ML20195J913
| ML20195J913 | |
| Person / Time | |
|---|---|
| Issue date: | 11/21/1988 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| References | |
| FRN-53FR47822, RULE-PR-50 PR-881121, NUDOCS 8812050092 | |
| Download: ML20195J913 (29) | |
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$3 AN7 34262 NUCLEAR REGULATORY COMMISSION '83 N0'.' 21 P 4 :04 10 CFR Part 50 .J, k -
Ensuring the Effectiver.ess of Maintenance Programs for Nuclear Power Plants AGENCY: Nuclear Regulatory Commission.
ACTION: Proposed Rule.
SUMMARY
- The Ccemission is proposing to amend its regulations to require commercial nuclear power plant licensees to strengthen their maintenance activities in or.sr i.n reduce the li.\elihood of failures and events caused <
by the 'ack of effective maintenance. The Commission believes safety can and must be enhanced by defining cn adsquate scaintenance program to ensure the e'ifectiveness of such programs throughout the nuclear industry, f
The proposed rule requires plant maintenance programs to include specific !
Activities, including the monitoring of the effectiveness of plant maintenanti programs.
DATE: Comment period expires January 27, 1989 . Comments received after this date will be considered if it is practical to do so, but assurance of cor. sideration cannot be given except as to comments received on or before this date.
l ADDRESSES: Mail written comments to: Secretary, U.S Nuclear Regulatory Commission, Washington, D c. 20555, Attention: Occheting and Service dranch.
Deliver cemments to: 11155 Rockvile Pike, Rockville, MD.
between 7:30 as and 4:15 pm weekdays.
8912050092 001121 PDR PR I 50 b3FR47022 PDR 1
t9/
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' Copies of the paper on rulemadng options, transcript and proceedings
.of the Public Workshop, draf t NUREG report, draf t regulatory analysis, !
environmentalassessmentandfindingofnosignificantimpact,thesupporting{
statement submitted to OMB, and comments received may be examined at: the j HRC Public Occument Room, 2120 L Street, tower Level, N.V. , Washington, i 1
0.C. '
FOR FURTHER INFORMATION CONTACT: Moni Dey, Office of Nuclear Regulatory i
Research, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, !
t (301) 492 3730. I i
i SUPPLEMENTARY INFORMATION: i,
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l l BACKGROUND i i j
On March 23, 1988, the Commission published a final Policy Statement f on Maintenance of Nuclear Power Plants. In the Policy Statement, the :
j Commission stated that it expected to publish a Notice of Proposed
] kulemaking in the near future and provided the general framework for the proposed rule. }
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j The Commission has a program to continually evaluate the operational f performance of nuclear power plants. Analysis of operational events has j shown that, in some cases, nuclear power plant equipment is not being
]i maintained at a level to ensure that the equipment will perform, with a high degree of reliability, its intended function when required. A j limited NP.C examination of nuclear power plant maintenance nrograms has f found a wide variation in the effectiveress of these programs. At some plants, maintenance has been a significant contributor to plant reliability
- probloms and hence, is of safety concern. The Commission believes safety
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can and must be enhanced by strengthening the effectiveness of maintenance l
programs throughout tre nuclear industry and this is the objective of this proposed rule.
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DESCRIPTION It is the objective of the Commission that all components, systems and structures of r.uclear power plants be effectively maintained so that olant equipment will perform its intended function when requirert. The scope of the proposed rule is intended to cover all systems, structures and cocponents including those in the Balance of plant (BOP). To ;
accomplish this objective, the proposed rule wculd require each commercial I nuclear power plant to develop and implement a well-cefined program to f assure that maintenance activities are conducted to preserve or restore, f
with prompt reoair the availability, performance anc reliatility of plant >
structures, systems, and components. The program should clearly define the components and activities included, as well as the mantagement systems
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j used to control those activities. Further, the program srould include !
t feedback of specific results to ensure corrective actions, provisions for j overall program evaluation, and the identification of possible component
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or system design problems. Compliance with the rule world be verified by f
NRC audit and inspection. I The proposed rule does not require that licenseer report Maintenance i Performance Indicators (MPIs). However, each licensee would be required !
to have his own system for monitoring maintenance effectiveness which I would be subject to NRC review. The Commission sol',cits comments on the (
application and usefulness of MFis as part of the rule, and whether a set f
of MPIs exists which could indicate the effectiveness of plant j maintenance programs, in addition, the Commissioi solicits feedback on {
whether to eequire reporting a specific set of Mf'Is to the NRC as pt.rt of f the rule. J PUBLIC WORKSHOP l
The Commission held a Public Workshop on July 11-13, 1988 in l
Washington, D.C. to solicit early input for the formulation of the rule t from the public and regulated industry. Frior to the Worksbap, a paper on rulemaking optiens was distributed to interested parties te facilitate 3
Workshop discussions. The paper on rulemaking options1 , and the transcript and proceedings (NUREG/CP - 0099)2 of the Workshop are available for inspection in the NRC Public Occument Room, 2120 L Street, Lower Level, N.W., Washington, D.C.
