ML20138E542
| ML20138E542 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1994 |
| From: | Black S NRC (Affiliation Not Assigned) |
| To: | Gody A NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20136A631 | List: |
| References | |
| FOIA-97-045, FOIA-97-45 NUDOCS 9501050342 | |
| Download: ML20138E542 (2) | |
Text
- _ . .._ _ __ __ . _ .. __ __ ._ _ __ ___
l ~
l c
lEr
, % X . u h r4 h k
- . i .
-Vl
>v
,,,,, December 15, 1994 l
i
! MEMORANDUM T0: Anthony Gody, Chief Inspection Program Branch Director for Inspection and Support Programs :
Chris Grimes, Chief Technical Specifications Branch Division of Project Support Robert Jones, Chief Reactor Systems Bfanch ,
Division of Sys'tein Safety and Analysis Edward Butcher, Chief Probabilistic Safety Assessment Branch !
Division of System Safety and Analysis FROM: Suzanne Black, Chief .
3 al. f" 4 I Quality Assurance and M ntenance ranch 1 Division of Technical Support
SUBJECT:
NRR REVIEW COMMITTEE FOR TEMPORARY INSTRUCTION 2515/126
" EVALUATION OF ON-LINE MAINTENANCE" ;
Temporary Instruction (TI) 2515/126. " Evaluation of On-Line Maintenance," was issued October 27, 1994. The objective of this Tl is to evaluate the impact on safety of licensee's procedures and practices regarding the removal of equipment from service for on-line scheduled maintenance. This TI was established as a result of an apparent increase of both the amount and frequency of maintenance performed by licensees during power operation. The Tl requires that the regional offices (or resident inspectors) perform the inspection by December 31, 1994, document the results of the inspection in a routine inspection report, and transmit their concerns to the Chief. Quality Assurance and Maintenance Branch, NRR. Upon receipt of inputs from the regional offices, the NRR Tl 2515/126 Review Committee will be responsible to review and evaluate the information.
We must now f ormulate the i4P.R TI 2515/126 Review Committee so that we are prepared to evaluate the reports as they start to come in from the regions.
We are requesting that each addressee of this memorandum designate a cognizant reprzentative from their branch to be a member of the 11 Review Committee.
Thir individual's responsibilities will include reviewing inputs from the regions and discussing the inforn'ation at the committee meetings. A copy of
- Tf 2515/126 and a draf t of the r.roposed information review and coordinat ion plan are provided as attachmer.ts to this memorandum to further detail the responsibilities of the NRR TI 2515/126 Review Committee and its members.
l
[6omoun yx , /3l
Multiple Addressee Please respond by December 21, 1994, wib. t he 'namo di 2ba 'tranch representative you have selected. Once the comdtier %u been formed, we will have a kick-off meeting to introduce the team weniters cand discuss the Il and review plan. If you have any goestions or concerns, please contact Rich Correia at 504-1009 or Ron Frahm, Jr. at 504-2986.
Attachments: 1. Temporary Instruction 2515/126, !
" Evaluation of On-Line Maintenance" I
- 2. Draft of proposed TI 2515/126 Information Review and Coordination Plan cc: R. Cooper, RI J. Wiggins, RI E. Merschoff, Ril A. Gibson, Ril E. Greenman, Rill G. Grant, RIII 1
B. Beach, RIV l T. Gwynn, RIV l
1 1
l l
I i
l _
l NRC INSPECTION MANUAL TgMs TEMPORARY INSTRUCTION 2515/126 l
EVALUATION OF ON-LINE MAINTENANCE SALP FUNCTIONAL AREA: MAINTENANCE (MAINT)
APPLICABILITY: All power reactor facilities 2515/126-01 OBJECTIVE To evaluate the impact on safety of licensee's procedures and practices regarding the removal of equipment from service for on-line scheduled maintenance.
