ML20236E455
| ML20236E455 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1989 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 8905170115 | |
| Download: ML20236E455 (1) | |
Text
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, April:26, 1989 WLEASED TOWE POR
$ MEMORANDUM FOR:
- Victor Stello, Jr.
Executive' Director for Operations
~
FROM:
, Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
. MINUTES OF CRG'R MEETING NUMBER 161 The Committee.to Review Generic Requirements (CRGR) met on Wednesday, LApril. 12,:1989-from 1:00 p.m.-5:00 p.m. and Thursday, April 13,.1989 from l
2:00 p.m.-4:00 p.m.
A list of attendees for this meeting is attached (Enclosure 1).
The item addressed at this meeting was the final rulemaking'en maintenance of
>r nuclear power plants and draft regulatory guide presented by B. Morris (RES),
xT. King (RES) and M. Dey (RES).
The Committee recommended in favor'of-forwarding the rule and regulatory guide to the Commission subject to resolution of substantial comments and recommendations made by the' Committee.
This matter'is discussed in Enclosure 2.
In-accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure ~of ~CRGR' Reviews," a written response is required from the cognizant office.to report agreement or disagreement'with'the CRGR recommendations in these' minutes. 'The response ~, which is required within five working. days after receipt ~of these minutes, is to be forwarded to the CRGR Chairman and if.there
Questions concerning these minutes should be. referred to Jim'Conran (492-9855).
crwnel signed Bb F. L Jorden Edward L.' Jordan, Chairman Committee to Review Generic Requirements
Enclosures:
_D.i stri bution: w/o enclosures As stated Central File CRGR CF (w/ enc.)
PDR (NRC/CRGR)
CRGR SF (w/ enc.)
cc w/ enclosures.:
B. Morris M. Taylor (w/ enc.)
Commission (5)
T. King E. Jordan (w/ enc.)
SECY M Dey J. Heltemes (w/ enc.)
J. Lieberman S. Treby J. Conran (w/ enc.)
P. Norry W. Little eCNSakenas^{w/ enc;)
Regional Administrators M. Lesar CRGR Members-P. Kadambi (w/ enc.)
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' ATTENDANCE LIST CRGR MEETING NO. 161 April 12-13, 1989 CRGR MEMBERS s
E.' Jordan C. Paperiello R. Bosnak (for D. Ross)
J. Sniezek S..Treby (for J. Goldberg)
NRC STAFF J. Heltemes J. Conran.
C. Sakenas B. Morris L. Norrholm*-
A. Gody-M. Dey T. King J. Roe K. Hart L. Plisco B. Richter-G. Mizuno R. Frahm J. Rosenthal*
E. Igne*
M. Taylor
- C. Ader*
- Not present at April 13 meeting.
n,
- s e to-the Minutes of CRGR Meeting No. 161 Proposed Final Rule and Draft Implementing Reg. Guidu on Maintenance April 12-13, 1989 TOPIC B. Morris (RES), T. King (RES), and M. Dey (RES) presented for CRGR review a proposed final rule. (10 CFR 50.65) and a draft implementing Regulatory Guide on Maintenance _of Nuclear Power Plants.
Copics of briefing slides used by the staff.to guide their presentations and the discussions with the Committee at this~ meeting are enclosed (Attachment 1).
BACKGROUND-
.1.
The package. submitted initially by the staff for CRGR review in this matter was transmitted by memorandum dated April 6, 1989, E. S. Beckjord to E. L. Jordan; that package contained the following:
Predecisional Commission Action Paper (undated), " Amendment to 10 a.
CFR 50 Related.to Maintenance of Nuclear Power Plants," and attachments as follows:
i.
Enclosure A - Proposed Federal Register Notice (containing proposed rule, summary and evaluation of public comments, and backfit analysis) ii.
Enclosure B - Draft Regulatory Guide (undated), " Requirements for Maintenance Programs of Nuclear Power Plants" iii. Enclosure C
" Key Milestones for Implementation of Final Rule" iv.
Enclosure D - Regulatory Analysis (undated) v.
Enclosure E - Environmental Assessment 2.-
Additional background documents were provided to CRGR members by the CRGR staff for their consideration in connection with the-Committee's review of this issue, as follows:
a.
Letter dated February 27,.1989 from the Nuclear Utility Backfitting
.and Reform Group providing comments on the draft Maintenance Rule.
b.
l.etter dated February 27, 1989 from Bishop, Cook, Purcell and Reynolds on behalf of nine individual utilities protiding comments on the draft Maintenance Rule.
-c.
Letter dated February 24, 1989 from the Tennessee Valley Authority providing comments on the draft Maintenance Rule.
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Draft' responses dated March 9, 1989 by Pacific Northwest Laboratory to public comments.on the draft Maintenance Rule Regulatory Analysis.
e.
Letter dated February 27,1989 from the Nuclear Management and.
Resources Council providing extensive comments on the draft Maintenance Rule.
3.
At Meeting No. 161, RES provided directly to CRGR members the following
. documents:
Updated versions of Items 1.a.i through 1.a.v above, reflecting NRR a.
and OGC comments on the earlier versions.
b.
