ML20236R311
| ML20236R311 | |
| Person / Time | |
|---|---|
| Issue date: | 06/10/1998 |
| From: | Latta R NRC (Affiliation Not Assigned) |
| To: | Stewart Magruder NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9807210359 | |
| Download: ML20236R311 (5) | |
Text
- . -
,j . 2.. Pa6 LEO
, onig 1 UNITED STATES
, ;f j
t NUCLEAR REGULATORY COM,M SSION WASHINGTON, D.C. - aans i f,!)
%,..u .s /
I E l June 10, 1998116 !fi 7: t:0 i IU3UC CCCL'MEhi Rja i
MEMORANDUM TO: Stewart L. Magruder, Project Manager Generic issues and Environmental Projects Branch Division of Reactor Program Management THRU: %hard P. Correia, Chief dbW Reubility and Maintenance Section Quality Assurance, Vendor inspection and Maintenance Branch Division of Reactor Controls and Human Factors FROM: Robert M. Latta, Senior Operations Engineer j -
Reliability and Maintenance Section Quality Assurance, Vendor inspection
[.
and Maintenance Branch Division of Reactor Controls and Human Fcctors
Subject:
SUMMARY
OF MAY 28,1998, MEETING BETWEEN THE NUCLEAR REGULATORY COMMISSION (NRC) AND THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING THE DRAFT REVISION TO NUMARC 93-01, REVISION 2 On May 21,1998, members from the NRC staff met with representatives from Nuclear Energy Institute (NEI), in a public meeting to discuss issues related to a draft revision to NUMARC 93-01," Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The draft revision to NUMARC 93-01, Revision 2, had been developed by NEl and submitted to the NRC by letter dated May 1,1998, in order to address the proposed rulemaking to 10 CFR 50.65 described in the December 17,1997, Staff Requirements Memorandum (SRM). Specifically, this SRM directed the staff to develop proposed rulemaking to revise the maintenance rule to require that safety assessments be taken into account prior to performing maintenance activities, subject to certain provisions definoated in the SRM.
In their opening remarks, NEl stated that the draft revision to NUMARC 93-01, Revision 2, had been developed through an industry task force and was primarily directed at (1) providing additional guidance concerning the conduct of assessments for equipment out-of-service, and (2) the process for incorporating existing guidance for shutdown configuration control by referencing portions of NUMARC 91-06, " Guidance for Industry Actions to Assess Shutdown )
j Management." NEl further stated that it was their intent to seek NRC endorsement of their implementation guidance to address the requirements of the final rule. t Subsequent to the opening remarks, NEl briefly described their suggested revisions to the h
l proposed rule wording for paragraph (a)(4) contained in the December 17,1997, SRM. O This suggested revision is descrited in Enclosure 1 to NEl's May 1,1998, letter and is included i
9807210359 930610 .a' 1 r ,: ,L b l PDR REVGP ERONUMRC t>
hf J l, g pf 4 p' \{Tg PDR g(t
S. Magruder as Attachment 1 of this meeting summary. As indicated by NEl, their basis for the suggested revision was that (1) the proposed description of maintenance activities was redundant to the Commission policy statement regarding the definition of maintenance, (2) that the terminology related to " risk-significant configurations" was not defined, and (3) that the suggested use of
" reasonable assurance", in conjunction with the requirement of maintaining safety functions, was more in keeping with the performance based approach of the maintenance rule. NEl also stated that, the changes contained in their draft revision to NUMARC 93-01, Revision 2, were limited to Section 11.0, " Evaluation of Systems to be Removed From Service"(see Enclosure 2 of Attachment 1).
During the ensuing discussions of the proposed revisions to Section 11.0, various topics were discussed including the need to provide additional clarification related to terminology such as
" key safety functions," and " unplanned corrective maintenance." Additionally, the staff indicated that Section 11.2.2, " Identify SSCs That Suppart Key Plant Safety Functions," would require revision to ciarify those plant configurations which could be preanalyzed in the assessment process. Relative to Section 11.2.6, " Safety Assessment for Removal of Equipment from Service During Shutdown Conditions," the staff noted that the principal guidance in this area was provided by reference to NUMARC 91-06, which has not been endorsed by the NRC. As indicated by the staff, the reference to aa LimUorsed industry cocument, in NUMARC 93-01, would not denote that the referenced document itself had been endorsed. Therefore, in order for NEl to use NUMARC 91-06 as the primary source of guidance for shutdown conditions, the document would require separate review and endorsement by the NRC. In response to this issue, NEl stated that they would consider expanding the guidance contained in Section 11.2.6, to be more self-contained.