2515/126-02 BACKGROUND During recent plant visits by several NRC senior managers, it was noted that licensees are increasing both the amount and frequency of maintenance performed during power operation. Most of the licensees visited stated that they were implementing or soon would implement the concept of outage windows while the plant was operating at power. Some licensees were limiting the planned outage window to a single train of a system while others would allow multiple equipment in other systems within a single train to be out of service as long as it did not violate Technical Specifications. For example, at one plant it was noted that i
over a three-day period the licensee had diverse components in a single train out of service for planned maintenance. During this period, work was performed on two battery chargers, an auxiliary feedwater pump, a residual water system heat exchanger, a safety injection pump, a safety-related chilled water system, and a station service water pump. Multiple components were planned to be simulta-neously out of service for testing or maintenance. Although most equipment could have been returned to an operable status, it is not clear that the licensee, prior to their removal, adequately evaluated the safety significance of having multiple components out of service for a period of time.
Licensees' expansion of the on-line maintenance concept without thoroughly considering the safety (risk) aspects raises significant concerns. The on-line maintenance concept appears to extend the use of Allowed Outage Times (A0T) stated in the Technical Specifications beyond the random single failure in a system and a judgement of a reasonable time to effect repairs upon which the A0Ts were based. The capability to withstand a single failure in fluid and electrical systems is a plant specific design requirement that is contained in the general design criteria in 10 CFR 50, Appendix A. Compliance with this criteria is demonstrated during plant licensing by assuming a worst case single failure which often results in multiple equipment failures. This does not imply that it is acceptable to voluntarily remove equipment from service to perform on-line ssue-DateMD/27 94 .
2515/126 C , , c. . f s ,- r e; j Attachment 1
maintenance on th! saum3tibm Wad c4mh. act0m9 are. bounded; b y a worst case ,
single failure ?
A simplified quaTWatirveimubril ifm riwsuat%9 rbstr cam Se> tdatujN of as inc1uding
- three f actors combined in the follwina;'wip..
Risk - P, x P, x P, Where:
P, = The probabi'lity of an initiativg aevi, sd a a t Oc4, turbine trip, or loss of offsite power.
P, - The probability of being able to mitigate the event using core damage prevention as a measure of successful mitigation.
P, = The probability of being able to mitigate the consequences using containment integrity preservation as a neasure of success.
An effective risk assessment process includes consideration of the impact of It also considers the maintenance activities on all three of these risk factors. i impact of maintenance activities on both safety-related and non safety-related equipment. Multiple or single maintenan:e activities that simultaneously, or within a short time frame, impact two or more risk factors tend to increase risk ,
the greatest. !
increase component ;
In addition, on-line scheduled maintenance tends to !
unavailabilities. With increased on-line scheduled maintenance, the overall 4 impact on train unavailability when averaged over a year has in many cases :
increased dramatically and in some cases to the point of invalidating the assumptions licensees themselves made in their plant specific Individual Plant Examinations (IPE).
NRC Inspection Manual Part 9900 Technical Guidance, " Maintenance - Voluntary :
Entry Into Limiting Conditions For Operation Action Statements to Perform Maintenance," issued in 1991, provided some general safety principles that ,
inspectors were to use in order to ensure that licenseesThe did guidance not abuse the lack recognized of specificity in TSs regarding the proper use of A0Ts.
that at the time the NRC was only beginning to quantitatively study the significance to safety (risk) of the trend to perform more scheduled maintenance at power, and in general, licensees had not yet fully developed the capability to perform such studies. Therefore, the guidance did not establish quantitative criteria by which the NRC or a licensee could determine the net effect on safety that on-line scheduled maintenance would have at the facility, or for the industry as a whole.
Tools to quantitatively asses the relative risks of various maintenance and Additional-outage schedules are now available to licensees as discussed below.
ly, Regulatory Guide 1.160, issued to support implementation of the TheMaintenance maintenance Rule (10 CFR 50.65) in 1996, provides some valuable insights. l rule requires licensees both to balance the improvement in reliability resulting i from maintenance with the increase in equipment unavailability due to the planned ,
maintenance and to evaluate the impact upon safety of all equipment currently out '
of service before voluntarily taking additional equipment out of service.
