1

i degradation were allowed to continue uncorrected until the next normally scheduled awvedlanee~ ssessment, the structure may not meet its a

design basis. The structure should continue to be monitored in accordance with pfaragraph (a)(1) until the degradation and its cause j

have been corrected.

6:*;

it is expected that for structures monitored in accordance with pgaragraph (a)(1) additional degradation-specific condition monitoring and increased surveillance frequency would be established until the licensee's corrective actions are complete and the licensee is assured -

that the structure can fulfill its intended functions and will not degrade to i

the point that it cannot fulfill its design basis.

j j

Consistent with the intent of the rule, licensees should use their existing structural monitoring programs (e.g., those required by other regulations or codes) to the maximum extent practica! te m::t the r^qu!rement: Of the meinten:n-re!e.

1 1.6 Definition of Standby

[

In NUMARC 93-01, standby SSCs]o(low safety significanost4SCs must have SSC-specific performance criteria or goals, similar to SSC{b[high safety significan6st-SSGs. NUMARC 93-01 provides a definition of standby. Some licenseesTave improperly interpreted this definition te-implyissinihiining; that SSCs

~ that are energized are normally operating. As stated in NUMARC 93-01, if the SSC only performs its intended function when initiated by either an automatic or manual

. demand signal-thenj the SSC is in standby.

Normally operating SSCs are those whose failure would be readily apparent (e.g., a pump failure results in loss of flow that causes a trip). Standby SSCs are those whose failure would not become apparent until the next demand, actuation, or surveillance. Only those SSCo[of, low safety significan6iiit4SGe whose failure would 11

~

,w-.

,,e.m, w

a em.

e

- o

t 1

7,.

be readily apparent (because they are normally operating)J should be monitored by

]

plant-level criteria.

~

SSCs may have both normally operating and standby functions. In order to adequately monitor the effectiveness of maintenance for the SSCs associated with the standby functions, licensees should develop SSC-specific performance criteria or l

goals, or condition monitoring.

i 1.7 Normally Operating SSC(6f; Low Safety Significance 44SCs 1.7.1 Cause Determinations For all SSCs that are being monitored using plant-level performance criteria (i.e., normally operating SSCaglow safety significanbin-SSGe), the NRC staff's l

position is that a cause determination is required whenever any of these performance criteria are exceeded (failed) in order to determine which SSC caused the criterion to be exceeded or whether the failure was a repetitive m !nten nce prevent:5!

l functiene! f !!ur:!! PEE. As part of the cause determination, it would also be necessary to deEidiihe whether the SSC was within the scope of the maintenance rule and, if so, whether corrective action and monitoring (tracking, trending, goal setting) under 10 CFR 50.65(a)(1) should be performed.

1.7.2 Unplanned Manual Scrams in order to monitor the effectiveness of maintenance for those SSCs monitored by plant-level criteria, NUMARC 93-01 recommends that only those scrams that are automatically initiated be counted. The NRC staff's position is that all unanticipated scrams be considered, including those scrams that are manually initiated in anticipation of an automatic scram. The purpose vi u..... i.ot to discourage manual trips but rather to ensure that operators do not mask a maintenance performance issue. If ineffective maintenance is forcing plant shutdowns, whether the trip is initiated automatically or manually should not affect how licensees address the maintenance performance issue under the maintenance rule.

i l

1.7.3 Establishing SSC-Specific Performance Criteria 1'

The maintenance rule requires that licensees monitor the effectiveness of meintenance for all SSCs within the scope of the rule. NUMARC 93-01 allows i

licensees to monitor,88Caglow safety significan6st-SSCe with plantilevel criteria.

NUMARC 93-01 notes that some normally operating SSC[bfjlow safety significancet i

SSGe cannot be practically monitored by plantilevel criteria. Licensees must ensure that the plant-ilevel criteria established do effectively monitor Gui; maintenance i

performance of the normally operating $SC[6fflow safety significan@t SSce, or establish SSC-specific performance criteria or goals, or Use condition monitoring.