At the conclusion of the meeting, the consensus was that the discussions were beneficialin identifying sectins of the draft rev!sion of NUMARC 93-01, Revision 2, that the staff believes will require amplification prior to consideration of any endorsement via Regulatory Guide 1.160.
Although the staff and NEl acknowledged that future meetings would be necessary to discuss refinements to NUMARC 93-01, Revision 2, no specific dates were identified. However, NEl indicated their intent to provide another revised draft version of NUMARC 93-01 in conjunction with the establish ed schedule for the proposed rule change, which would serve as a forum for future discussions in this area.
Project No. 689 cc: See next page Attachments: 1. NEl letter to NRC dated May 1,1998
- 2. Attendance List l
<-----_---__--._----_.-_-_--a . _ . - . _ - _ - _ - _ - _ . _ - - _ - _ _
\- .
N
{l l NU(llAR IN[tGV IN STIT Uf f
$271% IMP*
NUCLEAR GENERATON DMSON l
May 1,1998 Mr. Samuel J. Collins Director
~ I OfBee of Nuclear Regulatory Regulation )
U. S. Nuclear Regulatory Commission ]
Washington, D. C. 20555-0001 l
SUBJECT:
DRAFT Revisions to NUMARC 93-01, Industry Guideline for ;
Monitoring the Effectiveness ofMaintenance at Nuclear Power Plants, to Address Proposed Rulemaking to 10 CFR 50.65
Dear Mr. Collins:
Enclosed for NRC's information and use are proposed draft revisions to NUMARC 93-01, Revision 2. These revisions are directed at accommodating the proposed miemaking to 10 CFR 50.65 discussedin the December 17,1997, Staff Requirements Memorandum (SRM). It is our understanding that the staff will submit a rulemaking package to the Commission in the near future, and that the final rulo will be promulgated by the end of the year.
The proposed revisions were developed through an industry task force and I incorporate comments on a previous draft that was distributed to licensees. In response to the two principal areas addressed in the SRM, the intent of the revisions is to 1) provide additional guidance regarding conduct of assessments for equipment out-of service; and,2) incorporate existing guidance for shutdown con 6guration control by referencing portions of NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
NUMARC 93-01, Revision .2, currently serves as the industry implementation guidance for the maintenance rule and is endorsed by NRC Regulatory Guide 1.160, Revision 2. We intend to seek NRC endorsement of the revised implementation guidance to meet the final rule, and propose to work with the staff concurrent with the rulemaking effort to achieve this objective.
4
......3,,0 $_103
, .,_ M W _ ., _ . , _ ...... . . . . . . . . = ... ...... _ .Attachw .e :
- s. .
' -; - Mr. Samuel J. Cellins {
May 1,1998 Page 2 Enclosure 1 provides suggested revisions to the proposed rule wording for section (aX4) as discussed in the December 17,1997, SRM. We will provide more extensive comments in our response to the formal rulemaking package.
Enclosure 2 provides the draft revisions to NUMARC 93-01, Section 11.0,
" Evaluation of Systems to be Removed From Service." We believe all necessary revisions to reflect the proposed rulemaking would pertain to this section.
I We look forward to meeting with your staffin the near future to proceed with '
this important effort. Ifyou or your staff have any questions, please contact me at (202) 739-8081 or Biff Bradley at (202) 739-8083.
Sincerel , .
I h f K- JM Anthony R. Pietrangelo REB /ARP/npg Enclosures c: Ms. Suzanne C. Black, NRC/NRR Mr. Richard P. Correia, NRC/NRR l
s, . j
. \
l 1
Enclosure 1 t
Proposed revision to 10 CFR 50.65(a)(3)
{
10 CFR 50.65(aX4)[ proposed in 12/17/97 Staff Requirements Memo] j Pnor to performing maintenance activities on SSCs within the scope of this section (including, hut not limited to, surveillance testing, post-maintenance testing, corrective maintenance, performance / condition !
monitoring, and preventative maintenance), an assessment of the f
current plant con 6guration hs well as expected changes to plant l configuration that will result from the proposed maintenance activities shall be conducted to determine the overall effect on performance of safety functions. The results of this assessment shall be used to ensure that the plant is not placed in risk t.ignificant eenfigurations.