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As a result of Workshop dis:ussions, the Commission has ccme to the following conclusions:
1.
Rulemaking should encourage industry initiatives directed toward '
improving maintenance, since such initiatives promote industry responsibility for problem identification and resr!ution; 2.
Prescriptive rulemaking options may impece industry initiatives and responsibility to improve maintenance; and
- 3. Rulemaking should be directed teward specifying the NRC's expectations in maintenance and requiring licensee monitoring of the effectiveness of maintenance programs.
Therefore, the Commission proposes a maintenance rule which gives incentive for industry to develop a standard for a main +enance program, which NRC may encorse in a Regulatory Guide.
1 Memorandum f rom Victor Stello, Jr. , Executive Director for Operations, to the Commissioners, "Proposed Rulemaking for the Maintenance of Nuclear Power Plants," dated June 27, 1988, 2
Copies of NUREG series reports may be purchased through the U.S.
Government Printing Office by calling (202) 275-2060 or by writing to the U.S. Government Printing Office, P.O. Box 37082, Washington. 0.C.
20013-7082. Copies may also be purchased from the Ne ional Technical Information Service, U.S. Department of Comerce, 5285 Port Royal Road, Springfield, VA 22161. A ccpy is available for inspection or copying for a fee in the NRC Public Document Room, 2120 L Street, Lower Leval, N.W., Washington, D.C.
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r EXPECTATIONS FOR MAINTENANCE STANDARD The Commission encourages indystry to develop a Maintenance Standard i which will provide guidance for complying with requirements of the proposed ,
rule. TFe Commission believes that the development of a standard will guide l current incustry initiatives towards developing and implementing acceptable ,
maintenance programs, and that etility participation in preparation of a Maintenance Standard will provide additional incentive and responsibility for improving plant maintenance programs.
The Commission plans to develop a Regulatory Guide to provide guidance for complying with the rule if industry does not develop an adequate standard However, the Commission prefers to endorse an industry-developed standard.
) To meet the Commission's plans for implementation of the rule the industry commitment to develep a Maintnnance Standard should be made now and a final standard should be proposed no later than September 1,1989. The Commission expects to publish a Regulatory Guide endorsing a Maintenance Standsrd or providing NRC guidance in November 1989. The comprehensive program requirements of the proposed rule would be -equired to b3 fully impleme.Y.ed within two years following publication of the final Rule, 4
The proposed rule defines those attributes the Commission considers n2cessary
) for an acceptable Maintenance Program. To be acceptable, any standard developed to implement the rule should have the following characteristics:
Should define the plant systems, structures and components included in ine maintenance prograa (the scope of the rule covers all systems, struct.ures and cneponents including those in the BOC);
Should require a systematic evaluation ("systems approach") of the functions and objectives of plant sysuems, components and structures to determine maintenarce activities ano requirements; Should provide clear and specific programmatic requirements that 5
i can be practically implementee to achieve high reliability; Should be comprehensive in addressing the activities and
, functions included in the proposed rule plus provisions for self ,
assessment; i
Should reference standards or guidelines such as those developed l
ty ANS, ASME, IEEE, ASTM, INPO, or EPRI where practical to I
provide (a) spacific programmatic requirements or (b) guidance l for maintenance of specific typas of equipment; !
t Should allow flexibility for adoption of r.ew innovative technologie (
as they are validated; and I Should provide for sufficient documentation so that program !
effectiveness and compliance with requirements of the standard can be evaluated.
The Cen. mission has conducte:1 studies to review effective maintenance ;
approaches and practices in other countries and industries and has documented the findings ir, a draft NUREG series report.3 The Commission seeks commants on the draf t NUREG report which may be submitted to the t NRC as indicated under the ADDRESSES heading.
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3 A f ree single copy of draf t NUREG-1333, "Maintenance Approaches and .
Practices in Selected Foreign Nuclear Pcwer Programs and Otner U.S. l Industries: Review and Lessons Learned," to the extent of supply, may be ;
obtained by writing to the Distribution Services Section, Document l
Control Branch, Division of Information and Support Services, U.S. Nuclea !
Regulatory Commission, Washington, D.C. 20555, A copy is also available for inspection or copying for a fee in the NRC Public Occument Roem., 2120 t L Street, Lower Level, N.W. , Washington, D.C.
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1 The craft NUREG report concludes that the following are practices in foraign countries and other U.S. industrial maintenance programs which 4
nave been found to contribute significantly to effective maintenance:
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- 1. Focusonlongtermmaintenanceobjectives;establishaproactive t
maintenance program as opposed to reactive maintenance; i
1 2. Use of a reliability centered approach to maintenance, including consideratien of the man-machine interface; i s
- 3. Collection and engineering evaluation of fai 1 e data (root cause analysis);
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. Use of an integrated information system for collecting data and monitoring the effectiveness of a maintenance program; 3
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- 5. Use of maintenance technician training / certification programs; !
