ML20151T612

From kanterella
Jump to navigation Jump to search
Summary of 880626 Meeting W/Inpo Re Proposed Rulemaking on Maint,Maint PI Development Activities & INPO Experience W/ Maint Indicators
ML20151T612
Person / Time
Issue date: 07/19/1988
From: Novak T
NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To: Jordan E
NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
References
NUDOCS 8808160420
Download: ML20151T612 (3)


Text

{{#Wiki_filter:._ yj Q' dr8c o o e b UNITED STATES ["' i NUCLEAR REGULATORY COMMISSION 5 j WASHINGTON, D. C. 20555 \\...../ JtJL 191988 MEMORANDUM FOR: Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data FROM: Thomas H. hovak, Director Division of Safety Programs

SUBJECT:

MEETING WITH INP0 ON JUNE 28, 1988 TO DISCUSS THE C0 ORDINATION OF MAINTENANCE PI DEVELOPMENT The topics discussed included the proposed rulemaking on maintenance, maintenance PI develognental activities, and INP0's experience with maintenance indicators. Copies of the enclosed memorandum to the Comission, dated June 27,1988, on the proposed rulemaking were provided to INP0 representatives. The highlights of the discussion are provided below. July 11-13 Public Workshnp: INP0 representatives were briefed on the upcoming workshop, and were encouraged to actively participate in it and to share their experiences and positions related to the rulemaking issues and maintenance PIs on record. The participation of INP0 representatives is being coordinated through NUMARC. They are concerned in general about the potential adveree impact of a rule, especially in view of the industry initiatives. Maintenance PI Developmental Activities: INP0 was informed of the NRC's plan to collect plant-specific data for certain candidate maintenace PIs for evaluation and validation, and to recommend som maintenace PIs for Com11ssion approval in November 1988. INP0 representatives were concerned about the use of indicators by the NRC in assessing maintenance. Based on their experience in the use of mairtenance-related indicators, they believe quantitative data do not provide measures of mantenance ef fectivenes s. Maintenance evaluations should be based on monitorino and observing maintenance activities at the plant. With respect to assisting the NRC in validating some of the candidate indicators, including those currently in their program, they do not believe their data would be of much use. INP0's Maintenance-Related Indicators: INP0 is considering certain changes to their maintenace-related indicators. For example, they are considering including the corrective maintenace wark requests requiring outages in the maintenance 1 f)"QUfD

  • 93 i

esoe160420 880719 V 1 PDR ORG EPSI g i i

d$

  • , 'j Edward L'. Jordan backlog and monitoring over a longer period of time.

These changes are currently undergoing INP0 management review. provides a list of the meeting attendees. Original signed by: Thomas M. Novak Thomas M. Novak, Director Division of Safety Programs Office for Analysis and Evaluation of Operational Data

Enclosures:

1. Memo to the Comnission dated 6/27/88 2. List of Attendees cc: C. J. Heltemes J. Roe T. King DISTRIBUTI0'! IUC5 A PDR TPAB R/F DSD R/F MWilliams RDennig RSingh WJones VBenaroya JRosenthal D TPAB DSP RSingh:aj MWf ms 7/l3 /88 7/@/ 7f 88

.e Edward L. Jordan JUL 191988 backlog and nonitoring over a longer period of time. These changes are currently undergoing INP0 management review. Enclosura 2 provides a list of tha neeting attendees. D&? }A ^ Thomas M. Novak, Director Division of Safety Prograns Office for Analysis and Evaluation of Operational Data

Enclosures:

1. Meno to the Connission dated 6/27/88 2. List of Attendees cc: C. J. Heltemes J. Roe T. King

'.a in. ' 8[. b o, UNITED STATES NUCLEAR REGULATORY COMMISSION o B WASM NGTON, D. C. 20656 ~JUN 2 71988 ~ + MEMORANDUM FOR: Chairman Zech Comissioner Roberts Comissioner Carr Comissioner Rogers FROM: Victor Stello, Jr., Executive Director for Operations

SUBJECT:

PROPOSED RULEMAKING FOR THE MAINTENANCE OF NUCLEAR POWER PLANTS The purpose of this memorandum is to (1) inform the Comission of the options that the staff is considering for discussion at the July 11-13, 1988 ver ksho on the proposed rulemaking for the maintenance of nuclear power plar.ts, (2) p rovide a draf t rule for the preferred o p(3) sumarize the changes in our plans (ption for Comission cor. ideration and as reported in SECY-88-142) to meet the Comissior's desired schedule for the rulemaking effort.