For example, a licensee determined that the rod position indication system and the spent fuel pool pit cooling system were pjittiin tub; scope d[ttjii;#paintenanoejule 1.

12 l

b because they were safety-related at the licensee's site. None of the three plant-level performance criteria described in NUMARC 93-01 (unplanned automatic scrams, J

unplanned capability loss factor, or unplanned safety system actuations) wiHodid monitor the effectiveness of maintenance on these systems. Therefore, additional plant-level performance criteria or system-specific performance criteria must be established.

4

.1;8;[ { ClarificationTto18ecti6nT 9A,5[M.PFFs I

The third psragraphibflsectiori 9^4;5 p[rovides.guldsnce:regardir@ ths

' ompensating actionaisutisssi ent failsiesyosld t#consideisd MPFFuld c

d

~

particutsrfthis!paragiaphladdressss:actionsiwher4Lttisl failure lisinf$auseditspTs Licensee;could linale dssisnin6dificationsitslslimir atsithsipoorly dssign deficiency?st$However/iflthe~licenseeld$tefminssiithst'sdchWsp designedjequipmi theilicenda his td

not cost effective (ed.f costTof rnodificati6n is?pr6hibitlys)[jnerdj

~ ~ ~ '

optionsjfoll6wingieplademsrdMepair;bf tiiepilsdiequip (1)F (MakeTadjustmentsLiivhe'e"necessarp to'thblpraventive rnaintehance program:to prevent recurrence of theifailuresSubsequ;ent failures for;the'samelcaus r

~

inadequals?correctseXpreventisejrhaintsnanse souldLbsLMPITs[alndjcoulditW

!*Petitive MPFFsj i

(2)CiPeifoimiari~eilaisati6n that"deinoristrates'thitWsqsip' ehtiddh tWhkilio m

falldie?orl degraded performance (as"describedLin"section 9.3.3Mifithelequipmeht16an; beWri to failurehthen the, licensee ~can redis6ek repalftluffallodieqbipinenfat" digtsdedl performance or{alihe nest failurei bst 66 adjestments'ts;ths preventive maintenance,progniimiare necessary andfssbsequent;fsilureslwouidindt tssjMPFFs4 1.89 SSCs Considered Under 10 CFR 50.65(a)(1)

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 maintenance as described in pfaragraph (a)(2) of the rule. In the industry guideline for implementing the rule, all SSCs are initially placed under pfaragraph (a)(2) and are only moved under pgaragraph (a)(1) if experience indicates that the performance or condition is not adequately controlled through preventive maintenance as evidenced by the failure to meet a performance criterion or by experiencing a repetitive maintenance preventeb!c functienc!

fe!!ere"PFF. Therefore, the pParagraph (a)(1) category could be used as a tool to focus attention on those SSCs that need to be monitored more closely. It is possible 1

that no (or very few) SSCs would be hend!c&nonitored under the requirements of pRaragraph (a)(1). However, the rule does not require this approach. Licensees could also take the approach that all (or most) SSCs would be hend! cdp 6nitored under pfaragraph (a)(1) of the rule and none (or very few) would be 13

i

! 1

.s a

i.

handiedmonitored under pgaragraph (a)(2) of the rule. Licensees h = the Option of taking@ay;taldii either approach.