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- 6. Derive planning and scheduling from overall program objectives; J ,
- 7. Enhance environment / motivation of maintenance technicians (e.g. l l thru cross-training, "Crew Chief" concept); and I L i 8. Clearly define interf aces between maintenance and other i activities (engineering support, operations QA, QC, corporate ;
offices, safety review), t i
The Commission encourages in the development of any Maintenance Standard L co.isideration of the findings in the above referenced draf t NUREG report i and any other pertinent studies on effective maintenance practices. (
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The Commission also encourages the industry to consider incorporating appropriate maintenance derived from plant aging studies in the !
Maintenance Standard, i I r
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l The Commission views maintenance rulemaking as an opportunity to encourage (a) good maintenance practices, (b) the adoption of common maintenance standards, and (c) the development of valid quantitative measures of ef fectiveness which could become the basis for regulation by outcomes rather than processes. Thehereinproposedruleaddresses(a) <
and (b) but not (c). Follow-on rulemaking is envisioned which would build .
on the bases established in this rule and would define those validated measurable quantities or indicators that could credibly beccme the basis for regulatory attention or action in the future instead of the systems for maintenance under (a) and (b) of this proposed rule.
As noted above, an integral part of a good maintenance program is the monitoring and feeaback of results. Programs should utilize quantitativemeasurestomonitorandadjustthemaintenanceprogram activities. Measures that are based upon actual component reliability and failure history provide useful indication of maintenance effectiveness. Such measures need a well structured and component oriented system: (e.g., the Nuclear Plant Reliability Data System (NPR05))
to capture and track equipment history data. The Ccmmission notes and encourages the use of the industry-wide NPROS for this purpose in view of the multiple uses for the data.
CERTIFICATION OF PLANT MAINTENANCE PROGRAMS The Comission wishes to encourage industry initiatives and responsibility for problem identification and resolution. Therefore, as a further way of enccuraging industry participation and responsibility, the Comission is willing to consiaer a process of utilizing a designated third party, similar to the ASME code system, to review and certify l
licensee maintenance programs for conformance with the Haintenance
- Standard. This process, if successful, could alleviate the need for
' detailed NRC inspection of all licensee maintenance programs. The Cemission solicits proposals for conducting such a certification process.
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COMMENTS REQUESTi0 In addition to comments on the content of this Notice of Proposed Rulemaking, the Commission specifically solicits input on the following:
- 1. Is it appropriate for the nuclear power iraustry to 1:velop a Maintenance Standard and, if so, would the industry eyelop tuch a Maintenance Standard? '
- 2. '
What level of detail should be included in the Paintenance 5tandaro?
- 3. !$ t'ao years a reasonable time to develop, and implement a standarc?
4.
Is it apprcpriate for a designated third party to certify plant maintenance programs to comply with the Maintenance Standard; j
and, if so, would an organization be willing to perfore such j certification?
- 5. The Comission plans to issue by November 1989, a Regulatory Guide establishing standards ano criteria for determining what constitutes an effective maintenance program. This Regulatory Guide is being devriloped in parallel with the final rulemaking, i The Commission encourages the industry to develop standards ,
and acceptance criteria, if an acceptable industry standard is available in this time frame, the Commission will !
] consider endorsing the industry standard in the Regulatory i Guide. An industry commitment to develop a maintenance standard, consistent with the Commission's schedule to issue a final Regulatory Guide by November 1989, would be necessary during this public comment period. <
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- 6. The (c mission believes that the proposed esintenance rule
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should be considered under 10 CFR 50.109 (a) (4) of the backfit rule which would exempt the maintenance rule from backfit requirements based on the precepts that effective maintenance is necessary to assure adequate oublic protection and that the proposed rule codifies and standardizes previously oxisting Commission requirements, both explicit and implicit, in plant technical specifications, licensee safety analysis reports, and 10 CFR 50, Appendix 8. The CoeM ssion requests public comment concerning the r.eed for a ba.kfit analysis for this rulemaking.
7.
The Ccamission believes that the inclusion of balance of plant !
(BOP) equicment in the proposed maintenance rule is necessary and proper. However, the Commission also recognizes that some licensee maintenance programs, as presently configured, apply to ;
structures, systems, and components that are, without question, irrelevant to protection of pt.blic health af.d safety from radiological hazards associated with the operation of the nuclear pewer plant. The Commission requests public comment tencerning what limitation, if any, should be placed on the ,
final esintenance rule to provide some licensee flexibility in l this regard.
S.
The Comission believes that individual worker accountability plays an importv.'. role in an effective maintenance program.