- ACRS letter dated' April 11, 1989 entitled " Proposed Final Rulemaking Related to Maintenance of Nuclear Power Plants."
4.
At Meeting No. 161, J. Rosenthal (AE0D) provided CRGR members copies of Special Study Report AE0D/S901, dated February 1989, " Maintenance Problems at' Nuclear Power Plants," and a briefing summarizing some of the principal results of that study as pertinent to the Committee's consideration of the proposed Maintenance Rule and implementing Reg.
Guide.
CONCLUSIONS / RECOMMENDATIONS As a result of their review of this matter, including th'e discussions with the staff at this meeting, the Committee recommended in favor of issuing the
. proposed rule as effective, and the proposed Reg. Guide for public comment, subject to the comments and recommendations below:
A.
GENERAL 1.
The Committee agreed with the (revised) staff approach in the final rule package of not invoking the " adequate protection" provision of
~
the backfit rule as a basis for the proposed backfits, but providing instead justification (under 50.109 a.3) for the propcsed rule and Reg. Guide as backfit measures that provide substantial safety benefits which justify the costs of implementation.
The Committee did not agree, however, in view of the large uncertainties involved, that the quantitative analyses of costs and benefits presented in the package provide the necessary justification for the proposed actions.
Rather, the Committee concluded that the quantitative analyses indicate that associated costs and benefits balance out each other.
The Committee considered the qualitative arguments offered in support of the rule, in the review package and in the discussions at this meeting, to be the determining factors in recommending'g in favor of approval of the proposed rule, to wit:
a.
Maintenance problems continue to be a major contributor to operating events.
b.
There is a lack of understanding of NRC's authority with respect to B0P structures, systems and components with safety significance.
(See further discussion in A.3 below.)
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~ There is a.need for regulatory expression on maintenance to
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assure continued emphasis and prevent future lapses.
2.
The Committee felt that the Reg. Guide should be modified to emphasiza effective-maintenance performance,'and not maintenance program content.
The' Committee recommended a number of specific revisions to the draft Reg. Guide consistent'with this general recommendation for improvement.
(See below for further details.)
3.
The' Committee disagreed strongly with industry comments submitted in response to the draft rule that (a) appeared tc question.NRC's authority to regulate balance-of plant (BGP) structures, systems'and:
l components (SSCs), and/or (b) suggested that the proposed rule extends the reach of existing regulations by addressing maintenance of B0P:SSCs.
It was noted that the regulation specifying FSAR content (i.e., 50.34 b.6.iv) requires that the FSAR include a description ~and safety analysis of a plant's structures, systems and components and the facility as a whole (not just the safety-related portions), and.further' requires explicit information concerning facility operation, including plans for the conduct of maintenance.
This explicit requirement,-taken together with other approved 4
implementing guidance for licensees-(e.g., Reg. Guide 1.70,
" Standard Format and Content of Safety Analysis Reports...", and numerous other Reg. Guides and Standard Review Plan sections that-address specific B0P SSCs) have clearly established the B0P area generally, and many BOP SSCs specifically, within NRC's legitimate regulatory purview.
It was also noted, however, that in practice NRC has not previously chosen.to exercise its established regulatory prerogative by focusing on or emphasizing review and inspection of B0P maintenance programs; this may be an underlying reason for the misperception evident in the industry comments, alluded to above.
A factor compounding the confusion on this point was that the scope in the draft rule included all B0P SSCs.
The Committee agrees that the scope in the final rule (i.e., all SSCs within the current licensing basis of a plant whose failure could significantly affect the safety or security of the facility) is more appropriate and properly focused.
The revised scope should resolve many of the comments received in response to the draft rule.
Although, as noted above, the proposed rule and Reg.
Guide do not expand fundamentally the scope of the existing reg-ulations and do not extend NRC's established regulatory purview, they do involve additional requirements and new staff positions within the-established scope of regulations.
These need to be acknowledged as backfits.
The package should be revised to reflect the preceding discussion.
A number of specific changes'to the wording of the package that are consistent with this general recommendation by the Committee were discussed with the staff at this meeting.
(See Section B below for j
further details.)
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B.
SPECIFIC RECOMMENDED REVISIONS L
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NOTEIThe following is keyed to the-April 6, 1989 version.of the review package documents (Background Items 1.a.i thru 1.a.v) which were trans-mitted-officially'to CRGR in advance of Meeting No. 161.
1.
Commission' Paper a.
At page 1, change.the second line from the bottom to read as follows:
"... codify,' standardize, and better define'and extend, previously existing..."-
t b.
At'page 2, in the third line, insert a period after
".. 10 CFR Part 73.", and add the following:
" Requirements for structures, systems, and components.in the balance-of-p1 ant-(B0P) whose failure could significantly affect plant safety or security are included.
These actions add to the. number of explicit requirements contained in the-regulations, but do not expand fundamentally the estab-lished scope of current regulations as a whole, or the established purview of NRC regulatory authority."
c.