This Temporary Instruction (TI) is intended to provide guidance to inspectors to enable them to determine whether licensee processes appropriately consider the significance of on-line maintenance and identify specific instances where planned Issue Date: 10/27/94 2515/126
i result in an impact on plant safety (risk).
f*
maintenance will potentially, Inspectors are cautioned not to attempt to enforce the requirements of maintenance rule when implementing this II, but rather are requested to ra concerns to regional managers and the TI 2515/126 process of being established.
INSPECTION REQUIREMENTS 2515/126-03 Determine whether licensees haved in 03.01 Maintenance Plannina and Scheduling. d to discusse place a program that focuses on all three of the risk factors thoroughly evaluates the impact of scheduling on-line maintenance with re plant safety. ^
a.
Review the process and procedures that the licensee has in place to !
l schedule on-line maintenance.
b.
Determine whether the licensee evaluates the risk incurred from pe on-linc maintenance activities by assessing the cumulative effect of multiple equipment maintenance activities'and equipment outages, performing the maintenance or taking equipment out of service.
c.
Determine how the process integrates scheduled maintenance activ existing degraded / inoperable equipment.
d.
Determine the extent of knowledge and awareness of supervisory a ,
level personnel concerning the licensee's process for planning (The necessary level and scheduling operations and maintenance activities. I of knowledge of the comprehensive process should be dependent upon the extent to which the individuals are responsible for the details of ?
specific and over all planning and scheduling). l 03.02 Planned Maintenance.
Review the on-line scheduled maintenance t for th ;
i upcoming cycle (should look at a time period between one month a of planned activity) to identify any specific instances (situations or configurations) where planned on-line maintenance could i poten significant impact on plant risk.
or single maintenance activities that simultaneously, or within a sh frame, impact two or more risk factors tend to increase risk the great ,
Consult with and identify any concerns to regional managemen f 03.03 Reoorting. 2515/126 review committee.
for coordination with the NRR Tl GUIDANCE 2515/126-04 The process established by the 04.01 Maintenance Plannina and Scheduling.
licensee to evaluate what planned maintenance should ll plant be co consider the cumulative impact of the maintenance activities on overa safety.
a.
In ' reviewing the process, the inspector must concentrate d for on effectivenees of the maintenance program and on the procedures i for us h
planning and scheduling maintenance activiti (Some t
of the risk factors discussed in the backgrou 2515/126 Issue Date: 10/27/94
_ = _ . . . .. _
matrices which restrict having risk-significant combinations of equipment -
)
inoperable simultaneously.)
- b. Licensees may not have thoroughly considered the safety (risk) aspects of doing more on-line maintenance. Some licensees are using the concept of !
division or train outages to ensure that they do not have a loss of system function. In the extrema, this could result in all of the equipment in l a division being out of service at the same time with unexamined risk i consequences, while being in literal compliance with plant TS. For i' example, one facility that used a division or train approach to on-line maintenance had pl..incd to take out of service the following equipment:
B Auxiliary feedwater, B Battery Charger, 8 Service Water, B RHR, and the B Charging Pump. Because redundant train equipment was available, there was no violation of TS. However, in the event of a design--basis transient such as a loss of offsite power precipitated by maintenance or instrumentation calibration activities associated with nonsafety-related equipment in the switchyard, the plant would be in a configuration with significant risk implications due to a diminished capability to remove decay heat at high pressure. This is an example of maintenance '
simultaneously increasing the probability of an initiating event, in this case a loss of offsite power, and diminishing the plant's capability to mitigate the event.
The confidence in the operability of redundant / diverse equipment should be high during periods of on-line scheduled maintenance. Evaluate the licensee's conduct of operations during on-line maintenance activities.
The licensee should avoid performing other testing or maintenance that would increase the likelihood of a transient (a potential event initiation). This consideration should include degraded or out-of-service equipment in the balance of plant,
- c. The process used by the licensee to schedule and plan on-line maintenance should ensure that maintenance and testing schedules are appropriately modified to account for degraded or inoperable equipment. When reviewing ,
the process, determine how it accomplishes this function.