The Comission is, therefore, soliciting comments on the means for incorporating this consideration into a licensee's maintenanca prcgram.
9.
The Comission desires to establish criteria within the maintenance rule which would form the basis for determining when a maintenance program is fully effective and additional improvement is not warranted from a safety standpsint. Such criteria might be either quantitative or qualitative and coute 10
be baseo en specific measurable at. tributes. On overall plant performance, on program results, or on otter attributes. The Commission requests public comment concerring toe need for such criteria, the form of such criteria, and the criteria themselves, i
10.
Are performance indicators that are being used by industry, may be used in the future, or have been usud in the past, dppropriate Candidates as Quantit3tive melbures of maintenance I effectiveness? The Commission is particularly interested in
- .xcerience or analysis concerning inclicaters or the use of indicators of corponent reliability as maintenance performance indicators. '
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- 11. Should an industry-wide component failure reporting system, 1
e.g., NPR05, be used by all plants in order to support the ,
sharing of generic maintenance experience anc facilitate monitoring of maintenance effectiveness? t'
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- 12. Commissioner Roberts had the following vie =5: Icannotjcin the majority in supporting the preposed ruie.taking on '
l maintenance. In urder to have the benefit of the puolic's !
i ccaments, it has been my custom to agree t: publication of
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proposec ruiemakings. I cannot do so in this instance. I have asked one fencamental question. What are o trying to accomplish with this rule that cannot more effectively ana '
[{ innovatively be acccmplished without a regul& tion? I have not i received a satisfactory answer. I do not telieve the case has j
been trade that licensees do not hrve established maintenance j
programs. Most importantly to ee, there has been no demonstration that this rule would improve imple::entation cf l existing programs. Neither have I been provided with coepelling documentation on what the problem is and h:w, specifically, this I rule will fix it. On the contrary, the trends staff has
! provided show continued improvement in the maintenance area. '
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i The proposeo rule the Ccemission is now publishing fails to provide a basis for determining when a maintenance program is effective or wnen improvements are "appropriate." We are even i delaying publication of the accompanying Regulatory Guide until !
the final rule. Without being afforded the oppcrtunity to review this inolementation document, the Ccmmissien is lef t in the position of 1pproving a specious rule, it is no wonder that
, this rulemaking wculd elicit such *idespread opposition. The public is being askea to comment on a rule of form but no substance. I believe it would be core productive to delay issuance of this proposed rule until the c;raf t regulatry guide is available for ce=(nt, Only then can we receive ceaningful ,
comments on the rulemaking package.
4 I am concerneo that this rule gces beyond our autnority. ! [
cannot agree with a rule that v 4 ' have tne NRC regulating maintenance on all systems, structures and components regardless ,
of whether they have a nexus to radiological safety or not. ! .
sm troubled by the attitude demonstrated when we request public !
, comments on what limitations, if any, should be placed on the final rule to accress structures, systems and ccmponents that l sre "without cuestion irrelevant (my derhasis) to the protection of public 1:etith ano safety." Inis clearly abdicates cur
! responsibility to show that a regulation is needeo. We must ask ourselves: ere we proceeding with this rulemaking for the sake of the o i t.'el f ? As attested to by the cases where the Commi 4 cr. ited iicensees, the NOC already has the tuthority to i enforce cceliance i.* thc maintti.ance area.
The argeers advanced by both the staf f and the Comission in trying to comply with the requirements of the backfit rule have played a significant role in my decision not to support this propised rulemaking. The staff argument for the rule's compliance with 50.109 has been made on the basis of cost. The
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staff states that the backfit analysis shows that " .. the rule sill provide a substantial increase in the protection of the public health and safety without any additional cost." I am skeptical of the assumptions made in the backfit and regulatory analysis and request comments on both these documents. I also request comments on the views of the ACRS. They state that "...
there are characteristics of regulations, and especially the way in which they are typically enforced, that lead us to believe that, under a rule, a move toward uniformity would occur, and I this is likely to decrease the effectiveness of some of the better existing programs." I sha,e their concern that the existence of this rule could make things worse and diminish l rather than enhance the protection of the public.
Regarding "adequate protection," the Commission appears to be i
saying that since effective maintenance is necessary to maintain adequate protection, this rule should be excepted under 50.109(a)(4 This exemption would pronibit staff from taking imolementation cost into consideration. However, it would require that a documented i evaluation be prepared for public comment. Therefore, my oppositior to the exception is not to the exception itself but to the precedential nature of the use of the adequate protection argument.
Let me state that I too strongly believe that effective maintenance is necessary to assure that nuclear power plants are safe and to provide adequate protection to the public. Ialsobelieve,justas strongly, that this rule is not necessary to provide that protectior and that as the ACRS noted it may well have the opposite effect. I believe that we cannot afford to be careless about the use of the "adequate protection" argument for exception to the backfit rule.