At page 2, change the first sentence'of the third paragraph to read as follows:
"The Regulatory Guide provides guidance that maintenance programs include..."
2.
Federal Register Notice a.
At page'1, change the first sentence under "
SUMMARY
" to read as follows:
"The Commission is amending its regulations to require... licensees to implement.and maintain a maintenance program in order to..."
b.
At page 3, delete the words " develop and..." from the eleventh
'line under DESCRIPTION.
c.
At page 3, change the sentence beginning at the bottom of the page and extending onto page 4 to read'as follows:
"The proposed rule does not expand fundamentally the established scope of the regulations.as a whole with regard to the design, construction, or operation of a nuclear facility."
1 N.<;
Also change.the'following sentence as follows:
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"It does impose additional requirements within that established scope by explicitly defining..."
d.
At page 4, add.the following words at the end of the first sentence of the first full paragraph:
"...so it is appropriate that the Commission clearly express this in its' regulations."
Then delete the second sentence, and replace with an expanded discussion of the need for the proposed maintenance rule in terms of the safety importance of proper maintenance (including significantly' improved maintenance of BOP SSCs), and to clarify-that the established scope of existing regulations as a whole.
already, includes the 80P (because of the safety significance of-B0P SSCs.in.the current licensing basis for the: operating reactors.
At page 5, delete the second sentence under Implementation and e.
Compliance; and revise the following wording at the bottom of the page to convey more clearly the intended emphasis on effective performance of maintenance rather than programmatic aspects-(e.g., delete the words "... established, documented,..."
in subparagraph 1 at the bottom of page 5).
f.
At page 6,~in the fourth line from the top, place a period after the word action.
g.
At page 6, in.the third sentence under Maintenance Standard and Third Party Certification, replace the word " detailed" with the word " extensive."
h.
At page.7, the statement in subitem (2) of the middle paragraph that there has been no demonstration that the rule will increase safety, etc., should be rebutted explicitly in the Response to Comments section that follows.
i.
At page'10, in the last' sentence of the first paragraph, clarify by replacing the word " supported" with the word " preferred."
j.
At page 13, the suggestion by commentors on the draft rule that the proper approach to upgrading. maintenance would be to first issue a Reg. Guide, then a rule if still required should be responded to explicitly, as follows:
"The Commission believes it is.important to set forth explicit maintenance requirements in-the regulations prior to issuance of a Reg. Guide in order to...(here use the same language as in 2.d above).
k.
At page 18, the suggestion (in the third sentence on that page) by commentors on the draft rule that the proposed rule would require proper maintenance of components not required to be
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properly-installed should be explicitly responded to in the staff'.s Response to Comments.(e.g., by reference to appropriate sections of the existing regulations such as 50.34 (b),
50.34 (b)(6)(iv) and 50.34 (g)),;and other approved NRC guidance such as. Reg. Guide l.70 and the Standard Review Plan which already indicate / address the safety significance of B0P SSCs.
1.
At pages 21-22, in the staff's response to the comment regarding the lack of NRC criteria for a fully effective maintenance
. program, delete the. sentence that begins at the bottom of this page and continues at the top of page 22, and replace with the
.following sentence:
"However, as noted in the Reg Gui_de in Section 5.2.i and 5.2.iii, licensees are expected to identify and monitor their own maintenance performance indicators to assess for.their self assessment of maintenance performance."
At page~24, change the third. sentence in the staff's Response to m.
Comments on Question 10 to read as follows:
According to the Commission's definition, main-tenance includes activities traditionally assoc-iated with preventing, predicting, measuring,
'"E identifying, and correcting degraded conditions due to environment and service-over-time, and other causes; i.e., repair, surveillance, diag-nostic examinations, root cause analysis, and..."
n.
At page 28, in the staff's Response to Comments on Question 11, add the following sentence to the second paragraph on that page:
"It is not the Commission's intent to require ~
reporting to'and the use of the NPRDS, or to suggest expansion of the reportable scope of the NPRDS to cover the entire 80P."
o.
At pages 33-34, in the staff's. Response to Comments on Question 12:
- Move the sentence that begins with the worde "The existence of an imminent safety problem..." so that it follows immediately after the sentence that reads "That premise is incorrect.".
]
- Delete the last sentence on page 33.
)
- Following the first sentence at the top of page 34, insert a discussion that conforms with A.3, B.1.b, B.2.c, and B.2.d above with regard to NRC's established regulatory authority in the B0P.
3 1
. Delete the last sentence in the first paragraph on J
j page 34.
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p.
At page 41 (Backfit Analysis), delete the last sentence of the first paragraph on this psge.
q.
At page 44 (Backfit Analysis), the statement in the last sentence of the first paragraph indicating that the results of the staff.'s quantitative cost / benefit analyses support the proposed rule should be modified.
Those results do not unambiguously support the proposed action.
The wording here should be modified to indicate that the results of the quantitative analyses are "a wash"; that is, they so closely balance out and are subject to such uncertainty that they are not really useful in deciding the proposed course of action on the maintenance rule.