NEI believes the following changes should be effected to the proposed rule language:
Prior to performing maintenance activities on SSCs within the scope of this section, an assessment of the current plant configuration as well as planned changes to plant configuration that will result from the proposed maintenance activities shall be conducted to determine the overall effect on performance of sefety functions. The assessment shall be used to provide reasonable assurance that safety functions are maintained.
1
(
+.
I DRAFT !
Enclosure 2 Proposed Revisions to NUMARC 93-01,R2 (changes are italicized) 11.0 EVALUATION OF SYSTEMS TO BE REMOVED FROM SERVICE l
11.1 Reference (see previous page)
{
i 11.2 Guidance ~
This section provides guidance to develop and conduct assessments of the current plant configuration, andplanned changes to the plant conf 9guration,
\
with regard to the overall impact on performance of safety functions, prior to \
scheduled removal ofSSCs from service (cr maintenance. Sections 11.2.1 through 11.2.3 discuss thephilosophy and overall assessment approach.
Section 11.2.4provides guidance forperformance of the assessment, and is intended to cover all modes ofplant operation. Additionalguidance l regarding removal of equipment from service at power operating conditions is provided in Section 11.2.5. Section 11.2.0provides additicnalguidance on removal of equipment from service during shutdown conditions and references .
Section 4.0 of NUMARC 91-06, Guidelines for Industry Actions to Assess !
Shutdown Management. Section 11.2.7provides guidance for documentation of the assessment process.
The development of an approach to assess the impact on overall plant safety functions upon removal of SSCs from service consists of three Meps:
- 1. Identify key plant safety functions to be maintained;
- 2. Identify SSCs that support key plant safety functions;
- 3. Consider the overall effect ofremoving SSCs identi6ed above from service on key plant safety functions.
Steps 1 and 2 have been discussed in general terms in previous sedions, and establish a framework for the assessment ofremoving SSCs from service described in Step 3.
1
DRAFT 11.2.1 Identify Key Plant Safety Functions Applicable to the Plant Design Key plant safety functions are dependent on plant operating status (power operation or shutdown). Forpower operation, key plant safety functions are those that ensure the integrity of the reactor coolant pressure boundary, ensure the capability to shut down and rnrantain the reactorin a safe shutdown condition, and ensure the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to 10 CFR Part 100.
Examples of these power operation key safety functions are:
Containment Integrity (Containment Isolation, Containment Pressure and Temperature Control);
Reactivity Control; Reactor Coolant Heat Removal; and Reactor CoolantInventory Control.
Shutdown key safety functions are as follows (from Section 4 ofNUMARC 91 06)
Decay heat removalcapability
- Inventory Control
- PowerAvailability
- Reactivity control Containment (primary / secondary)
For Lth power operations and shutdown, the key safety functions are achieved by using systems or combinations of systems, that could include redundant subsystems or trains.
11.2.2 Identify SSCs That Support Key Plant Safety Functions Once the required key plant safety functions are identified, the SSCs that support the key safety functions need to be identified: When removing SSCs from service, it is important to be aware of what function is being lost so the 2
l
9 impact ofremoving multiple equipment from service can be determined. The ability of a system, or ofredundant or supplemental systems to support the key safety function is key to determining the overall effect of taking SSCs out ofservice.
For the purposes of the equipment out-of service assestmnt, SSCs are considered to support a key safety function if they:
- Have a significant impact on the performance ofa key safety function; or e
Have a significantpotential to challenge a key safety function, such as SSCs whose failure would result in a scram or safety system actuation, or would significantly complicate recovery efforts.
Work done to date on symptom-based emergency operating procedures, IPE vulnerability assessments and shutdown safety assessments can be used to identify SSCs and to select those SSCs required to fulfill a key safety function. Section 9.11 discusses establishment ofrisk significant criteria for 1 SSCs for the purpose ofestablishing goal setting and monitoring. This approach can also be used to identify SSCs which support key safety functions for the equipment-out of service assessment.