The Commission is in litigation about this very issue. The Commission addressed this point in detail under the heading "Adequate Protection" in the Response to Commena on the final 10 CFR Part 50 Revision of Backfit Process for Power Reactors. Let us remember that there had been concerns that in dealing with the 13
1 backfit rule, the Commission wculd use the phrase "adequate
- protection" arbitrarily. The Commission could unwittingly be giving credence to that view.
Additionally, it seems to me that the Commission position on adequate protection is internally inconsistent. The Commission needs to recognize that when it states that this rule is needed to maintain adequate protection, it is saying that the current operating plants now pose undue risk to the public which we are presently tolerating. IfIbelievedthat.Iwouldsuggett(as s I'm sure would the rest of the Commission) that this rule become immeaiately effective. This is clearly not the case. As the Commission in the very same comment shows, "... the proposed rulecodifiesandstandardizespreviouslyexistino(myemphasis)
Commission requirements, both explicit and implicit, in plant technical specificati::ns, licensee safety analysis reports, and 10 CFR 50, Appendix B." It seems to me that the Commission can't have it both ways.
I request comments on my views.
IMPACT Although the Commission believes that this prnnosed rule is by virtue of 10 CFR 50.109(a) (4) not subject to the requirewnt for a backfit finding and analysis, it has nevertheless performed an analysis of ccst and other backfit factors as an alternative ground for proceeding with the proposed rule and to facilitate public comment on the backfit issue.
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The economic impact of the proposed requirement on licensees should i be negligible. The accompanying draft regulatory analysis shows that, although initial financial investments will be required by some licensees to establish a systematic and comprehensive maintenance program, the savings due to decreased corrective maintenance costs and increased plant availability should outweigh the investment costs. The Commission 14
l requests cooperation of informed sources in ordar to develop further details and verification of this analysis.
FINDING OF N0 SIGNIFICANT ENVIRONMENTAL IMPACT: AVAILABILITY The Commission has determined under *.he National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Subpart A of 10CFRPart51,thisruie,ifadopted,wouldnotbeamajorFederalaction significant',y affecting the quality of the human environment and; therefnre, i an environmental impact statement is not required.
i The proposed acti::n is directed to preserve and promptly restore ;
operability, reliability, and availability of, or to prevent the failure ;
of, plant structures, systems, and components whose failure could threaten j the health and safety of the public. Since the proposed action is I directed to improving the maintenance of plant systems, components and '
structures and does not require any mocification of the plant, it will not
- af fect the quality of the human environment.
The environmental assessment and finding of no significant impact on which this determination is based are available for inspection at the NRC Public Document Room 2120 L Street, Lower level, N.W., Washington, D.C. !
Single copies of the environmental assessment and finding of no significant impact are available from Moni Dey, Office of Nuclear Regulatory Research, Telephone: (301)492-3730, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.
PAPERWORK REDUCTION ACT STATEMENT
- i This proposed rule amends recorokeeping requirements that are subject !
to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.) This -ule has been submitted to the Office of Management an'i Budgst for review and approval of the paperwork requirements.
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Public reporting burden for this recordkeeping of information is estimated to average 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> per plant per year including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this bute.en, to the Records and Reports Management Branch, Division of Information Support Services /lRM, Office of Administration and Resources Management, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555; and to the Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, D.C. 20503.
REGULATORY ANALYSIS The Commission has prepared a draft regulatory analysis on this proposed regulation. The analysis examines the costs and benefits of the alternatives considered by the Contnission. The draf t analysis is available for inspection in the NRC Public Document Room, 2120 L St. , N.W.
Washington, D.C. Single copies of the draf t analysis may be obtained from Moni Dey, U.S. Nuclear Regulatory Commission, Washington, 0.C. 20555, (301) 492-3730.
The Commission requests public cumment on the draf t regulatory analysis. Comments on the draft analysis ', e be submitted to the NRC as indicated under the ADDRESSES heading.
BACKFIT ANALYSIS As noted above, the Commission has completed a backfit analysis for the proposed rule. The Commission has determined, based on this analysis, that backfitting to comply with the requirements of this proposed rule will proviae a substantial increase in protection to public health and safety without any additional costs. The backfit analysis on which this j determination is based is as follows:
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Analysis and Cocumentation for the Procosition that the Proposed Rule Satisfies the "Adecuate Protection" Exception in 10 CFR 50.109(a)(4);
Analysis and Determination That the Rulemaking to Amend 10 CFR 50 Concerning fiaintenance Comolies with Backfit Rule 10 CFR 50.109 In Any Event While the Commission's existing regulations contain several provisions which, either implicitly or explicitly, address the need for effective maintenance, they do not explicitly address the requirements of an effective maintenance program in any easily understood and comprehensive fashion. The Commission believes that safety can and must be enhanced by improving the ef fectiveness of maintenance programs throughout the nuclear industry. The proposed rule requires nuclear power plant maintenance programs to have a set of functions and activities which the Commission believes are essential for a comprehensive and effective program.