Background

On May 23, 1988, the staff submitted to the Commission its proposed "Staff Plan and Schedule for Proposed Rulemaking for the Maintenance of Nuclear Power Plants" in SECY-88-142. The plan and schedule was developed in response to the Comission's direction (in memorandum Chilk to Stello, dated 2/26/88 M880107) for the staff to develop a proposed rulemaking on the subject. The Comission disapproved (in memorandum Chilk to Stello, dated 6/17/88, H8800281) the staff's schedule to prepare a proposed rule and indicated that some of the activities presently scheduled as "front-end" could be treated as confirmatory "back-end" activities, thereby reducing the schedule. A Notice of Proposed Rulemaking was requested by October 3, 1988. The staff received further Comission direction'(in meanorandum Chilk to Stello, dated 6/17/88,COMXC-88-03) to develop a preferred maintenance rulemaking option (reguiring licensee's to track certain maintenance performance. m indicators) which should be the focus of the NRC Public Workshop for Maintenance Rulemaking on July 11-13, 1988. This paper describes the rulemaking options being considered by the staff, including a "Strawman" maintenance rule for the preferred option, anc responds to the Comission's direction to accelerate the schedule. Discussion The staff has developed five rulemaking options within the general framework of the Final Comission Policy Statement on Maintenance of Nuclear Power Plants for the purpose of discussion at thc July 11-13, 1988 workshop on the maintenance rulemaking. y v *l-i0.-O-W f.

Chairman Zech and Connissioners 2 These options fall into two main categories. The objective of the options in the first category is to emphasize reporting measures of the effectiveness of rnaintenance programs, whereas the options in the second category provide more detailed requirements on the content of a maintenance program, as well as addressing measures of effectiveness. A process highlighting key decisions that lead to the five options is presented along with a description of the options and a qualitative assessment of the impact tt.ey would have on NRC and industry resou ces and on industry initiatives. Based on results of assessments to date in the rulemaking effort, a set of foctors the staff considers important in selecting the desired option are presented. A "Strawman" rule for the preferred Commission option is also presented and it is our intent to emphasize and focus detailed discussion on this option at the workshop. Rulemaking Options The enclosed "Decision Chart for Determining Rulemaking Options" (Enclosure 1) shows the key decisions and the resulting rulemaking options. In addition, there are other consiaerations required for determining the exact nature of the options. These are discussed later and are not included in the Chart, which shows for clarity only the key decisions. The enclosed "Table on Characteristics of Maintenance Rulemaking Options" (Enclosure 2) indicates the relaticnship of a rule, Reg. Guide or industry standard in the various rulemaking options, the mechanism for verifying compliance and a qualitative assessment of the costs to the licensee and the NRC. The options are sumarized below. They vary in scope and in the degree of prescription. In general, the scope and the degree of prescription increases from Option 1 tu Option 5. I) Performance Based Options Performance based rulemaking options are based on a decision to address, only in a general fashion, the implementation of a maintenance program with specific emphasis in the rule on reporting the measures of the effectiveness of the progrem. Option 1-General Performance Based Rule Option 1 consists of a generdi rule which would require each licensee to have an effective and documented maintenance program, to establish measures to evaluate and improve the effectiveness of his maintenance program and to report periodically on its effectiveness. A Reg. Guide would provide guidance on acceptable methods for measuring the effectiveness of maintenance programs; however, each licensee could establish a measuring and reporting program he considers acceptable. Based on review of the information provided by licensees, inspections could be conducted on plants that are judged to be performing poorly. Since the measures of performance are provided in a Reg. Guice as guidance, there may be a large variation in the type of data reported to the NRC.