11.2.3
- Assess and Control the Effect of the Removal of SSCs hem Service on Key Plant Safety Functions During the planning and scheduling phe.se and prior to authorizing the removal of SSCs from service, each planned maintenance activity that results in the removal of an SSC identified in Section 11.2.2 from service shall be assessed forits impact on key plant safety functions. This assessment applies during all modes of plant operation and shall take into account current plant configuration as well as planned charges to plant configuration.
On-line maintenance is a planned and scheduled activity to perform preventive or corrective maintenance, with the reactor at power, while properly controlling out of-service time ofsystems or equipment. The benefits of well managed snaintenance condv.Med during power operations include increased system and unit availability, reduction of equipment and system deficiencies that could impact operations, more focused attention during periods when fewer activities are competing for specialized resources, and reduction ofwork scope during outages. On-line maintenance should be carefully managed to achieve a balance between the benefits and potential impacts on safety, reliability or avails.bility. For example, the margin of safety could be adversely impacted ifmaintenance is performed on multiple 3
L _ __
DRAFT equipment or systems simultaneously without proper consideration of risk, or if operators are not fully cognizant of the limitations placed on the plant due to out of service equipment. On-line maintenance should be carefully evaluated, planned, and executed to avoid undesirable conditions or transients, and to thereby ensure a conservative margin ofplant safety.
For example, scheduling maintenance that requires auxiliary feedwater pumps being out of service should take into account plant mode or condition, an assessment of the impact on key safety functions, including scheduled availability of other sources of feedwater, and the time auxiliary feedwater would be unavailable. Additionally, prior to actually removing the system from service to begin maintenance, the condition of the plant should be reviewed to verify that conditions are acceptable to take the system out of service.
Outage safety can be improved by focusing on the availability ofsystems that provide and support key safety functions as well as measures that can reduce both the likelihood and the consequences of adverse events.
Insights gained from available operating experience and analytical tools (i.
e., probabilistic safety assessments) can be incorporated into the on-line maintenance process. Such insights can be used to identify the systems or equipment that can be removed from service, considering assessments of when the system would be least needed. These insights can also be used, where appropriate, to establish specific criteria for use in maMng decisions about planned equipment removal, frequency, and duration. Actions to manage risk generally are directed at properly controlling out of-service time and maintaining configuration control to ensure defense-in-depth when certain systems or equipment are made unavailable.
The decision to take equipment out of service for maintenance should take into consideration the likelihood and possible consequences of an event for which the out-of service SSC would be needed occurring while the equipment it out of service.
4 a
~
.. DRAFT 11.2.4 GeneralGuidance for the Assessment
- 1. The assessment shall be conducted prior to the planned removal from service ofan SSC that is identified in Section 11.2.2 as supporting key safety functions. Individual SSCs that are not identified as supporting key safety functions may be removed from service for maintenance without the need for the assessment. For titcfollowing discussion, "SSC" refers only to those SSCs that support key safety functions.
- 2. The assessments for ditferent combinations ofSSCs may be predetermined orperformed on an as needed basis.
- 3. The degree ofdepth and rigor of the assessment should be related to the safety significance ofthe SSCplannedfor removalfrom service. The assessment may use either a quantitative or qualitative approach. The overall safety significance is a function of the combination ofSSCs that will be out ofservice (those already out ofservice in the existingplant configuration plus those that are contemplated for removalfrom service).
- 4. M assessment may take into account whether the out-of service SSCs could be promptly restored to service if the need arose due to emergent "
conditions. Examples include:
- An SSC out ofservice for monitoring or surveillance might be i capable ofprompt restoration offunction, whereas an SSC out of k service for extensive maintenance would typically not be promptly available.
- An SSC placed in pull to lock (automatic feature disabled), but would still be functional in that the system would start ifswitched to run.
- 5. The assessment should consider the capability of the SSC to support performance of the key safety function ifcalled on. SSCs having Technical Specification requirements trary be declared "insperable," but still be capable ofperforming their function. An ezample would be ifinoperability is declared due to a missed surveillance, or due to documentation issues.