The findings and conclusions of the Commission's assessment of the effectfveness of plant maintenance programs can be found in tiVREG-1212, "Status of !!aintenance in the U.S. Iluclear Power Industry." The study showed weakr. esses at plants in a number of areas of maintenanct which the Commission believes is critical for an overall effective program.
Further, analysis of operational events has shown that, in some cases, nuclear power plant equipment is not being maintained with a high degree of reliability that the equipment will perform its intended function when required. The Commission believes that effective maintenance is necessary for adequate protection. The objective of the proposed rule is to require improvements for those plants that are poorly maintained, and also to prevent the declining performance of plants that are well-maintained. The proposed rule, by addressing in an easily understood way the requirement that there be an effective maintenance program, would advance the goal of having a comprehensive set of regulations which define what is needed for adequate protection and; therefore, satisfies the "Adequate Protection" Exception in 10 CFR 50.109(a)(4).
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In addition, the Commission has conducted an ar.alysis and determined that the proposed maintenance rule complies with section (3) of the backfit rule, 10 CFR 50.109. The benefit of improvements in maintenance has been estimated to be in the order.of 250,000 person-rem for the lifetirne of all nuclear power plants. Common sense also suggests that a well-maintained plant poses less risk than one poorly maintained. The proposed rule will help ensure a satisfactory level of performance for maintenance programs by specifying those activitier, and practices which, through experience, have been shown to be key elements of effective mainter.ance programs, and should result in a substantial enhancement of public health and safety.
J Inprovements in meintenance serve to meet dual objectives: (1) enhance safety; and also (2) increase plant availability and capacity factor. Therefore, it has been estimated that enhancenent in safety as a result of improved maintenance mty be accomplished without any additional costs, due to cost savings from reduced plant downtire, further, a proactive and well-planned maintenance program decreases costs of corrective and repeat maintenance.
The following discussion presents the surrary of the backfit analysis, further details may be found in the Regulatory Analysis for the proposed rule.
Analysis of i 50.109(c) factors 1
- 1. Statement of the specific objectives that the backfit is designed to achieve.
The purpose of the maintenance rule is to improve maintenance i
effectiveness, and thereby enhance overall safety, by establishing
- basic requirements for plant maintenance programs. In establishing these requirements, the Comission intends to consider the 1
industry-wide efforts that have already been initiated.
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,-,----,mm.-r.. -- - -regar---- - --.-, - n,
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i The c%iectives of the maintenance r'Je are as follows:
'.1 ) io (cfine NRC's exper stions for plant maintenance; and (2) to irr. prove licensee maintenance programs by requiring the effective conduct of a set of functions and activities.
With implementation of the rule, it is expected that the current wide variat. ion in maintenance performance will be reduced so that the performance of plants that lag benind the industry as a whole will be crought up to the level of performance of the majority of the induvtfy. Second, the overall average level of industry's performance should also improve.
An important part of the structure of the rule is to achieve improved maintenance performance in a way that allows licensees the flexibility to determine the details of their individual maintenance program so that plant-specific factors can be taken into account.
This flexible approach will enhance both safety and cost-effectiveness, compared to a rigid and prescriptive rulemaking approach.
- 2. General descriptian of the activity required by the licensee or applicant in order to complete the backfit.
- The licensees will be required to have a documented and effective maintenance program which shall include the following activities
(1) Technology in the areas of:
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(i) Corrective maintenance,
) (ii) Preventive maintenance, j (iii) Predictive maintenance, and (iv) Maintenance Surveillance; 19
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(2) Engineering in support of maintenance; (3) Quality assurance and quality control of maintenance activities;
, (4) Incorporation of plant modifications into the maintenance program; (5) Equipment history and trending; 2
(6) Maintenance record keeping; i
(7) Management of parts, tools, and facilities; (d) Maintenance procedures; I L
l (9) Post-Maintenance testing and return-to-service activities; 4
(10) Measures of overall maintenance prograw effectivenass; (11) Maintenance management and organization in the areas of:
(i) Planning, (ii) Scheduling,
{ (iii) Staffing, '
(iv) Shift coverage, and (v) Resource allocation; ;
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(12) Control of contracted maintenance services; !
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(13) Radiological exposure control (including ALARA) during maintenance activities; I
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(14)Maintenancepersonnelqualificationandtraining; (15) Internal communications between the maintenance organization and plant operations and support groups; (16)Communicationsbetweenplantandcorporatemanagementand the maintenance organization; and (17)Considerationofmaintenancerecommendationsorrequirements of individual vendors.
Criteria for acceptability of the conduct of the above activities will be provided in the proposed Maintenance Standard or Regulatory Guide.
- 3. Potential change in the risk to the public from the accidental offsite release of radioactive material.