The overriding factors in recommending that the Commission adopt a maintenance rule are qualitative safety considerations...(see A.1 above).
(Also see A.3 above.)
At pages 49-50 (Backfit Analysis, Response to Item 7), replace r.
the sentence that begins at the bottom of page 49 and continues at the top of page 50, and the following sentence, with a sentence that reads as follows:
"NRC does not expect to allocate any additional resources for inspections."
l At page 52 (Proposed Rule), under Definitions, change the wording s.
to conform to that given in B.2.m above.
t.
At page 54 (Proposed Rule), under Scope, modify the wording to read as follows:
"The scope of the maintenance program shall include all SSCs included in the plant's current licensing basis as established by existing regulations and described in the plant's FSAR, as required by 10 CFR 50.34(b), whose failure could signifi-cantly affect the safety or security of the facility."
At page 54 (Proposed Rule), under Requirements, delete the words u.
" establish" and " documented".
At page 54 (Proposed Rule), under Implementation, replace the v.
word "can" with the word "shall" throughout.
3.
Draft Regulatory Guide At pge 1, under Introduction, modify the wording to conform to a.
that given in B.2.a above.
b.
At page 2, in the third line from the top of the page, delete the words "importance and".
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- At page 3, under Regulatory Position, change the first s'entence c.
of the last paragraph on the page to read as follows:
"A maintenance program shall be implemented as
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required by 10 CFR 50.65."
Also,. delete the word " documented" in the following sentence.
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. d.
At page 4, in the fourth line from the top of the page,:delece the words "be developed."
At page 6, under Establishment of Goals cnd Objectives, change
- e.
the wording of Section 3.(a) to conform to that in Section 2.(b) of the Proposed Rule (at page 52).
f.
At page 7, under Goals, note.that information available from plant-specific PRAs or from IPEs that indicate the contri-butions of SSCs'to overall plant risk may be utilized to i
' set the goals and objectives of maintenance.for those systems that deserve-special attention.
g.
At page 7, under Goals, after the second sentence in the second paragraph, insert a new sentence that reads as follows:
'"For'many.SSCs," goals may not be. required."
Also,' delete the last sentence of that paragraph.
h.'
At page 9, under Staffing, in the first line of that paragraph delete the words "and procedures."
i.
At page 10, under Engineering in Support of Maintenance, in the first sentence delete the words "...be an integral *part of and....".Also, change the fourth sentence to read as follows:
"The root cause of unplanned events should be investigated to determine if failure was caused by poor maintenance and to take appropriate corrective action."
Add.the words " Regulatory-requirements" at the beginning of the fifth sentence; and add a sentence to the end of the paragraph that reads as follows:
" Engineering and technical support should be avail-able to evaluate potential degradation mechanisms due to environment and service-over-time and to provide direction for timely mitigation of their effects."
j.
At page 11, under QA and QC..., in the second line of the first sentence change the wording to read "... commensurate with their safety and security significance."
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At.page-14, unde'r Predictive Maintenance,: change the. wording in
. the second line-- of.that paragraph.to read as follows:
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... analyze parameter / property and performance-characteristics? or -signatures as'sociated with..."
)
Also-change the ending of the second. sentence to read'as follows:
"...that indicate the need for. preventive mainten-ance prior to equipment failure."
m
'And change the last sentence to read as follows:
' tot causes should be determined,. if possible,:
and action taken and results. fed back into the entire program."
1.
At page 17,,under Feedback and Corrective Actions, add the following words.to the end of the first sentence:
"...as well as' resolution of identified deficien-cies of SSCs' commensurate with theirl safety and security significance."
At page 19,.under' Implementation, delete the last paragraph on m.-
this page..Also' delete subitems 1, 2, and 3'at the top of' the next page.
C. -
CONFORMING CHANGES
~ The staff;should review carefully the entire package to assure that conforming changes'are made.throughout the package (including the-additional " Attachment to Enclosure A" that was provided.to CRGR members
.in a. revised version'of.the review package distributed at Meeting No. 161) consistent with the specific changes recommended in the preceding.
All changes to the package should be closely coordinated with the CRGR staff before forwarding.the revised package to'the EDO and Commission for final consideration.
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- " BASIS AND' REGULATORY ANALYSIS FOR RULE AND REG;~GUIDELON MAINTENANCE" T. L. KING, RES 492-3765.
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- SUPPORTING BASIS FOR RULE'AND REG, GUIDE.
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0 JUSTIFIED ON THE. BASIS OF-ENHANCED SAFETY:
QUALITATIVE BASIS QUANTITATIVE BASIS (REGULATORY IMPACT ANALYSIS)
- 0 MANY-COMMENTS RECEIVED ON PREVIOUS REGULATORY-IMPACT ANALYSIS'
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RIA. REVISED' FACTORS'IN MANY COMMENTS RECEIVED.
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QUALITATIVE BASIS j
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MAINTENANCE HAS A DIRECT IMPACT ON PLANT SAFETY:
RELIABILITY OF SAFETY SYSTEMS CHALLENGE TO SAFETY SYSTEMS AND OPERATORS (B0P).