- d. Determine the extent to which the process used by the licensee is used by the operations and maintenance staffs. The following are examples of
- questions that should help determine the operations / maintenance level of familiarity with the process employed in managing scneduled maintenance activities. When planning on-line maintenance:
- Does the licensee take probabilistic risk insights into account?
- Does the licensee allow multiple train outages? i
- How does the licensee take into account component and system dependencies?
- How does the licensee assure that important combinations of equipment needed for accident mitigation are not unavailable at the same time?
- By what process does the licensee determine how and what procedures and testing to focus on in minimizing unavailability and reducing the potential for accident or transient initiation, including the impact of maintenance activities involving nonsafety equipment (e.g.,
turbine generator and electrical equipment)?
2515/126 Issue Date: 10/27/94
4 *
' How does the licensee determine the maximum amount of time to allow for the maintenance and how does it determine the risk associated i
- with the decision? .
At any given time, how much planned maintenance is in progress and I 1
how is it coordinated to minimize risk?
i 4
04.02 Planned Maintenance. In reviewing the licensees planned maintenance look )
for occurrences of scheduled maintenance activities that simultaneously, or j
. within a short time frame, impact two or more of the risk factors discussed in j
.the Background section, above. The following example is provided- !
l
- Example
- Maintenance is scheduled to be performed at a PWR. The equipment '
- (the A EDG and the A motor driven auxiliary feedwater pump) will be out of l service during the maintenance. '
! Before undertaking the above maintenance, the licensee's planning and j
- scheduling should consider the potential effects on plant safety of any '
- concurrent maintenance, surveillance or testing on, as well as unavailability
. of:
I 1. Obvious risk contributing systems and components such as offsite power, the normal power to other Train A components, the Train B EDG, the Train
! B motor driven auxiliary feedwater pump, and the turbine driven auxiliary feedwater pump.
J
- 2. Less obvious potential risk contributors could also exist. Considering just the unavailability of the EDG, the steam driven aux feed pump and the station batteries could be significant (if for instance a grid perturbation caused a loss of offsite power and concurrent RX trip and j failure of the B EDG to start). In the case of the unavailable auxiliary feedwater pump, maintenance on secondary components such as the main i feedwater and condensate pumps might be significant given that their loss 5
could cause a Reactor trip and the need for auxiliary feed.
4 04.03 Reportina. Inspector's concerns with any specific upcoming on-line scheduled maintenance should be given priority over completed maintenance, a
i 2515/126-05 REPORTING REQUIREMENTS The inspector should reference TI 2515/126 and briefly document the results of the completion of this Tl in a routine inspection report. In addition, the 1 l inspector should transmit, through appropriate regional office management, those l j concerns identified to the Chief, Quality Assurance and Maintenance Branch, NRR, 4
OWFN 10-A-19.
i l 2515/126-06 COMPLETION SCHEDULE l
4 This inspection should be completed by December 31, 1994. l j i I
2515/126-07 EXPIRATION l This Temporary Instruction will expire on June 30, 1995.
Issue Date: 10/27/94 2515/126 l
2515/126-08 CONTACT .
Direct questions regarding implementation of this TI to R. Correia, Quality i Assurance & Maintenance Branch, at (301) 504-1009. ;
d 2515/126-09 STATISTICAL DATA REPORflNG l l
Report the direct inspection effort expended for this TI against 2515/126 and .i under inspection program element (IPE) code of "SI" (Safety Issue Program).
2515/126-10 ORIGINATING ORGANIZATION INFORMATION 10.01 Oraanizational Responsibility. The Quality Assurance and Maintenance Branch (TQMB) originated this temporary instruction.
10.02 Resource Estimate. It is estimated that approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of direct inspection effort will be necessary to complete this TI. Actual inspection at a specific plant may require more or less time depending on plant specific issues.
10.03 Other. Portions of Inspection Procedure 62703, " Maintenance Observa-tions," may be satisfied by the performance of this TI.