Chairman Zech and Comissioners 3 The Comission has indicated (in menorandum from Chilk to Stello, dated 6/17/88, COMKC-88-03) preference for a rule which would require licensees to track certain defined maintenance performance indicators and directed the staff to focus the July 11-13,1988 Public Workshop on the preferred rulemaking option. The staff believes that Option 1 is the best choice to satisfy the Comission's desire I for a preferred option. A "Strawman" rule for Option 1 is provided in Enclosure l 3, along with a set of maintenance performance indicators (ftPis) and definitions which could form the basis for a Reg. Guide. The set of MPIs provides a starting point for discussions at the public workshop to determine the adequacy of the indicators and to delete or add other MPIs to the set. powever, validation of the MPIs is needed prior to issuing the final Reg. Guidt. l ~ Option 2-Prescriptive Performance Based Rule Option 2 is similar to Option 1, except that it would specifically list the j measures of effectiveness of a maintenance program to be reported to NRC. It would not specify numerical thresholds that have to be met but, similar to Option 1, would require a licensee to have as part of his program a means to feed back results to improve maintenance, where appropriate. Similar to that i 1 j for Option 1, inspections could be conducted at plants that report data indicating l poor performance. l l The prescriptive nature of the rule would assure uniformity in the measures reported to the NRC. However, since the measures would be codified into regulation, changes in reporting would require a change to the rule. II) Program Element Based Options The Policy Statement on the Maintenance of Nuclear Power Plants lists various activities which the Comission views as being necessary in a plant maintenance program. The following options could address some or all of these activities. The degree of prescription of the details of the maintenance activities increases from Option 3 to Option 5. .I0pt' ion 3-G'eneral Rule /!ndustry Standard in this option, a general rule would require a utility to establish, document and implement a maintenance program. The activities listed in the Policy Statement would be mentioned in the rule in a general sense as items which the maintenance program should address, but would not prescribe by regulation the manner and the extent to which these activities are conducted, in this option, a Reg. Guide would be developed to provide guidance to indusi.ry for the timely development of an industry standard which.the Comiss review and endorse. This app ~ roach is similar to the er.o adoptqOy;the Fedeta Aviation Administration (FAA) and would provide some degree of standardization c to utility maintenance practices. This could be attractive in light of the Cocrnission's emphasis e standardization. The FAA certifies a maintenance program for each type of aircraf t.

Chairman Zech and Consnissioners 4 Ine licensee maintenance program developed in accordance with the regulation ar.d industry standard would not be made part of the FSAR or operating license but rather would only be required to be available for inspection by the Regions. Option 4-General Rule / Reg. Guide The regulatory approach in this option is similar to that for Option 3, except no industry standard would be required. Each licensee would be responsible for developing its own raintenance program using the Reg. Guide..as appropriate. The Reg. Guide would be developed to provide the scope and methods for the. conduct of the maintenance activities. /The results of research in the Nuclear Power Plant Aging flesearch program could provide some information towards the development of the Reg. Guide. As for Option 3, the licensee maintenance program developed in accordance with the rule and Reg. Guide would not be made part of the FSAR or operating license but rather would only be required to be available for inspection by the Regions. Option 5-Prescriptive Rule This option would prescribe, via a detailed rule, the objectives and requirements for the conduct of the maintenance activities listed in the Policy Statement. The Japanese follow a similar approach (mandatory annual scheduled outages); however, their regulatory environment permits industry initiatives and flexibility in the conduct of the maintenonce activities. The scope and level uf prescription in the rule in this option could vary. Specifically, the rule could be applicable to each licensee individually or could require the standardization of maintenance activities across the industry, including the establishment of a central organization to facilitate uniformity in the conduct, quality and feedback of maintenance infonnation. This latter approach would most closely parallel that used by the U.S. Navy. Impact of Options on NRC and Industry Resources The resources required (both NRC and industry) for developing and implementing the rules and supporting. documents will generally increase in going from Option 1 to Option 5. 1he' performance based rulef (0ptions 1 asd 2f will require only ~ limited NRC and industry resources as a result of the limited scope of the rules. These rules will require licensees to report data for'NRC review. NRC inspection of licensee maintenance programs would be carried out based on the review of the data provided by the licensees. The rules in Options 3, 4, and 5 will be more specific on the content of a maintenance program and, therefore, could demand more resources than Option 1 or 2. Among the program element based options, Option 3 will require the least amount of NRC resources. Option 3 will require industry resources to develop an industry standard. However, since the effort for developing an industry standard will be distributed among industry organizations, the impact on each individual organization could be small.