THEREFORE,.IT'IS REASONABLE AND PROPER FOR NRC TO REGULATE IN THE MAINTENANCE AREA IN A FASHION THAT WILL RESULT IN AN IMPROVEMENT IN SAFETY.
0.
THERE IS A VARIATION ACROSS THE INDUSTRY IN MAINTENANCE.
MAINTENANCE TEAM INSPECTION RESULTS TO DATE (FROM 19 SITES /28 PLANTS)' CONFIRM THIS VARIATION:
21% - GOOD
'74% - SATISFACTORY 5% - POOR i
THEREFORE, THE RULE WILL FACILITATE THE COMMISSION'S TAKING ACTION IN THE MAINTENANCE AREA TO ACHIEVE IMPROVEMENT.
0 OVER THE REMAINING LIFE OF THE PLANTS, A REGULATION WILL STABILIZE AND BETTER DEFINE REQUIREMENTS T0:
HELP ENSURE GOOD MAINTENANCE IS ACHIEVED AND SUSTAINED ACROSS THE INDUSTRY i
NELP ENSURE THE EFFECTS OF AGING ARE FACTORED INTO PLANT MAINTENANCE PROGRAMS 0
IT IS COST BENEFICIAL TO HAVE A GOOD MAINTENANCE PROGRAM (I.E. SOME PLANTS ARE ALREADY DOING IT).
3
l REGULATORY ANALYSIS OVERVIEW 0
OVERALL POSITIVE NET BENEFIT J
0 REDUCTION IN PUBLIC RISK 0
INDUSTRY COST' SAVINGS REDUCED DOWNTIME i
0
' INCREASED INDUSTRY COSTS, E.G.:
i PREVENTIVE MAINTENANCE l
RECORDINGKEEPING MAINTENANCE INDICATORS 0
RELATIVELY SMALL NRC COSTS 0
RELATIVELY SMALL CHANGE IN OCCUPATIONAL EXPOSURE l
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MAJOR CHANGES FROM DRAFT REGULATORY ANALYSIS' DRAFT
. REVISED' REGULATORY REGULATORY ANALYSIS ANALYSIS 0 COST ELEMENTS BASIS NUREG-1212 DRAFT REGULATORY GUIDE.
O NUMBER OF REACTORS'NEEDING NUREG-1212-MAINTENANCE TEAM
' IMPROVEMENT.
INSPECTIONS-1
" POOR" 20-30 6
" SATISFACTORY" 0
81
" GOOD" 80-90 23 0 DATA ON' SCRAMS, SAFETY 1985-1987 1988 SYSTEM FAILURES, CAPACITY FACTORS 0-PUBLIC COMMENTS CONSIDERED:.
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NUMARC SUGGESTED BASELINE PLANT RISK VALUE USED (100 REM /R-Y)
NUMARC SUGGESTED ADJUSTMENT-TO FAILURE DATA DUE TO MAINT. USED (50%)
NUMBER OF P00R' PLANTS ASSUMED CONSISTENT WITH NUMARC SUGGESTED VALVE (6-8) 5
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CHANGE IN' RISK CALCULATED USING'1988 DATA'ON:
UNPLANNED' SCRAMS WHILE CRITICAL' SAFETY SYSTEM FAILURES o
DATA USED T0' ESTIMATE IMPROVEMENT POSSIBLE IN GOING FROM
" POOR" AND " SATISFACTORY" PERFORMERS TO " GOOD" PERFORMERS-(NO RISK REDUCTION' ASSUMED FOR " GOOD" PLANTS)
-0CONEE PRA USED TO CALCULATE CHANGE IN RISKS:
' BASE CASE: RISK = " SATISFACTORY" PLANTS BASE CASE RISK-USED NUMARC SUGGESTED VALUE OF 100 PERSON-REM /R-Y (300 USED IN ANALYSIS FOR PROPOSED' RULE)-
DOUBLED AND HALVED SCRAM RATE AND SSF RATE TO REPRESENT " POOR" AND " GOOD" PLANTS, RESPECTIVELY.
r GAVE CREDIT FOR:
INDUSTRY INITIATIVES (50% OF IMPROVEMENT)
NOT ALL IMPROVEMENT DUE TO MAINTENANCE (50%)
ESTIMATED RISK REDUCTION = 50,000 PERSON-REM
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COST TO' INDUSTRY:
USED MTI. RESULTS TO IDENTIFY !<HERE IMPROVEMENTS NEED T0 BE'MADE USED ACTUAL' DATA, AS MUCH AS POSSIBLE, TO CALCULATE:
COST.(E.G., SALEM - PM PROGRAM)
COST ESTIMATES FOLLOW FORMAT OF' DRAFT R.G.
SOME BASE COST ASSUMED FOR ALL PLANTS (e 10 MILLION)
FOR MONITORING AND ASSESSMENT LARGER COSTS FOR " SATISFACTORY" AND " POOR" PLANTS TO ACHIEVE " GOOD" LEVEL l
50% REDUCTION IN COSTS (EXCEPT MONITORING) ASSUMED BECAUSE' INDUSTRY INITIATIVES WILL COST $ REGARDLESS OF RULE.