- 6. Theplant licensing basis already considers the unavailability ofsingle SSCs through the Technical Specifications allowable outage times. If the
, plannedplant csnfli , ration will result in a single SSC with Techa~al Specification requirements out ofservice, and the duration of availability is within the 11rchnical Specifications allowed outage time, the assessment need not be conducted, unlesk unusualconditions a^re >
i l '.- -
DRAFT present orforecasted (e.g., severe weather). Some SSCs identified as necessary to support key safety functions may not have Technical Specifications Requirements;however, a single SSC may still be removed
' from service for a reasonable duration (e.g. commensurate with typical Technical Specification allowed outage times), without performance of the (
assessment, except as noted above for unusual conditions.
11.2.5 Assessment for Removal ofEquipment fVom Service During Power Operating Conditions Power Operating conditions are defined as plant modes other than hot shutdown, cold shutdown, refueling, or defueled.
- 1. If theplannedplant configuration wil result in multiple SSCs out of service, and these SSCs are within the scope of the existingplant PSA, an acceptable approach would be to quantitatively assess the risk impact.
This quantitative assessment can take the form ofusing the PSA model reflecting the plannedplant configuration, or using a safety nwnitor, matrix, or list derived from the PSA insights (see items 2 through 5 below forguidance. Ifcertain of the out-of. service SSCs are not in _the PSA scope, a blended (quantitative and qualitative) approach can be used for the establishment of the safety monitor, matrix, or list.
Whether quantitative assessment tools are available or not, an acceptable approach is to qualitatively address the performanr* ofks; safety functions (item 6 below).
- 2. Most plant's quantitative assessment tools include the capability to address core damage frequency (level 1) for internal events at power operation. For thepurpose of the assessment, the existing PSA is not required to be expanded to quantitatively address containment performance (level 2), external evente, or conditions other than power operation. ' Strengthening ofthc. existing PSA represents en optional approcch to support conduct of the assessment.
Maintenance activities for some SSCs (e.g., containment isolation valves) may require consideration ofissues that are not addrened in a level 1 internal events PSA. In these cases, the assessment may need to include consideration of actions which could affect the ability of the containment to perform its function as a flesion pmduct barrier, and may need to include external events considerations.
6
u DRAFT With regard to containment performance, the assessment should consider:
whether new containment bypass conditions are crated, or the probability ofcontainment bypass conditions is significantly increased; i
whether new containment penetration failures that can lead to loss of containment isolation are created; and.
- ifmaintemnce isperformed on components ofthe containment heat removal system, whether redundant containment heat removal trains should be available.
- 3. External event consideratica irwolve the potential impacts of weather, flooding, and seismic conditwns with regard to theproposed maintenance evolution. For the purposes of the assessment, weather and external flooding need to be considered only ifsuch conditions are imminent or have a high probability ofoccurring during the planned out-of service duration. An example where these considerations are appropriate would be the long term removal ofdoors or floorplugs. Internal flood issues are associated with the potentialfor a condition to exis: Juring a planned maintenance evolution when one maintenance activityposes an increased risk offlood and a second activity exposes SSCs needed toperform key safety functions to that flood hazard.
- 4. The EPRIPSA Applications Guide (EPRI TR-105396) discusses considerations regarding PSA attributes, maintenance, and use in decisionmaking. This guidance should be considered in determining the degree of confidence that can beplaced in the use of the PSA for the equipment-out-of service assessment, and whether additional qualitative considerations should be brought to bear. For example, ifthe PSA has not been updated to reflect significant permanent changes in plant configuration, it may be necessary to qualitatively address the impact of these charages.
- 5. If the assessment is performed qualitatively, it show !.d consider the impact of the out-of serobe SSCs upon key safety functions, and whether the maintenance activity could significantly challenge key safety systems. The analysis should include the assessment ofplant systems supporting the affacted key safety functions, and trains supporting theseplant systems.
This includes the following considerations:
- Providing systems, structures, and components to ensure key safety l functions are maintained using redundant, alternate or diverse methods; 7
V .- -
DRAFT Planning and scheduling activities in a manner that optimizes safety system availability;
- Providing administrative controls that support and/or supplement the above elements.
