ML20195G877
| ML20195G877 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/1987 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML20154D839 | List: |
| References | |
| NUDOCS 8712210174 | |
| Download: ML20195G877 (12) | |
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UNITED STATES
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g NUCLEAR REGULATORY COMMISSION W ASMO TON. O. C, m66 OEC 161987
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MEMORANDUM FOR:
Edward L. Jordan, Chairman Comittee to Review Generic Requirements FROM:
Thomas E. Hurley, Director i
Office of Nuclear Reactor Regulation
SUBJECT:
COMMISSION PAPER AND PROPOSED POLICY STATEMENT ON MAINTENANCE l
The enclosed Comission Paper and proposed Maintenance Policy Statement (Enclosure 1) was prepared by the staff in response to the Staff Requirements Mercranda (SRM), dated April 27, 1987, and October 19, 1987 (Enclosures 2 and 3).
1 The Comission I sper presents the underlying considerations that were analyzed in the 41evelopmeit of the proposed Policy Statement.
In this analysis, the staff evaluated the findings of the NRC Maintenance and Surveillance Program and other programs relevant to maintenance and assessed the initiatives that industry has undertaken. The proposed Policy Statement was designed to accomplish the following objectives:
(1) delineate the Comission's nuclear power plant maintenance, (2) specify a time period (2 years) goals for after which the Comission will assess whether the initiatives being implemented by the industry meet the Comission's goals, and (3) define the means of oversight the NRC will utilize to monitor industry activities and programs during the 2-year trial period, i
The proposed Policy Statement acknowledges voluntary industry self-improvement for the time being, and provides the Comission with the option of estabitshing i
i requirements via rulemaking if a lack of progress warrants such action at a later date.
J The industry initiatives addressed in the Policy Statement were provided by a letter from INPO dated September 10, 1987.
l The proposed Policy Statement recognizes ongoing industry efforts and does
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i not impose any new regulatory requirements. We are prepared to provide the 1
Cemittee with a briefing or revice describing the Policy Statement, industry i
initiatives it addresses and the means of NRC oversight at the December 23, 1987 rieeting.
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I CONTACT:
G. C. Cwalina. NRR X24045 gy h------------------------------------
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-2 DEC 161987 l
1 Supplementary information in accordance with the CRGR Charter of April 1987 l
1s also provided in Enclosure 4.
c4twdh Mnu 1
) omas E. Murley, Di e r
'fice of Nuclear Reactor Regulation
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Enclosures:
1.
Connission Paper and Proposed M4intenance Policy Statement 2.
Staff Requirements tiemoranda, 4/17/87 I
3.
Staff Requirements Memoranda, 10/19/67
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4.
Supplemental Information for CRGR 2
cc:
Y. Stello ED0 4
i J. Snlezek, NRR l
R. Scrnero, MNSS j
D. Ross, RES T. Martin, RI C. Heltemes, AEOD T. hovak AEOD l
l B. Sheron, RES F. Miraglia, NRR D. Crutchfield, NRR j
1 S. Varga, NRR i
L. Shao, NRR l
1 C. Rossi, NRR F. Congel, NRR i
q J. Partlow, NRR W. Johnston, RI l
A. Gibson, RI!
l D. Miller, Rill i
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J. Milhean, RlY I
D. Kirsch, RV i
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t f.or:
The Comissioners From:
Victor Stello, Jr.
Executive Director for Operations
Subject:
INTERIM POLICY STATEMENT ON MAINTENANCE OF NUCLEAR F0WER PLANTS i
Purpose:
To provide the Comission with a Policy Statement on
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Maintenance (Enclosure 1).
Background:
Since 1985, when the NRC Maintenance and Surveillance Program Plan was developed, the staff has provided the Comission with several reports and uriefings to describe I
the status of maintenance in the U.S. nuclear industry, i
The staff's findings presented in these communications clearly estabitsbed the relationship between maintenance and i
plant safety.
In April 1987, the Comission directed the i
staff to develop a Policy Statement to formalize the Comission's position on maintenance.
l Discussion:
ThePolicyStatementonMaintenance(1)definesmaintenance in a comprehensive manner; (2) describes a framework for f
effective maintenance programs; (3) states the Comission's position on structures, systems, ar.d components to be i
included in maintenance programs; (4) specifies the NRC's future actions, and (5) recognizes industry initiatives.