Chairman Zech and Comissioners 5 Irpact of Rulemaking Options on Industry Initiatives Industry initiatives could continue no mtter which approach is taken by the hk'. However, past experience has shown that the initiatives may decrease with the degree of prescription in NRC regulations. Thus impact on industry initiatives would most likely increase in going from Option 1 to Option 5. i The performance based rules (Option 1 and 2) should have the.least impact ort. Industry initiatives. s However, care must be taken to ensure that NRC specified ' performance indicators do not cause industry initiatives or licensee maintenance programs to be manipulated for the purpose of optimizing the information to be reported. i Industry initiatives could be steered towards an industry standard for Option 3. Options 4 and 5, which prescribe the conduct of ma,intenance activities or l provide more detailed NRC guidance, could affect the initiatives taken by the { industry to improve plant maintenance. factors Important in the Selection of a Maintenance Rulemaking Option 1 I from the work done to date in reviewing industry initiatives, reviewing maintenance practices in other industries and countries and developing the above options, certain factors have stood out as important considerations which the staff believes should be used to help guide the decision process in selecting i a final option. Specifically, the factors which the staff believes the option should meet are:

  • Should not divert or hinder good industry initiatives directed toward improving maintenance:

- maintain / promote industry responsibility (ownership) for problem identification, resolution and monitoring ~ - state objectives, not prescribe solutions.

  • Should not require submission of documents or information that NRC does not plan to review.
  • $hould haWp5vlsion to mea's'ur's'6V6iall p'rogr'an effectiveness and ensure, feedback Of result 5'{[ Imp' rove the lM0j% ~

i 1 The preferred option satisfies the above factors. l Schedule l In the memorandum Chilk to Stello, dated 6/17/88, (M880281), the Comission i directed the staff to provide a Notice of Proposed Rulemaking to the Comission { l l

Chairman Zech and Comissioners 6 by October 3,1988. In order to do this, certain items planned for completion prior to providing the Notice of Proposed Rulemaking have been rescheduled to be completed in parallel with completion of the final rule. Chief among these are* 1) final reports on aviation and foreign country maintenance programs and practices, 2) all work on a supporting NUREG documenting development of the rule, 3) completion of a final draf t of the Reg. Guide to accompany the rule (however, sufficient information will be provided along with the proposed rule to provide the basis for developing a Reg. Guide) ard 'j{ final vali6 tion; ofggsl As requested, the Notice of Proposed Rulemaking package to be provided by October 3,1988, will discuss the schedule to complete the rulemaking. In conclusion, the staff is currently evaluating the above rulemaking options. The options and "Strawman" Rule for Option 1 described herein are being provided to the Comission for info-mation and feedback (on an individual basis) prior to our conducting the ilaintenance Rule Workshop on July 11-13, 1988. The workshop will concentrate on soliciting discussion and feedback on the preferred option, but will present the other options as well. Subsequent to the workshop, I plan to provide you with a briefing on the coments received from the public and regulated industry on the preferred rulemaking optiun and the other options discussed at the workshop. To facilitate discussion at the workshop, this memorandum is being placed in the PDR to be available for participants prior to the workshop. 0 ctor Ste lo, Jr. Executive Director for Operations

Enclosures:

1. Decision Chart for Maintenance Rulemaking Options 2. Characteristics of Maintenance Rulemaking Options 3. "Strawman" Rule for the Maintenance of Nuclear Power Plants )

w....au=u v Decision Chart for liaintenance Rulemaking Options Define measures Option 1 l in Reg. Guide ' General Performance N0 Based Rule Heasures of Should the rule Option 2 overall program prescribe the measures? Prescriptive Performance affectiveness Based Rule Yes What activities Yes ?- .0ption 3 listed in Policy General Rule / Industry Standard --4h" Statement should Should a Reg. Guide (FAA approach) b2 addressed in