Implementation of the proposed maintenance rule will result in an estimated total risk reduction to the public ranging from 50,000 to 500,000 person-rem with a point estimate of about 250,000 person-rem.
- 4. Potential impact on radiological egosure of facility employees.
Alargefraction(twothirdstothreefourths)oftheoccupational radiation exposure incurred at nuclear power plants is associated with maintenance, on the order of 300 person rem per reactor year in 1987. Improvements in maintenance programs can affect collective occupational exposures both positively and negatively. Increases in maintenance activity due to expanded preventive maintenance or more aggressivecorrectivemaintenance(toreducebacklogs,forexample) will tend to increase exposure, and productivity and reductions in the amount of rework will tend to reduce exposures. The net effect of thase positive and negatlve trends is believed to be beneficial, 21
but small compared to the other costs and benefits of improved maintenance.
- 5. Installation and continuing costs associated with backfit, including the cost of facility downtime or the cost of construction delay.
For 100 operating reactors, the total estimated cost associated with the proposed maintenance rule is -$198 million. The minus sign denotes a cost savings. This estimate breaks down as follows:
Industry Cost Element Millions of 1988 Dollars Maintenance Plan 4 Recordkeeping and Reporting 12.3 Maintenance Standard 2.8 Reg. Guide Workshops 0.4 Implement Improvements (at some plants)
Preventive Maintenance 1500 Maint. -Ops. Coord. 2.1 Maint. Info. System 150 Procedures 14 Increased Staffing 50 to Reduce Overtime Reduced Risks of Onsite Property Damage -33 Cost Savings Due to Improved Availability and Reduced Corrective Maintenance -1900 Total Net Industry Costs -198 NOTES: 1. Negative signs denote cost savings.
- 2. Values in table are rounded.
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)
6.
The potential safety impact of changes in plant or operational complexity, including the relationship to proposed and existing regulatory requirements.
The proposed rule would require certain elements in a plant maintenance program and should not add to plant or operational
' complexity. Improved maintenance should result in a decrease of challenges to safety systems and forced outages, and therefore, should decrease the complexity of operations.
The proposed maintenance rule is related to the following existing regulatory requirements:
(1) Surveillance requirements for safety systems is required in the technical specifications. These requirements are not duplicated for the proposed maintenance rule.
(2) In-service inspection requirements are covered under 10 CFR 50.55a, Codes and Standardt. These requirements of a preventive maintenance program are not duplicated under the proposed maintenance rule.
(S) Criterion 1, Appendix A,10 CFR 50, concerning General Design Criteria (GDC), requires that a quality assurance (QA) program be established and implehtented in order to provido adequate assurance that Nuclear Power Plant (NPP) structures, systems, ana components will satisfactorily perform their safety functions. Appendix B of 10 CFR 50 establishes QA requirements for the design, construction, and operation of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. Regulatory Guide 1.33 has been promulgated to describe acceptable methods for complying 23
with the provisions of these appendices of 10 CFR 50 for the operational phase of NPPs.
These requirements are directed towards maintaining a quality assurance pregram and do not explic.itly address maintenance as defined in the proposed rule. The proposed Maintenance Standard and Rcgulatory Guide will directly address the maintenance activities in the preposed rule.
7.
The estimated resource burden on the NRC associated eith the backfit and the availability of such resources.
The estimated total cost for NRC review of industry subsittals required by the proposed maintenance rule is $400,000 based on the need for developing a Regulatory Guide to provide the basis for review of an industry-developed Maintenance Standard or to ,
provide guioance on implementation of the rule if a Maintenance Stanaard is not developed. Individual plant maintenance programt will be subject to the ongoing Inspection process but ,
would not be required to he submitted so the NRC for review and approval.
- 8. The potential impac of difference in facility type design, or age on the relevancy and practicality of the backfit.
The proposed maintenance rule establishes generic requirements applicable to all types of facilities and designs, regardless of 4
their age.
- 9. Whether the backfit is Interim or final and, if interim, the justification for imposing the backfit on an interim ' asis.
u The
, proposed maintenance rule would be a final requirement.
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REGULATORY FLEX 1BILITY CERTIFICATION in cccordance with the Regulatory Flexibility Act of 1980, 5 U.S.C.
605(b), the Commission hereby certifies that this proposed regulation will not, if promulgated, have a significant economic impact on a substantial number of small entitics. This proposed regulation affects licensees that own and operate nuclear utilization f acilities licensed under Sactions 103 and 104 of the Atomic Energy Act of 1954 as amended. These licensees do not fall within the definition of small business set forth in Section 3 of the Small Business Act, 15 U.S.C. 532, or within the Small Business Size Standards set forth in 13 CFR Part 121.