1 The Policy Statement has been developed, in part, to assure that various rules, regulations and requirements are fully integrated within the utility's organization. The underlying philoscphy of the proposed Policy Statement is that corrective, preventive and predictive raintenance should be conducted on equipment commensurate with its import 6tice to safety.
i CONTACT: John P. Jar.kovich, NRR j
49-24892 i
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2 The Policy Statement specifies a two year period to evaluate i
the effectiveness of industry initiatives. The staff will conduct team inspections at selected sites over the next two years, cocynencing in Spring 19P8. At the end of the evaluation period the NRC will decide whether a maintenance rule is required and, if so, what fom the rule should take.
To prepare for that decision, the staff will issue an i
Advance Notice of Proposed Rulemaking and develop a proposed
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rule during the evaluation period.
TheInstituteofNuclearPowerOperations(INPO)has provided a current listing of their maintenance initiatives in a letter to NRC, dated September 10, 1987 (Enclosure 2).
l The NRC will have access to important INPO documents and data which are necessary to assist in the accurate assessment of industry progress.
During this trial seriod, the NRC will continue to take action to ensure t1st existing regulatory requirements are met.
Resources:
hRC will carry out team inspections at selected licensed l
1 facilities to assess industry progress. Resources for the team inspections will be reprogramed from existing NRR l
programs.
recomendation: That the Comission approve the Interim Policy Statement on Maintenance and note that it will be published in the I
Federal Register with a coment period of 60 days.
Schedule:
Pecomend affirmation at an open meeting.
F l
Victor Stello, Jr.
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Executive Director i
for Operations
Enclosures:
i 3: NRC Policy Statement on l
Maintenance of Nuclear Power Plants 2.
IhPO Letter. September 10, 1987 t
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i DISTRIBUTION: WITS 860238 i
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- 12/ /87
- 12/ /87 J'
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JJankovich/rif GCCwalina JAZwolinski JVRoe JSnierek l
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DATE:
12/ /87 12/ /87 12/ /87 12/ /87 12/ /87 I
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FNCLOSURE 1 e
i NUCLEAR REGULATORY COMMISSION l
INTERIM COMMISSION POLICY STATEFENT ON MAINTENANCE OF N9 CLEAR POWER PLANTS
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AGFNCY Nvalese Ryu13tery Cemit:icn.
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ACTION:
Interim Policy Statement.
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SUMMARY
- This Policy Statement is to inform the industry of the expectations l
of the Comission regarding the maintenance of nuclear power plants. With I
I this Policy Statement the Comission intends to erphasize the irportance of t
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maintenance in nuclear safety and to evaluate the industry initiatives underway to upgrade r.aintenance programs during a two year evaluation period, a
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EFFECTIVE DATE: This Interim Policy Statement is effective upon issuance.
I However, the public is invited to submit coments by On the basis of the submitted coments, the Comission will determine whether to riodify the Policy Statement before issuing it as final, r
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FOR FL'RTHER lhFORMATION CONTACT: Jack W. Roe. Office of Nuclear Reactor h
Regulation. U.S. Nuclear Regulatory Comission. Vashington DC 20555 telephone (301) 492-4E03.
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POLICY:
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l BACKGROUND L
l The Comission has a program to evaluate continually the operational
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performance of nuclear power plants. Analysis of operational events has j
shown that, in mar.y cares, nuclear power plant equipment is not being maintained at a level comensurate with its importance to safety. A 11Mited examination of nuclear power plant raintenance programs has foend a wide variation in the effectiveness of these programs.
Inadequate maintenance at some plants has been a significant contributor to plant and safety 1
j reliability problems and, hence, is of safety concern.
It is for this reason i
that this Policy Statement is being issued.
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i P01.!CY STATEPENT I
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It is the objective of the Comission that components, systems and structures I
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of nuclear po er plants be maintained so that they are available to perforn i
their intended functions.
In the event a coeponent. system or structure is l
l unable to perform its intended function, it should be proeptly repaired.
In I
crder to accerplish this objective, each licensee should have a prescribed maintenance program which provides for the availability end prompt repair of plant components, systers and structures comensurate with their importance I
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to safety.
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3-SUPPLEMfETAP,Y INFORMATION:
Definition of Maintenance The Commission defines maintenance as the aggregate of those funcitons that are aired at preserving or restoring safety, reliability and availability of plant structures, systems, and components. As such, maintenance includes not only activities traditionally associated with identifying and correcting degraded conditions, i.e., repair, surveillance, diagnostic examinations, and preventive reasures; but extends to include all tupporting functions for the conduct of these activities.