"- only provide guidance for an the rule?

industry standard? I ,Yes No I Should the rule only functionally Develop Reg. --4>- Option 4 All activities 2: group and list the activities? Guide (s) General Rule / Reg. Guide S No Develop rule defining Oction 5 requirements for activities Prescriptive Rule (Japanese / Navy approach) l I

[baracterest kg ef MainteninCe R31cewalin<j options ENCI.0SLRE 2 Promote Pitentist Compit nce $tsndardized impact on Industry Csst to Cnst ts Ce3. Guide Vtrtfic*tton Maint. Pract. Inttlattves Llaensee NRC _ Coassent s, n Option 1 General Tes-guidance Report info. No small (ifright small sma ll Each licensee (MP!) on acceptable to NRC. MRC MPIs. audit, as needed indicators) chosen) coJ1d select aPprop. MPIs Option 2 Prescriptive Yes-guidance Report info. No small (if right sus 11 small Promotes (HPI) on how to to NRC. MRC indicators calculate MPIs audit, as needed chosen) standardized reporting Option 3 General Yes-genera l NRC audit, as Yes small (uses industry coderate variable Similar to FAA (Ind 5td) guidance on needed content of standard) approach. industry std. Promotes standardized industry practices. Optica 4 General Yes-detailed NCR audit, as ' Na small (Reg. Guide) guidance needed sedera te variable Each licensee would have flexibility to develop his own progras:. Option 5 Prescriptive No (Rule) NRC audit, as Yes large large variable Similar to needed Japanese and U.S. Navy approach. Navy approach would result in maximum s tandardiza t io n of maintenance practices across industry 5

17590-011 Enclosure "3" Proposed Amendment of 10 CFR b0.75 t "Strawman" Rule for the Maintenance of Nuclear Power Plants 1 Enclosure

(7590-01). ~. NUCLEAR REGULATORY CONIISSION 10 CFR Part 50 Improvement of the Effectiveness of Maintenance Programs for Nuclear Power Plants AGENCY: Nuclear Regulatory Comission ACTION: Draft proposed rule

SUMMARY

The Connission is proposing to amend its regulations to require strengthening of the maintenance activities in nuclear power plants to reduce the likelihood of failures and events caused by the lack of effective maintenance. The Comission believes safety can be enhanced by improving the effectiveness of maintenance programs throughout the nuclear industry.

The draf t proposed rule requires the implementation of an effective and documented maintenance program, including reporting of information on measures and indicators of the effectiveness of the program, and feedback of results to ensure improvement, where appropriate. Guidance on acceptable measures and indicators of effectiveness of maintenance programs will be provided via a Reg. Guide. EFFECTIVE DATE: FOR FURTHER INFORMATION CONTACT: Moni Dey, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555,(301)492-3730. 2 Enclosure

17590-01} SUPPLEMENTARY INFORMATION: On March 23, 1988, the Cournission published a final Policy Statement on Maintenance of Nuclear Power Plants. In the Policy Statement, the Connission stated that it expected to publish a Notice of Proposed Rulemaking in the near future and provided the general f ramework for the proposed rule. The Commission has a program to continually evaluate the operational performance of nuclear power plants. Analysis of operational events has shown that, in some cases, nuclear power plant equipment is not being maintained at a level which it could b' to ensure that the equipment will e perform, with a high degree of reliability, its intended function when required. A limited tiRC examination of nuclear power plant maintenance programs has found a wide variation in the effectiveness of these programs. At some plants maintenance has been a significant contributor to plant reliability problems and hence, is of safety concern. The Commission believes safety can be enhanced by strengthening the effectiveness of maintenance programs throughout the nuclear industry and, accordingly, this is the objective of this proposed rule. It is the objective of the Commission that all components, systems and structures of nuclear power plants be effectively maintained so that plant equipment will perform its intended function when required. To accomplish this objective, each connercial nuclear power plant should develop and implement a well-defined end effective prograai to assure that maintenance activities are conducted to preserve or restore, with prompt repair, the availability, performance and reliability of plant structures, systems, and components. Jhe' program should clearly define ~ theponentg and activities; included, as well as 'the Nanagement.. systems used Wifo'nt@. ~ .._....w~ those activities. further, the program should include feedback of specific results to ensure corrective actions, provisions for overall program, evaluation, and the identification of possible component or system des.ign problems. F,isally,, the program should include indicato'r's'r'etated tj , easuring effectJvfe,isint'enadce' 3 A set of candidate maintenance performance m indicators (MPIs) has been included as an appendix. The set of MPIs is 3 Enclosure