ESTIMATED COST TO INDUSTRY = 1,250 MILLION 7
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__RIA'(CbNTINUEDF COST SAVINGS'TO~ INDUSTRY 4
IMPROVEMENT.IN MAINTENANCE WILL IMPROVE PLANT PERFORMANCE RESULTING IN~ REDUCED DOWNTIME.
1988 CAPACITY FACTOR DATA USED TO ESTIMATE IMPROVEMENT POSSIBLE IN GOING FROM A " POOR" OR " SATISFACTORY" PLANT.
T0 A " GOOD" PLANT IMPROVEMENT ASSUMED IN CAPACITY FACTOR:
POOR PLANTS - 16%
SATISFACTORY PLANTS - 1%
CREDIT'GIVEN FOR' INDUSTRY INITIATIVES (50%)
ESTIMATED COST' SAVINGS TO INDUSTRY = l,350 MILLION 1
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. MAJOR AREAS'0F UNCERTAINTY:
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- 0' EFFECTl'0F IMPROVED MAINTENANCE ON RISK:
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-TRANSIENT FREQUENCY.
SAFETY SYSTEM UNAVAILABILITY
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0 COST: 0F ' MAINTENANCE EFFECTIVENESS INDICATOR
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EFFECT OF IMPROVED MAINTENANCE'ON CAPACITY. FACTOR u
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SUMMARY
'0F COSTS At'D BENEFITS
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PROPOSED RULE CRGR PKG
. MODIFIED
- PUBLIc RISK REDUCTION-250 M' 40'M 50 M.
L OCCUPATIONALERADIATION SMALL SMALL-SMALL l
EXPOSURE REDUCTION'
- INDUSTRY COSTS.
' 1,700 M-
-815 M
-1,250 M
' INDUSTRY COSTfSiVINGS l'900 M.
880 M
'1,350 M
. NRC COSTS SMALL SMALL SMALL NET BENEFIT 450 M 105 M
- 150 M
- USING' REVISED MTI RESULTS e -
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3 FINAL' MAINTENANCE RULE AND DRAFT REGULATORY-GUIDE o >
1 MONI DEY, TASK MANAGER 0FFICE OF NUCLEAR REGULATORY RESEARCH PRESENTED TO THE COMMITTEE'To REVIEW GENERIC REQUIREMENTS APRIL-12,--1989 i
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OUTLINE'0F BRIEFING I
0 ' ANALYSIS OF PUBLIC COMMENTS i
0 FINAL RULE O
REGULATORY GUIDE 0 'BACKFIT' ANALYSIS 4
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REGULATORY' BACKGROUND
- 1980 - 1985.
_ REVIEW 0F STATUS OF MAINTENANCE'IN U.S..
NUCLEAR POWER ~ INDUSTRY, NUREG-1212, n.
MARCH 1988 PollCY STATEMENT ON MAINTENANCE RULEMAKING INITIATED i
..PUBLIC: WORKSHOP ON RULEMAKING 1
JULY.1988
- NOVEMBER-1988 NOTICE OF' PROPOSED RULEMAKING (NPRM).
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NOTICE'0F PROPOSED-RULEMAKING-10
' MAINTENANCE-DEFINED TO INCLUDE' TRADITIONAL ACTIVITIES PLUS
' SUPPORT FUNCTIONS-
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'O SEVENTEEN ~ ACTIVITIES LISTED
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'REQUI'REMENTS:-
ESTABLISH, IMPLEMENT, At., MAINTAIN' PROGRAM ASSESS PROGRAM -EFFECTIVENESS AND EXECUTE CORRECTI5'E -
' ACTIONS.
- 0' SOL'IC'ITED COMMENTS.ON 12_ QUESTIONS INCLUDING:
MAINTENANCE STANDARD / THIRD PARTY CERTIFICATION O
_ IMPLEMENTATION:
3 MONTHS FOR PLAN AND SCHEDULE 1
l 2 YEARS FOR FULL IMPLEMENTATION l?
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'l PUBLIC COMMENTS COMMENTE11'
' PRIOR To-AFTER 02/27/89*-
02/27/89*
UTILITIES 19-37 INDUSTRIAL l GROUPS-3 1
- VENDORS 3
' FEDER.tl AGENCY 2'
STATE GROUPS / INDIVIDUALS-2 PUBLIC INTEREST GROUPS /INDIV.
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_3 36 44 FOR RULE 7
0 AGAINST RULE 29 44
- ALREADY EXTENDED PUBLIC COMMENT PERIOD FROM 01/28/89 To 02/27/89.
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- MAINTENANCE RULE PUBLIC COMMENT
SUMMARY
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- A.;
NO RULE l
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NO DEMONSTRATION.THAT RULE INCREASES SAFETY.
DIVERT INDUSTRY RESOURCES, MAY HAVE NEGATIVE IMPACT.
AUTHORITY ALREADY' EXIST TO IMPROVE.THE FEW POOR PERFORMERS.