2 During the pilot site visits, the-licensees questioned whether a large number of.

SSCs in-themonitoEM~Gnder pgaragraph (a)(1) 0:00; r/ would be used by the NRC j

as an indicator of poor maintenance performance. The NRC staff assured the licensees that NRC management would not use the number of SSCs in-themonitdied bnder Paragraph (a)(1) =t ger; as an indicator of maintenance performan65~n6F~

j would it be used in determining the systematic assessment of licensee performance

~

(SALP) grade in the' maintenance area. The number of SSCs in-themonitored^Under 2

firagraph (a)(1) =te;cr/ can vary greatly because of factors that hhi"h6tSng~f6"do 4

with the quality of the licensee's maintenance activities. For example, two identical plants with equally effective maintenance programs could have different numbers of SSCs in-thepumitoredfdWfaragraph (a)(1) =t:ger/ ecause of differences in the b

.way system boundaries were defined (a system with three trains may be defined as one system at one plant while the same system may be defined as three separate systems at an identical plant) or because of differences in the way performance criteria were defined at the two plants (a licensee thatwhh takes a very conservative approach to monitoring against the performance criteria would have more SSCs in i

the (a)(1) category). The NRC staff also cautioned licensee managers that they l

should not view the number of SSCs in the (a)(1) category as an indicator of j

performance since that attitude might inhibit thei(lioedsee) staff from p!r&gM' an SSC under pgaragraph (a)(1) when a performance criterion was exceeded or a repetitive R $ had occurred. When : !!cene b !!:= if there is some doubt about whether a particular the conservative approach would be to pleeernoni$t the SSC in-theunde SSC should be ee6geri:cd !" monitored [Onder Paradijiph (a)(1) or Paragraph a)(2),

(a)(1) =t gerj.

1.910, Use of Other Methods i

)

Licensees may use methods other than those provided in Revision 2 of i

NUMARC 93-01 to meet the requirements of the maintenance rule, but the NRC will determine the acceptability of other methods on a case-by-case basis, i

2.

OTHER DOCUMENTS REFERENCED IN NUMARC 93-01 NUMARC 93-01 references other documents, but NRC's endorsement of l'

NUMARC 93-01 should not be considered an endorsement of the referenced documents.

3.

INCLUSION OF ELECTRICAL DISTRIBUTION EOUIPMENT i-The monitoring efforts under the maintenance rule, as defined in 10 CFR 50.65(b), encompass those SSCs that directly and significantly affect plant operations, regardless of what organization actually performs the maintenance activities. Maintenance activities that occur in the switchyard can directly affect plant 14

'4 e

i operations; as a result, electrical distribution equipment out to the first inter-tie with the offsite distribution system (i.e., equipment in the switchyard) should be considered for inclusion as defined in 10 CFR 50.65(b).

I D.

IMPLEMENTATION The purpose of this section is to provide information to applicants and licensees regarding the NRC staff's plans for using this regulatory guide.

Except in those cases in which an applicant or licensee proposes an '

acceptable alternative method for complying with specified portions of the NRC's regulations, the methods described in this guide will be used in the evaluation of the effectiveness of maintenance activities of licensees who are required to comply with 10 CFR 50.65. The guide will also be used to evaluate the effectiveness of i

l emergency diesel generator maintenance activities associated with compliance with 10 CFR 50.63.

REGULATORY AND BACKFIT ANALYSES J

Separate regulatory and backfit analyses were not prepared for Revision 2 of Regulatory Guide 1.160. The regulatory ana!ysis and the backfit analysis that were 4

prepared when this guide was first issued as a draft, DG-1020, in November 1992, are still applicable. The backfit analysis prepared for DG-1020 concluded that no backfit was associated with the regulatory guide because it was only providing guidance to implement the existing requirements of the maintenance rule. The Commission determined, on the basis of the backfit analysis performed for the maintenance rule, "... that backfitting of the requirements in the maintenance rule will provide a substantial increase in the level of protection of public health and safety beyond that currently provided by the Cor.wist!- '- - : Nions, and that the costs of implementing the rule of justified in view of this increased protection.7 The regulatory analysis and backfit analysis for DG-1020 are available, in the file for Regulatory Guide 1.160, for inspection or copying for a fee in the Commission's i

Public Document Room,2120 L Street NW., Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555: phone (202)C34-3273; fax (202)634-3343.

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'56 FR 31320 15

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