(7590-011 expected to be modified as experience is gained. The staff expects to issue a Regulatory Guide to provide guidance to the industry as an acceptable way of satisfying the rule. PART 50 - DOMESTIC LICENSING 0F PRODUCTION AND UilLIZATION FACILITIES 1. The Authority citation for Part 50 continues to read as follows: Authority: Secs 103.104,161,182,183,186,189, 68 Stat. 936, 837, 948, 953, 954, 955, 956, as amended, Secs. 234, 83 Stat.1244, as amended (42 U.S.C. 2133, 2134, 2201, 2232, 2233, 2236, 2239, 2282); Secs, 201, 202, 206, 88 Stat. 1242, 1246, asamended(42 U.S.C.)5841,5842,5846), unless otherwise noted. Section 50.7 also issued under Pub. L.: 95-601, Sec. 10, 92 Stat. 2951 (42 U.S.C. 5851). Sections 50.58, 50.91 and 50.92 also issued under Pub. L. 97-415, 96 Stat. 2073 (42 U.S.C. 2239). Section 50.78 also issued under Sec.122, 68 Stat. 939 (42 U.S.C. 2152). Sections 50.80-50.81 also issued under Sec.184, 68 Stat. 954, as amended (42 U.S.C. 2234). Sections 50.100-50.102 also issued under Sec.186, 68 Stat. 955 (42 U.S.C. 2236). For the purposes of Sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273), 5 50.10(a), (b), and (c) 50.44, 50.46, 50.48 and 50.80(a) are issued under Sec.161b, 68 Stat. 948, as amended (42 U.S.C. 2201u.,, il 50.10(b) and (c) and 50.54 are issued under Sec.1611, 68, stat. 949, as amended (42 U.S.C. 2201(i)); and il 50.55(e), 50.59(b),50.70,50.71,50.72,and50.78areissuedunder Sec.1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)). 2. A new $ 50.75 is added to read as follows: i 50.75 Requirements for improving the effectiveness of maintenance programs for nuclear power plants. 4 Enclosure

17500-01) (a) Applicability. The requirements of this section apply to all nuclear power plants. (b) Definition. For the purpose of this section, the Comission defines maintenance as the aggregate of those functions required to preserve and promptly restore safety, reliability, and availability of plant structures, systems, and components. Maintenance includes not only activities traditionally associated with identifying and correcting actual or potential degraded conditions. i.e., repair, surveillance, diagnostic examinations, and preventive measures; but extends to all supporting functions for the conduct of these activities. These activities and functions are listed below: Technology in the areas of Corrective maintenance, Preventive maintenance, Predictive maintenance, Surveillance; Engineering support and plant modifications; Quality assurance and quality control; Equipment history and trending; Maintenance records; t Management of parts, tocls, and facilities; Procedures; Post-Maintenance testing and return-to-service activities; 5 Enclosure

f {7590-011 Measures of overall program effectiveness; Maintenance management and organization in the areas of Planning. Scheduling,

Staffing, Shift coverage, Resource allocation; Control of contracted maintenance services;

{ Radiological exposure control (ALARA); f Personnel qualification and training; J Internal comunications between the maintenance j organization and plant operations and support groups; Communications between plant and corporate management and the maintenance organization; Maintenance recomendations or requirements of individual l vendors. I l l (c) Requirements. Each holder of an operating license for a nuclear power plant l (licensee) shall (1) maintain and implement an effective and documented maintenance program, (2) measure the effectiveness of the maintenance program and, based upon this measure, improve maintenance where appropriate, and (3) submit quarterly to the Comission a gintapance'Pe'rfoEma'nci V@Mwhich shall include data for the indicators of the effectivencss of the maintenance program. Each licensee shall develop an appropriate 6 Enclosure