INDICATORS'ALREADY: EXIST (SALP, NRC' INSPECTORS).
INDUSTRY HAS BEEN IMPROVING, PROGRAMS ALREADY EXIST.
B.
PROPOSED' RULE'IS UNBOUNDED NOLDEFINITIONLOF BOP.
PUBLIC CANNOT ASSESS IMPACT WITHOUT R.G.
NO DEFINITION OF 10CFR50.65(B) ACTIVITIES.
L C.-
REGULATORYLANALYSIS NUREG 1212 DATA OBSOLETE.
L INDUSTRY HAS IMPROVED FROM 1985 TO 1989.
.NRC COST ESTIMATES TOO LOW.
NRC RISK' REDUCTION TOO HIGH.
D.
- ADEQUATE PROTECTION BACKFIT ANALYSIS BOP REQUIREMENTS NEW, THEREF0 F. BACKFIT NEEDED.
NO' DEMONSTRATION PLANTS ARE BELOW ADEQUATE PROTECTION LEVEL.
INDUSTRY IS IMPROVING.
VERY FEW BAD / PROBLEM PLANTS (5% NOT 30%).
USE PRESENT REGULATORY AUTHORITY TO IMPROVE FEW BAD PLANTS.
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FINAL RULE 0
PUBLICATION OF FINAL RULE RECOMMENDED
'OS DEFINITION OF MAINTENANCE MODIFIED TO:
F THE-COMMISSION DEFINES MAINTENANCE AS THE AGGREGATE OF-THOSE PLANNED AND SYSTEMATIC ACTIONS REQUIRED.TO PREVENT THE DEGRADATION OR FAILURE OF, AND TO PROMPTLY RESTORE
'THE~ INTENDED FUNCTION OF, STRUCTURES, SYSTEMS, AND COMPONENTS."
0
. DESIGN MODIFICATIONS NOT INCLUDED 0
' REQUIREMENTS UNCHANGED:
NONPRESCRIPTIVE PROCESS APPROACH 0
SCOPE MODIFIED TO:
" MAINTENANCE PROGRAM SHALL INCLUDE ALL SSC'S WHOSE FAILURE COULD SIGNIFICANTLY IMPACT THE SAFETY AND SECURITY OF THE FACILITY."
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BASED ON PUBLIC WORKSHOP AND COMMENTS RECEIVED txt NPR, WE RECOMMEND:
THAT INDUSTRY CONTINUE INITIATIVES AND PROVIDE:
LEADERSHIP..
THE DEVELOPMENT'0F AN INDUSTRY-WIDE MAINTENANCE LSTANDARD.
THE ESTABLISHMENT OF A THIRD PARTY CERTIFICATION PROGRAM.
0 IMPLEMENTATION SECTION CHANGED TO INCLUDE TWO OPTIONS:
1.
INDIVIDUAL LICENSEE CERTIFICATION, 12.
-THIRD PARTY CERTIFICATION WITH MAINTENANCE STANDARD.
O REG. GUIDE DEVELOPED IN ABSENCE OF INDUSTRY COMMITMENT.
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- APPROACH / PURPOSE'0F REG, GUIDEn
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0l PROVIDE' BASIC.. GUIDANCE.AND CRITERIA FOR MAINTENANCE PROGRAM
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' ADOPT' PROCESS AP.PROACH ps 0:
, ALLOWS FLEX 1BILITY FOR SPECIFIC ACTIVITIES 0-MINIMAL IMPACT ON EXISTING GOOD MAINTENANCE PROGRAMS 0
ALLOWS.USE-OF INDUSTRY GUIDES AND PROGRAMS FOR DETAILS
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EFFECTIVE MAINTENANCE PROCES_S__
4 DEFINE OVERALL l
MAINTENANCE POLICY l
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DEVELOP MAINTENANCE OBJECTIVES t
1 r DERIVE REQUIRED SSC MAINTENANCE ACTIVITIES 1 P
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CONDUCT MAINTENANCE l EVALUATION, FEEDBACK &
4 MONITOREFFECTIVENESSl CORRECTIVE ACTIONS 10
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'CRTI_ERIA FOR ACCEPTABILITY i
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0 FOLLOWING ONGOING STEPS MUST BE ADEQUATELY. EXECUTED:-
j PROGRAM ESTABLISHED,-DOCUMENTED, AND IMPLEMENTED BASED ON SSC PERFORMANCE OB'JECTIVESJ PROGRAM EFFECTIVENESS MONITORED.AND DOCUMENTED; AND
. CORRECTIVE ACTIONS EXECUTED AND DOCUMENTED.
