ML20195G680
| ML20195G680 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/1987 |
| From: | Zech L NRC COMMISSION (OCM) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20154D839 | List: |
| References | |
| CON-IIT07-776-91, CON-IIT7-776-91 COMLZ-87-51, NUREG-1455, NUDOCS 8711040258 | |
| Download: ML20195G680 (2) | |
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ENCLOSURE 3 i<,\\c.a
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UmYE D STATc3 f, * ' '
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October 9, 1987
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CHAIRMAN g *,
cp pt-97-51 g PEFORANDUM TOR: Victor Stello, Jr.
Executive Director for Operations h iv.
@k, FROM:
Lando W. Zech, Jr.
$Ulk'tCT:
COMM155!0N POLICY STATEMENT ON t4AINTEt1NCE As you knnw, the Comissinn approved the staff's propot al to proceed with '
development of a Comission Policy Statement on Maintet ance in April of this year, t! pen reflection, the Comission believes ti at sone changes to the policy cut 11ned in SECY-86-316 need to be made in order to address all significant policy elements, to ensure the effectivenet 5 of industry initiatives, and to reinforce the importance the Comit sion places on this policy.
I am bringing these changes to your attention at this tiene so they can be f actored into the staff's' proposed policy stater. ant before Comission consideration and to avoid undue schedule ir pacts.
First, please assure that Cemissioner Carr's exr.ents en SECY BS 316 are considered in development of the proposed policy statenent. The inportant roles of preventive and predictive maintenance should t.e addressed as well as the significance'of good maintenance practices to itsproved safety, reliability, and life extensior) for, aging plants.
Second, particular attention should be paid to maintent.nce practices in balance of plant systems and components where plant tr.,nsients and challenges to safety svstems may be avoided by improved maintenance practices and procedures.
The policy statenent should explicate an fRC position that maintenance programs and procedurcs must reflect a canagement comitment to total systems attention.
In addition, the following specific coments should qu'de the staff in preparing the proposed Comission Policy on P.aintenance:
1.
The staff should proceed with an Advance Notice o' Proposed Rulemaking cr.d studies necessary to develop a proposed maintor.ance rule when the maintenance policy statement is issued.
Ec schsLTe7h15uTrl be such u
that the proposed rule will be ready for Comie, ion consideration about the time that the period of evaluation of iisdustry progress, outlined in the maintentrice policy statement, expires. Any proposed nalntenance rule should avoid indirectly encouraolrg the limitation of vigilant maintenance to safety related cceponents and systems.
The maintenance policy statement should indicate J,at the Comission will darer imposition of nes r.aintenance requirer. nts to the extent tnat industry maintenance initiatives are ef fecti"e and consistently applieJ.
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The staff should develop one or rore objective maintenance performance indicators as part of the performance indicator progran, to enhance our ability to monitor licensee maintenance performance and the effectiveness of industry self-improvement initiatives.
If feasible, performance indicators should be implemented before issuing the policy statement.
l 2.
The staff should continue to devote whatever resources are necessary to those plants with category 3 SALP performance in maintenance that NRf 1
monitoring indicates are not achieving the improvement intended by the policy statement.
Fesources necessary to implement the proposed maintenance policy should be i
explicitly sddressed in your proposal.
The Commission considers each of these comments to be important to the overall goal of enhanced safety based on improved maintenance practices at licensed conwercial power reactors.
Your prompt attention to these matt "?s is appreciated.
cc: Commissioner Roberts Connissioner Bernthal Connissioner Carr Commissioner Rogers AEOD NP.R
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SECY OGC GPA 1
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