PART 50 - DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILIT
- 1. The Authority citation for Part 50 continues to read as follows:
Authority: Se cs ., 102, 103. 104, 105, 161, 182, 183, 186, 189, 68 Stat. 936, 937, 938, 948, 953, 954, 955, 956, as amended, Secs. 234, 83 Stat.1244, as amended (42 U.S.C. 2132, 2133, 2134, 2135, 2201, 2232, 2233, 2216, 2239, 2282); Secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended 1244, 1246 (42 U.S.C. 5841, 5842, 5846).
Section 50.7 alto issued under Pub. L.: 95-601, Sec. 10, 92 Stat.
2951 (42 U.S.C. 5851). Sections 50.10 also issued ur. der Secs. 101, 185, 68, Stat. 236, 955, as amended (42 U.S.C. 4332). Sections 50.23, 50.35, 50.55 and 5056 also issued under Sec.135, 68, Statl.
955 (42 U.S.C. 2235). Sections 50.33a, 50.55a, and Appendix Q also issued under Sec.102, Publ. I,.91-190, 83 Stat. 853 (42 U.S.C.
4332). Sections 50.34 and 5054 also issued under Sec. 204, 88' Stat.
124S (42 U.S.C, 5844). Sections 50.58, 5091, and 50.92 also issued undcr hbl. 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 50.80-5u.C' also issued under Sec.184, 68 Stat. 954, as amended (42 25
c.
U.S.C. 2234). Section 50.103 also issued under Sec. 108, 68 Stat.
939, as amended (42 U.S.C. 2237).
For the purpores of Sec. 223, 68 Stat. 958, as amended (42 U.S.C.
2273),il50.10(a),(b),and(c) 50.44, 50.46, 50.48 and 50.54 and 50.54(a) are issued under Sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); 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 50.9, 50.55(e), 50.59(b), 50.70, 50.71, 50.72, 50.73 and 50.78 are issued under Sec. 1610, 68 Stat. 950, as amendeo (42 U.S.C. 2201(o)).
2, A new i 50.65 is added to read as follows:
i 50.65 Requirements to ensure the effectiveness g maintenance pregrams for nuclear power plants.
(a) Applicability. The requirements of this section apply to all nuclear power reactors licensed under i 50.21 b or 50.22.
(b) Definitions. For the purpose of this section, the Comission defines maintenance as the aggregate of those planned and systematic actions required to preserve and promptly restore operability, reliability, and availability of, or to prevent the failure of, plant structures, systems, and components. The Comission intends the scope of the rule to cover all systems, structures and components, including those in the Balance-of-Plant. Maintenance includes not only activities traditionally associated with identifying and correcting actual or potential degraded conditions, i.e., repair, surveillance, '
diagnostic examinations, and preventive reasures; but extends to all supporting functions for the conduct of these activities.
Maintenance includes the following activities:
26
(1) Technology in the areas of:
(i) Corrective maintenance, (ii) Preventive e,sintenance, (iii) Predictive matittenance, and (iv) Maintenance Surveillance; I
(2) Engineering in support of maintenance; (3) Cuality assurance and quality control of maintenance activities; i
(4) Incorporation of plant modifications into the maintenance program; ,
(5) Equipment history and trending; II (6) Maintenance record keeping; -
(7) Management of p;rts, tools, and facilities; (8) Maintenance procedures; (9) Post-Maintenance testing and return-to-service activitiest t (10) Measures of overall naintenance program effectiveness; i
1 (11) Maintenance management and organization in the areas of:
(i) Planning, (ii) Scheduling, 27
(iii) Staffing, (iv) Shift coverage, and (v) Resource allocation; (12) Control of contracted maintenance services; (13) Radiological exposure control (including ALARA) during maintenar.ce activities; i
(14) Maintenance personnel qualification and training; t
(15) Internal communications between the maintenance organization and plant operations and support groups; (16) Comunications between plant and corporate management and the maintenance organization; and (17' Consideration of maintenance recommendations or requirements of individual vendors.
2 (c) Reouirements. Each holder of an operating license subject to this section shall (1) establish, implement, and maint6fn an effective and documented maintenance progran that addresses elements and activities in paragraph (b) of this section, and (2) regularly assess the effectiveness of this maintenancu program and, based upcn this assesscent, make improvements, o appropriate.
(d) Imple entation. By (insert a date 2 years after the effective date of the amendment) each licensee shall certify, by letter to the Director of the Office of Nuclear Reactor Regulation, that a comprehensive documented maintenance program is being maintained and ieplemented, which addresses all elements and activities in p4ragraph (b) of this secticn including measures to conitor the 28
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effectiveness of the maintenance program and to improve the program whtre appropriate, in addition, each licensee shall develop [ insert a date 3 months af ter the effective date of the amendment] a timely and expeditious plan and schedule (including Key Milestones) for meeting the requirements of this section.
Dated at Rockville, Maryland this 11 Jay of c/edw,1988 for the Nuclear Regulatory Commission.
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}- =
amuelJ.Chilh, 0- A 25 '
Secretary of the Commission.
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