10.04 Trainina. No special training requirements are associated with this TI.
2515/126-12 REFERENCES NRC Inspection Manual Part 9900: Technical Guidance " Maintenance - Voluntary Entry Into Limiting Conditions for Operation Action Statements to Perform (;
Preventive Maintenance" 10 CFR 50.65 Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. (Maintenance Rule) !
Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear ,
Power Plants" ,
END l
l L
I y
4 2515/126 Issue Date: 10/27/94
4 d
i TEMPORARY INSTRUCTION 2515/126 " EVALUATION OF ON-LINE MAINTEtlANCE" INFORMATION REVIEW AND. COORDINATION PLAN
- 1. RECEIPT OF INFORMATION FROM RESIDENTS / REGIONS Reports are to be submitted to Ronald Frahm, Jr., Richard Correia, or Suzanne Black of the Quality Assurance & Maintenance Branch (TQMB) by December 21, 1 1994. Reports may be submitted by any of the following means:
- electronically mailed to RKF (Frahm), RPC (Correia), or SCB (Black)
- telefaxed to fax number 301-504-2968 (ATTN: R. Frahm, Jr.)
a mailed to mailstop 0-10A19 (ATIN: R. Frahm, Jr.)
- telephoned in to 301-504-2986 (Frahm) or 301-504-1009 (Correia) - l (phone calls MUST be followed up with written reports -- this is not the )
preferred method of submittal and should only be used if necessary) '
In all cases, final reports are required to be documented in writing and j mailed to mailstop 0-10A19.
II. COORDINATION Questions concerning implementation of this TI should be directed to Mr. Frahm or Mr. Correia by e-mail or phone as discussed above. Upon receipt of reports from the resident inspectors, Mr. Frahm will be responsible for filing the reports, entering the pertinent information into the database, and j coordinating with the resident inspectors and regional offices to assure l accuracy, completeness, and timeliness of information. Mr Frahm will be further responsible to disseminate the reports to the NRR Tl 2515/126 review committee and schedule and chair the committee meetings.
The NRR Tl 2515/126 review committee will consist of:
Suzanne Black, Chief, Quality Assurance & Maintenance Branch (TQMB) - as needed Richard Correia, Chief, Reliability and Maintenance Section TQMB - as needed Ron Frahm, Jr., TQMB Thomas Foley, TQMB Inspection Program Branch (PIPB) representative - A. Gody, Chief Technical Specifications Branch (OTSB) representative - C. Grimes, Chief Reactor Systems Branch (SRXB) representative - R. Jones, Chief Probabilistic Safety Assessment Branch (SPSB) representative - E. Butcher, Chief Attachment 2
a Each Branch Chief will be responsible to appoint a representative from their branch to the committee Committee members will be responsible to review inputs from the regions, and discuss the information at the review committee meetings (committee members may wish to utilize the enclosed form / data sheet to document their review). The NRR TI 2515/126 review committee will meet on an as needed basis to discuss and assess the inputs from each plant. The review committee members will also be responsible to provide inputs to and concur on the final report which will detail the conclusions and recommendations of the committee.
III. TRACKING M. Frahm will develop and maintain a database (using dBASE 111 PLUS) to include the following for each reactor:
PLANT NAME REGION REPORT DATE RESIDENT INSPECTOR / REGIONAL CONTACT PHONE NUMBER FREQUENCY OF ON-LINE MAINTENANCE / TRENDING ADEQUACY OF ON-LINE MAINTENANCE PROGRAM STRENGTHS WEAKNESSES AND CONCERNS OVERALL ASSESSMENT FOLLOW-UP ACTIONS FINAL REPORT DATE Mr. Frahm will prepare a data sheet (see sample enclosed) for each unit / plant to document the evaluation by the review committee. These data sheets will be utilized for data entry and then filed with the respective plant submittal.
Summary reports and real-time data will be available upon request from the database. Mr. Frahm, Mr. Foley, and Mr. Correia will have access and training to fully utilize and maintain the database.