^ 9590-01} set of indicators of effectiveness which address the following functions: (1) Overall Plant Performance Related to Maintenance (ii) Management Support of Maintenance (fii) Maintenance luglementation (d) Implementation By [ insert a' date 3 months af ter the effective date of the arnendment] each licensee shall certify, by letter to the Director of the Office of Nuclear Reactor Regulation, that an effective, documented maintenance program is being maintained and implemented, which includes measures to monitor and improve the program, where approriate. In addition, each licensee shall submit to the Director of the Office of Nuclear Reactor Regulation the Quarterly Maintenance Performance Report requested in Paragraph (c), including an explanation of the method used to calculate the performance indicators. Dated at this day of 1989 for the Nuclear Regulatory Commission Samuel J. Chilk Secretary of the Commission 7 Enclosure M rp i --.. +

Aeewou _ CANDIDATE MAINTENANCE PERFORMANCE INDICATORS 1 A/ r9 1. Ratio of Preventive to Total Maintenance. The definition of this indicator is identic'al to the one used by INPO. It is the ratio of non-outage preventive and surveillance testing man-hours to total non-outage mainte-nance (corrective and preventive maintena..ce, and surveillance testing) man-hours, f., 2. Corrective Maintenance Backlog Greater than Three Months Old. This indicator (used by INPO) is defined as the percentage of open corrective maintenance work requests (MWRs), not requiring an outage, that are greater than three months old. J 3. Preventive Maintenance Items Overdue. This indicator (used by INP0) is defined as the percentage of preventive maintenance items in the period that were not completed by the schedule date plus a grace period equal to 25% of the schedule interval. 4. Maintenance Staff Turnover Rate. It is the number of vacancies in a functional group, e.g., mechanical maintenance department, created by voluntary re.ignation divided by the average number of employees in that group. Retirement, death, promotion, termination for cause and part-time employment are not considered in the turnover rate, 5. Maintenance Rework. This is defined as the number of HWRs reopened in a c period. 6. Ratio of Deficiencies Discovered During Surveillance to those Discovered During any Demand (i.e., Demand During Surveillance or Event). (self explanatory) 7. Number and Duration of BOP Equipment Out of Service. It is the total number of BOP equipment (e.g., Instrument Air Compressor) that are out of service in a period. The out of service duration of each BOP equipment in a period is added to obtain the curation of BOP equipment out service. // 8. Safety System Performance Indicator. This performance indicator (used by INPO) is calculated separately for three PWR systems and three BWR systems. The systems for PWRs are high pressure safety injection, auxiliary feedwater, emergency AC pnwer, and for BVRs are high pressure coolant injection (high pressure core spray or feedwater coolant injection), and reactor core isolation cooling (or isolation condenser), residual heat renoval, and emergency AC power. For each system, this indicator is defined as the sum of the unavailabilities of the components in the system during a time period, divided by the number of trains in a system. i

9. hean Tice to Return to Service, it is defined as the sum of the out of service durations of equipment in a period divided by the number of equipment. Onlymajorequipment of service due to failures are con (e.g., those in the NPROS) that are out sidered. 10. Backlog of__ Engineering Change Notices (ECNs) Related to Equipment Per-formance. It is definra as the percentage of Echs generated by plant staff to correct equipment performance problems that were not completed within the schedule plus a grace period equal to ?S% of the scheduled completion time. 4 E 8 4 i

7.- ?,*. List o' Attendees at Meeting with INPO Juna 28, 1908 1 INPO NRC Pat Beard (part-tine), Vice President. Thomas Novak. Diractor Government Relations Division of Safety Programs, AEOD Terry Sullivan, Group Vice President Rabi Singh, Chief Analysis and Engineering Performance Indicator Section, AE00 Gary Fader, Manager, Plant Analysis Ed Moore, Vice President and Director Plant Support Services Rick Jacobs, Government Relations Bill Dean, Maintenance Department Gary Peterson, Manager Maintenance Department H L r, 9 9 ,w we-v*- F" ' " * *'"""7N"*W T' =}}