For example, the supporting functions that are l
considered to be integral to maintenance include such activities as engineering analyses and technical support; organization; planning, scheduling and work control; reporting, trending and analysis activities; staffing and qualifications for rechanical, electrical, electronic, instrumentation and control, and chemistry functions; supervisory control; 1
parts and tool r.anagement; interface with operations, review groups and i
sinilar activities; and radiation exposure control.
I Framework for Maintenance Programs All coerercial nuclear power plants should develop and implement well defined and effective prograr.s to assure raintenance activities are conducted to L
preserve o' restore the availability and reliability of plant structures, systems and corponents to a level commensurate with their significance to i
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safety. Although licensees are organized and managed in diffcrent ways, the i
following elements have broad applicability in any framework for an effective maintensnce program:
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Establish Program Objectives,:
I it is important to analyze plant raintenance requirements ine.ludtrg j
technical, management and organization naeus and establish l
maintenanceprogramobjectives.
The objectives should include those requirements necessary to ensure that plant corponents, i
systers and structures are maintained so that they are available to
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perform their intended functions.
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Develop and Implerent Program:
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The maintenance progran should accomplish the objectives. An i
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adequate program should consider:
technology in the areas of corrective maintenance, preventive maintenance, predictive maintenance and surveillance; engineering support and plant modifications; quality assurance; equipment history and trendir.g; ransgerent of parts, tools and facilities; procedures; post-raintenance testing and return.to-service activitits; maintenance l
ransgerent and organization in the areas of planning, scheduling, i
shift coverage, resource allocation; quality control; radiological exposure control; staffing, qualification and training; interface 1
i with plant operations; and interface with plant and corpnrate ransgerent.
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3.
Program Evaluation:
1 Licensees should develop methods and criteria to evaluate the j
effectiveness of maintenance activities on a periodic basis to j
assure that the objectives are being met.
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Feedback:
t Evaluation results should be fed back into the program objectives and the maintenance program to assure that lessons are learned and shortcomings are corrected.
Components, Systems and Structures i
P.aintenance programs should encoepass all plant components, systems and
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structures. The attention devoted to a component, system or structure should be conmensurate with its importance to safety. To this end the Commission expects maintenance programs to focus primary attention to those iters which:
j are relied upon to remain functional during and following design basis events to ensu.a:
the integrity of the reacter coolant pressure boundary.
the capability to shut down the reactor and maintain it in a safe shutdown condition; or i
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6-the capability to prevent or mitigate the consequences of l
accidents that could result in potential offsite exposures comparable to tha ;0 CFR 100 guidelines.
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components, systems or structures whose failure could lead to:
l a reactor scram, or a transient, or
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a condition outside the design basis of the plant, or j
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being in an unanalyzed condition that compromises safet.y. or l
an uncontrolled release of radioactive material.
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l are utilized in emergency operating procedures, f
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I are utilized in monitoring the status of reactor paraM ters, I
are utilized in fire protection, I
i are utilized in the prevention or monitoring of radiation exposure.
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j are utilized in plant security.
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KEC Assessment Activities I
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In order to r.onitor industry progress in meeting tFe expectations of this t
Policy Statement, the NRC staff will conduct several assessment efforts, i
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During the two year evaluation period, the ARC assessrent efforts will cover t
prograftatic and plant-specific activities in the following areas:
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7 Cirect inspections and assessments of licensee maintenance programs at selected sites.
Review of the licensee's use of the Nuclear Plant Reliability Data System (NpRDS) reporting program and related activities concerning i
trending and analysis of failure data, l
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Review of the INPO plant and corporate evaluation programs and j
evaluation reports in the area of maintenance, 4
l Direct observation of the conduct of INPO plant evaluations in the I
area of maintenance.
1 Industry Activities 1
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The Commission recognizes that the industry has made progress in developing j
and implementing prograr.s intended to improve nuclear power plant l
t maintenance. The Comm.ission realizes the importance of these initiatives and
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wishes to encourage further self improvement. Therefore, subject to the continued improvemer.t of industry maintenance programs, the Commission is I
de'ferrirg rulemaking for a period of two years, during which tir4 the NF.C l
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staff will evaluate the effectiveness of industry reintenance initiatives.
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ENFORCEMENT Nothing in this Policy Statement shall limit the authority of the hRC to I
j conduct inspections or to take appropriate enforcerent action when regulatory l
requirerents are not met.
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