(0-COMPLIANCE WITH RULE' VERIFIED BY NRC AUDIT-AND INSPECTIONS f
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THE MAINTENANCE PROGRAM SHOULD COVER THOSE STRUCTURES, SYSTEMS, AND COMPONENTS (AND THEIR SUPPORTING SYSTEMS):
(A)
RELIED UPON FOR THE INTEGRITY OF THE REACTOR COOLANT PRESSURE B0UNDARY, SAFE SHUTDOWN CAPABILITY,-AND ACCIDENT PREVENTION AND MITIGATION; (B)
WHOSE FAILURE CAN CAUSE OR ADVERSELY AFFECT A TRANSIENT OR ACCIDENT THAT SIGNIFICANTLY CHALLENGES STRUCTURES, SYSTEMS, AND COMPONENTS RELIED UPON FOR THE INTEGRITY OF THE REACTOR COOLANT PRESSURE BOUNDARY, SAFE SHUTDOWN, OR MITIGATION;
'(C)
AND 0THER SSC'S THAT PROVIDE REASONABLE ASSURANCE THAT THE' FACILITY CAN BE OPERATED WITHOUT UNDUE RISK TO PUBLIC HEALTH AND SAFETY AND COMMON DEFENSE AND SECURITY (E.G., FIRE PROTECTION, SECURITY / SAFEGUARDS, EMERGENCY PREPAREDNESS, POSTACCIDENT MONITORING),
(D)' REQUIRED FOR THE PROTECTION OF THE OCCUPATIONAL HEALTH AND SAFETY OF WORKERS AT THE PLANT FROM HAZARDS ASSOCIATED WITH RADIOACTIVE MATERIALS.
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.,.. z.c ESTABLISHMENT OF GOALS AND OBJECTIVES
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GENERAL OBJECTIVE IS TO PREVENT THE FAILURE-OR DEGRADATION OF SSC'S COMMENSURATE'WITH SAFETY SIGNIFICANCE 0
HIERARCHICAL GOAlb AND OBJECTIVES BASED ON EVALUATION OF SSC FUNCTIONS AND IMPACT ON SAFETY 0
EXAMPLES OF GOALS:
LACK OF OR IMPROPER MAINTENANCE LEADING T0; SAFETY SYSi;M FAILURES.
CHALLENGES TO SAFETY SYSTEMS 0.
ALLOWS CONSIDERATION OF:
SYSTEM FUNCTION EQUIPMENT REDUNDANCY DIVERSITY OPERATING MODE PLANT CONDITION SAFETY RELATIONSHIP 0
QUANTITATIVE GOALS CONSISTENT WITH TOP PERFORMERS j
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CONDUCT OF MAINTENANCE
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SER'ES AS' A GUIDELINE'FOR' LICENSEES
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0 ALLOWS FL5X1BILITY l'
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AREAS' COVERED:
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PLANT ORGANIZATION AND MANAGEMENT OF MAINTENANCE MAINTENANCE PERSONNEL QUALIFICATION AND TRAINING-MAINTENANCE-SUPPORT ORGANIZATIONS MAINTENANCE PROCEDURES PLANNING AND SCHEDULING TYPES OF MAINTENAf4CE WORK CONTROL PROCESS RECORDKEEPING s
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- AND ASSESSMENT-l
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- ASSESSMENTS.
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- PERFORMANCE. MONITORING u.
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FEEDBACK'AND CORRECTIVE ACTIONS BASED ON EFFECTIVENESS MONITORING
'AND ASSESSMENT
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. FEEDBACK TO BE USED-TO DETERMINE NEED FOR CORRECTIVE-ACTIONS' MAINTENANCE PROGRAM SHOULD DEFINE THOSE RESPONSIBLE FOR-FEEDBACK.INFORMATION AND THE CHANNELS OF COMMUNICATION
. CORRECTIVE ACTION DIRECTED TO ENSURE DEFICIENCIES-ADDRESSED
' PROGRAM SHOULD DESCRIBE PROCESS FOR TIMELY. FEEDBACK AND IMPLEMENTATION I
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MAJOR CHANGES TO APRIL 6, 1989' PACKAGE f'
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PGS. 6, 54 AND 55 - REVISED S0C AND SECTION (E) 0F RULE' L
" IMPLEMENTATION" TO PROVIDE A SCHEDUI.E FOR PROPOSING AND IMPLEMENTING'A 3RD PARTY CERTIFICATION' PROCESS AND TO ELIMINATE THE REQUIREMENT THAT IT BE INDUSTRY WIDE.
OL ADDING "LINE IN/LINE OUT"' VERSION OF RULE TO SHOW CHANGES IN GOING FROM PROPOSED TO FINAL RULE.
O' ADDING ENCLOSURE TO INCLUDE AND-ADDRESS ACRS LETTER.
O ADDING REFERENCE TO 0MB LETTER IN S0C kESPONSE TO PUBLIC-COMMENTS.
O REVISING REGULATORY IMPACT ANALYSIS TO USE MORE-ACCURATE PERCENTAGES OF " GOOD,"'" SATISFACTORY" AND'" POOR" PLANTS FROM MTIS.
O.
REVISED REG. GUIDE:
SECTION C. 3 TO REMOVE EXAMPLE GOALS SECTION.5 TO MORE STRONGLY ENCOURAGE USE NPRDS 0
ADDING TO SOC A SECTION SOLICITING COMMENT ON DRAFT R.G.
PLUS SPECIFIC QUESTIONS.
,