All activities performed for the purposes of reviewing and coordinating inputs from the regions in response to Tl 2515/126 should be charged to TAC = M90822 "Il 2515/126 Information Review and Coordination."
IV. RESOLUTION Mr. Frahm will document the findings of the NRR Tl 2515/126 review committee and coordinate with the residents and regions to obtain additional information and resolve issues and concerns as necessary. Mr. Frahm will be further i responsible to prepare and issue a letter to the Director of NRR summarizing ;
the conclusions and recommendations of the review committee. l 1
l 1
l Attachnent 2 ;
i l
I l
l l
J
, TI 2515/126 " EVALUATION Of ON-LINE MAINTENANCE" SUBMITTAL DATA SHEET -
PLANT NAME/:
LICENSEE REGION:
REPORT DATE:
4 RESIDENT INSPECTOR /:
REGIONAL CONTACT PHONE NUMBER:
1 FREQUENCY OF ON-LINE MAINTENANCE / TRENDING:
I 1
ADEQUACY OF ON-LINE MAINTENANCE PROGRAM: l 1
l PROGRAM STRENGTHS:
PROGRAM WEAKNESSES / CONCERNS:
OVERALL ASSESSMENT:
FOLLOW-UP ACTIONS:
l FINAL REPORT DATE: '
l l
1 At t ac hn:en t 2
a
's Multiple Addressee December 15, 1994 Please respond by December 21, 1994, with the name of the branch representative you have selected. Once the committee has been formed, we will have a kick-off meeting to introduce the team members and discuss the T1 and review plan. If you have any questions or concerns, please contact Rich Correia at 504-1009 or Ron Frahm, Jr. at 504-2986.
Attachments: 1. Temporary Instruction 2515/126,
" Evaluation of On-Line Maintenance"
- 2. Draft of proposed 11 2515/126 Information Review and Coordination Plan cc: R. Cooper, RI J. Wiggins, RI E. Merschoff, Rll A. Gibson, Ril E. Greenman, Rill G. Grant, RIII B. Beach, RIV T. Gwynn, RIV DISTRIBUTION:
Central Files TQMB R/F DOCUMENT NAME: G:\ FINAL \2515-126.MEM SEE PREVIOUS CONCURRENCE To receive a copy of this document, indicate in the box: 'C" = Copy without enclosu r ec "F" e Cnt v eth enchsures "N" = % u1q 1 0FFICE TOMB / DOTS l TQMB/ DOTS l TOMB / DOTS l DOTS /NRR l NAME RFrahm:kr* RCorreia* SCBlack* RL5pessard DATE 12/13/94 12/13/94 12/14/94 12/ /94 0FFICIAL RECORD COPY l
i I
l l
a 6
Multiple Addressee December 15, 1994
~
Please respond by December 21, 1994, with the name of the branch representative you have selected. Once the committee has been formed, we will have a kick-off meeting to introduce the team members and discuss the T1 and review plan. If you have any questions or concerns, please contact Rich Correia at 504-1009 or Ron Frahm, Jr. at 504-2986.
Attachments: 1. Temporary Instruction 2515/126,
" Evaluation of On-Line Maintenance"
- 2. Draft of proposed Tl 2515/126 Information Review and Coordination Plan cc: R. Cooper, RI J. Wiggins, RI E. Merschoff, RIl A. Gibson, RII E. Greenman, Rlll G. Grant, RIII B. Beach, RIV T. Gwynn, RIV DISTRIBUTION:
Central Files TQMB R/F DOCUMENT NAME: G:\ FINAL \2515-126.MEM SEE PREVIOUS CONCURRENCE To receive a copy of this document indicate in the uom: "C' = Copy without enclost.en ' F" = Cwv w th enclo>ures 'N" r f.. copy 0FFICE TOMB / DOTS l TOMB / DOTS l TQMB/ DOTS l DOTS /NRR l NAME RFrahm:kr* RCorreia* SCBlack* RLSpessard DATE 12/13/94 12/13/94 12/14/94 12/ /94 0FFICIAL RECORD COPY cr