I
- 6. For unplanned corrective maintenance (i.e., no assessment has yet been performed), the assessment should be conducted with the following guidelines:
\
The assessment should be conducted on a reasonable schedule )
\
commensurate with the safety significance ofthe out-of service SSC.
- Performance of the assessment should not interfere with, or delay, the operator andfor maintenance crew from taking timely actions to mitigate theplant risk.
- If the SSC is restored to serviceprior to performance ofthe assessment, the assessment need not be conducted.
- 7. Conditions may arise following originalperformance of an assessment, and before or during the maintenance activity, that could affect the assessment results. Examples includeplant configuration or mode changes, SSCs out ofservice due to failures, and significant changes in external conditions (weather, offsite power availability). The following guidance applies to this situation:
The safety assessment should be re evaluated to address the changed plant configuration on a reasonable schedule commensurate with the safety significance of the plant configuration change. Based on the results of the re evaluation, ongoing maintenance activities may need to be suspended or rescheduled, and SSCs may need to be returned to service.
- Re-evaluation ofthe assessment should not interfere with, or delay, the ~
operator andIor maintenance crew from taking timely actions to mitigate theplant risk.
\
1
- If thepreviously assessedplant configuration is restored to service prior to re evaluating the assessment, the assessment need not be re-evaluated.
8 l
DRAFT 11.2.6 Safety Assessment for Removal ofEquipment from Service During Shutdoum Conditions Performance of the safety assessment for shutdown conditions involves the samegeneralprocess as described in Sections 11.2.1 through 11.2.4.
However, there are some different considerations than the at power assessment. These include:
- Quantitative assessments are not generally available, as PSA models for shutdown plant conditions are not in wide use.
- Key safety functions for shutdown conditions are decay heat removal capability, inventory control, power availability, reactivity control, and containment (primary or secondary).
- Assessments for shutdown maintenance activities need to take into account outage conditions and multiple plant configurations that impact the key safety functions. For example, assessment of mainte uince activities that impact the decay heat removal key safety function should consider: '
- initial magnitude ofdecay heat
- time to boiling.
- time to core uncovery e
initialRCS water inventory condition (e.g., $lled, reduced, mid-loop, refueling canal filed, reactor cavity Gooded, etc.)
RCS con 6gurations (e.g, openIclosed, nozzle dams installed or loop isolation valves closed, steam generator manways on/off; vent paths available, temporary covers or thimble tube plugs installed, main steam line plugs installed, etc.)
- natural circulation capability with heat transfer to steam generator shell side NUMARC 91-06, Guidelines forIndustry Actions to Assess Shutdown Maragement, Section 4.0, provides a complete discussion ofshutdown safety considerations with respect to maintaining key shutdown safety functions,
\
and should be considend in developing an assessment process that meets the requirements of10 CFR 50.65(a)(4).
In addition to the guidance in NUMARC 9106, forplants which obtain amendments to Technical Speci6 cation requirements on primary or secondary containment operability and ventilation system operability during fuel handling or con alterations, the following guidelines should be included in the assessment ofsystems removed from service:
9 l
- / , .
DRAFT
- During fuel handlingIcore alterations, ventilation system and radiation monitor availability (as defined in NUMARC 91-06) should be assessed, with respect to pltration and monitoring of .
releases from an event. Following shutdown, radioactivity in the fuel decays awayfairly rapidly. M basis ofthe Technical Speci6 cation operability amendment is the reduction in doses due to such decay. The goal ofmaintaining ventilation system and radiation monitor availability is to reduce doses even further below thatprovided by the natural decay, and to ensure unmonitored releases do not occur.
- l To ensure that any potential radiation releases from a rapidly evolving event, such as a fuel handling accident, would be routed to appropriate systems for treatment and monitoring, normal or contingency means topromptly achieve closure ofprimary or secondary containmentpenetrations should be developed. Such prompt methods need not completely block the penetration or be capable ofresistingpressure. Thepurpose is to reduce containment inleakage to thepoint that ventilation systems can treat and monitor radiation releases.
