ML20244E441
| ML20244E441 | |
| Person / Time | |
|---|---|
| Issue date: | 04/11/1989 |
| From: | Remick F Advisory Committee on Reactor Safeguards |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1346, FACA, NUDOCS 8904240487 | |
| Download: ML20244E441 (2) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION j ,E ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l WASHINGTON, D. C. 20555 April 11, 1989 j The Honorable Lando W. Zech, Jr.
Chairman ,
U.S. Nuclear Regulatory Comission l Washington, D.C. 20555
Dear Chairman Zech:
l
SUBJECT:
PROPOSED FINAL RULEMAKING REL.eTED TO MAINTENANCE OF NUCLEAR POWER PLANTS During the 348th meeting of the Advisory Comittee on Reactor Safe-guards, April 6-8, 1989, we discussed the draft Comission paper related to final rulemaking for maintenance of nuclear power plants, including a draft regulatory guide. Our Subcommittee on Maintenance Practices and Procedures discussed this matter with representatives of the NiJ staff and the Nuclear Management and Resources Council during a meeting held on March 30, 1989. We also had the benefit of the document referenced.
We previously comented on the proposed rulemaking in a report dated September 13, 1988.
In our September 13, 1988 report we did not endorse the staff's proposal to establish a maintenance rule. After review of the proposed final rule, including the public coments and a related draft regulatory !
guide, our position remains essentially the same. We still believe that good maintenance is a necessary ingredient in any operational program that seeks to ensure reliable and safe plant operation, but that is not the issue. The issue is how to achieve good maintenance. ,
i We were told by the industry that its aggressive emphasis on the devel-opment of effective maintenance programs over the past several years has resulted in a marked improvement in the maintenance programs themselves, !
and in significant progress toward reaching its objectives. The staff l members with whom we conferred agreed that this is the case. Further, we were told that a staff evaluation of a sample of maintenance pro-grams, which included about one quarter of those plants now operating, indicated that only a few percent of the operating plants may have poor maintenance programs. 'Given an environment in which there is already a scarcity of industry and NRC resources, we believe that it is more cost effective to seek improvements applicable to the few plants with " poor" maintenance programs by means of existing regulations rather than burdening all plants with a costly program of unproven efficacy.
The scope of the proposed final rule is also of concern. The Comission l has the responsibility to regulate the operation of nuclear power plants !
in a way that ensures protection of the public health and safety, but b (SM 8904240407 ACRS 890411 pgu O a[>/, r' i
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.The Honorable Lando W. Zech, Jr. April 11, 1989 does not have the responsibility for managing plant operation. The proposed final maintenance rule strains severely and may violate the boundary between regulating and managing. The scope of the proposed final rule and its accompanying regulatory guide is so broad that almost every facet of plant operation would be under the continuing scrutiny of the NRC on the basis of its effect on maintenance. This would be counterproductive.
Because everyone involved believes that maintenance programs are im-proving, and because the industry is comitted to additional improve-ments, we recomend that the staff continue to monitor the industry's i' progress and not intervene at this time.
The proposed final rule would introduce a major policy change extending j NRC responsibility far beyond . identified safety systems. We do not )
believe such a significant change in policy should occur in the guise of I a maintenance rule which deals only with maintenance and provides no j guidance on which systems deserve special attention. The ACRS has in the past recommended more emphasis on the performance of some nonsafety systems. For example, the Comittee recomended an evaluation of the i contributions to risk from failures of nonsafety-grade control systems.
More recently, the Comittee has recommended a reevaluation of the current set of regulations in the light of additional insights provided by risk-based evaluations of plant performance and the adoption of safety goals. We would endorse a well-conceived reevaluation of current regulations which would undoubtedly suggest that more regulatory em-phasis should be placed on some systems that in the past have been treated as balance-of-plant, and less on others. However, this evalu-ation should be done in an integrated manner which would, on the basis of what has been learned about risk contributions, identify some systems for special attention.
Sincerel
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orrest J. Remick Chairman
Reference:
Memorandum dated April 6,1989 from Bill M. Morris, Office of Nuclear Regulatory Research, for Raymond F. Fraley, ACRS,
Subject:
Draft Comission Paper for Notice of Final Rulemaking For Maintenance of l
Nuclear Power Plants," w/ enclosures (Predecisional)