11.2.7 Documentation The following are guidelines for documentation of the safety assessment:
- 1. The purpose of this section of the maintenance rule is to establish a process for assessment ofimpacts on key safety functions due to planned removal ofequipment from service. This purpose should be established through plant procedures that address process, responsibilities, and decision approach. It may also be appropriate to include a reference to the appropriate procedures that govern planning and scheduling ofmaintenance or outage activities. Theprocess itself should be documented.
- 2. Once a process is established, it is not necessary to document each assessment for removal ofequipment from service as long as the process is followed. For evaluation ofremovalfrom service ofmultiple SSCs i'
using a predetermined approach (such as a' safety monitor, list, or matris), no further documentation is necessary unless additional special considerations (such as compensatory measures, or consideration ofissues beyond the scope of the assessment tool) are involved. -
l 10 L
-o 9
DD 1
- 3. In special situations where the normal assessment tools may be l
unavailable or not applicable, it may be necessary to rely on operator i
judgment as the basis for the assessment. This situation should be addressed by the proceduralized process above i
/
1 1
l I
i i
I e
II
--- _ _ _ _ _ _ _ - - - - - - - - ~ _ _ _ _ _
a Attendance List NAME/ TITLE 2 . 5:l; 1,, ; hy ? ",'? 4 : TELEPHONE-l
- ) c ^ y , . : Q .:'t" A o' ORGANIZATION AFFILIATION ,
~ ' 6:: " r , : '
.,,,s*, ' + : w.
l};*':w':-a
,' ;,: (
- f ^> ' , ;, '7; ~'
f };f,~ 3a ,.'^
Gary Holahan, Director 301-4152884 NRR/DSSA Suzanne Black, Branch Chief 301-415-1017 NRR/DRCH/HOMB Rich Correia, Section Chief 301-415-1009 NRR/DRCH/HOMB Michael Knapik 202-383-2167 McGraw-Hill Tony Pietrangelo, Director Licensing . 202-739-8081 NEl Biff Bradley, Sr. Project Manager 202-739-8083 NEl Mark Rubin, Section Chief 301-415-3234 NRR/DSSA/SPSB Eric Weiss, Section Chief 301-415-3264 NRR/DSSA/SRXB Mike Tschiltz, Sr. Regional Coordinator 301-415-1733 OEDO l Thomas Wilson 610-640-6568 PECO Energy Tony Hsia 301-415-8420 NRC/OCM/NJD Bradley S. Ferrell 440-280-5703 Clevland Electric (CEl)
Jerry Dozier 301-258-2490 NUS Info Services Mike Check 301-415-8380 NRR/DSSA/SPSB i i
Gareth Parry 301-415-1464 NRR/DSSA lan Jung 301-415-1837 NRR/DSSA/SPSB ;
Nanette Gilles 301-415-1180 NRR/ADPR/TSB Millard Wohl 301-415-1181 NRR/DSSA/SPSB Jin W. Chung 310-415-1071 NRRIDSSA/SPSB Peter Wilson 310-415-1114 NRR/DSSA/SPSB Mohammed Shuaibi 301-415-2859 NRR/DSSA/SRXB Dean Raleigh 301-417-4868 Bechtel Power Corp l
Lawrence Wild 860-285-2747 CE Owners Group
{
Julio Crespo 301-415-8364 NRR/DRCH/HQMB R. M. Latta 301-415-1023 NRR/DRCH/HQMB Attachment 2
i , .
4 e
t .
j Nuclear Energy institute n Project No. 689 f cc:
Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy institute Suite 400 Suite 400 1776 l Street N.W.
1776 i Street N.W. Washington, D.C. 20006-3708 Washington, D.C. 20006-3708 Mr. Nicholas J. Liparulo, Manager Mr. Alex Marion, Director Programs Nuclear Safety and Regulatory Activities Nuclear Energy Institute Suite 400 -
Nuclear and Advanced Technology Division Westinghouse Electric Corporation 1776 i Street N.W. P.O. Box 355 Washington, D.C. 20006-3708 Pittsburgh, PA 15230 Mr. David Modeen, Director Engineering NurJear Energy institute Suke 400 17761 Street N.W.
Washington, D.C. 20006-3708 Mr. Anthony Pietrangelo, Director Licensing Nucleat Energy institute Suite 400 1776 i Street N.W.
Washington, D.C. 20006-3708 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 i Street N.W.
Washington, D.C. 20006-3700
______