ML20248B014

Summary of ACRS Maint Practices & Procedures Subcommittee Meeting on 890330 in Bethesda,Md Re Rulemaking Package

ML20248B014
Person / Time
Issue date:	07/17/1989
From:	Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
References
ACRS-2634, NUDOCS 8908090092
Download: ML20248B014 (12)

Text

- _ _ . - _ _ _ _ _ _ _ - _ _

gegS-a a f V '

f'D R 2l* N 9

}

4 CERTIFIED COPY 1

L,3 g 3 DATE ISSUED: July 17, 1989 j

SUMMARY

/ MINUTES MAINTENANCE PRACTICES AND PROCEDURES SUBCOMMITTEE MEETING q MARCH 30, 1989 /

BETHESDA, MARYLAND The ACRS Maintenance Practices and Procedures Subcommittee met at 8:30 a.m., March 30, 1989, Room P-110, 7920 Norfolk Avenue, Bethesda, Ma ryland. Mr. Carlyle Michelson is the Chairman of this subcommittee.

The subcommittee members in attendance were: Mr. James C. Carroll, Mr.

C. Wylie, and Dr. W. Kerr.

Due to a scheduling problem, the court reporter didn't arrive until 10:14 a.m. During the pre-transcript period, the staff made a presenta-tion on their approach and outlined the final rulemaking package.

Robert Frahm, Research, presented a summary and analysis of public comments.

Mcni Dey, Research, stated the purpose of the briefing was to present the subcommittee with a rulemaking package and to obtain ACRS comments prior to CRGR and Commission review. He noted that the staff requests an ACRS letter at the April full Committee meeting. He said the rulemaking package will be submitted to the Commission on April 21, 1989.

l Mr. Dey outlined the regulatory background fur the Maintenance rule:

E IC M Q ORIGINAL C utigggg 3, -(}lj

'2 890717

&SO __

F'DC El__ __ _ - - _ - - - - _ . _ _ _

~*' '

[. Minutes / Maintenance Practices 2 i

. & Proceduras Subcom. Mtg. March 30,1989

o. Work initiated in 1980' o Review of status of maintenance in U.S. nuclear industry o Policy statement o Public workshop 1988 o Notice of proposed rulemaking, November 1988.

The notice of the proposed rulemaking included the definition of mainte-nance in 17 areas. This includes the requirements to establish, imple-ment and maintain a program, assess program effectiveness and execute corrective actions. The proposed rule calls for the licensee to develop-a plan and schedule within three months after publication of the rule, and implement the rule after two years following the effective date of the rule.

l Mr. Dey noted that the scope of the rule had been changed to respond to comments received.- The rule now reads that the maintenance program shall include all structures, systems and components whose failure could significantly impact the safety and security of the facility.

The subcommittee noted that the definition of all things that could significantly impact safety is too broad in scope. Mr. Michelson noted that everything impacts safety unless you show that it doesn't.

Mr. Dey noted that an option has been added to the implementation. This option provides that the certification of the licensees maintenance program could be provided by a third party. The certification would be reviewed against a maintenance standard.

s-

• ~ '

Minutes / Maintenance Practices' . 3 L' .. .& Procedures Subcom. Mtg.', March 30,1989-

, Mr. Dey noted that the staff had prepared a regulatory guide in the absence of an industry commitment to provide a maintenance standard by the close'of the public comment period. The regulatory guide has an i.

introductory discussion and a section on the regulatory position.

Within the section on regulatory position are six subsections. The regulatory guide concludes with a section on implementation which provides guidance on compliance with the regulations.

Mr. Dey noted the objectives for the regulatory guide would be to determine what the licensee plans to accomplish with the maintenance program in relationship to safety. General and specific objectives depending on the functions and safety significance of the equipment would be developed. The maintenance activities for the equipment would then be developed. After conducting maintenance on the equipment, the equipment would be monitored to determine if the maintenance program is effective. The results of the monitoring would be used to determine if any corrective actions are necessary.

Mr. King pointed out that the regulatory guide requires that the licens-ee develops quantitative numerical goals for his systems, structures and components. In addition to that, there would be some qualitative assessments that could be done. Mr. King noted that when the plant is inspected against the regulatory guide, the fact that he hasn't achieved those goals is not grounds for determination of non-compliance with the rule and the regulatory guide.

E-~ - - _ . - -- . _ - _ _ _ _ _ _ _ _ - - - _ _ - - - - _ _ _ _ _ -

• Minutes / Maintenance Practices 4

. & Procedures Subcom. Mtg., March 30,1989 The subcommittee questioned how the systems and components would be-sel.-oted as part of the maintenance program. The staff responded that each licensee would have to use its judgement.

l_ A subco.t:nittee member asked how far down to the component level should this program be carried? The staff responded that it was up to the licensee.

1 A subcommittee member asked if system goals could be established and not worry about components? The staff responded that the regulatory guide states that some component-level goals are important to monitor the effectiveness of maintenance.

Mr. Mark Williams, AEOD, pointed out that in the area of indicating and monitoring of indicators, that the staff couldn't get correlation at the system level. In oroer to develop indicators that measured the effec-tiveness of maintenance, they had to 90 to the component level and look l at the changes in failure rates at the component level.

There was considerable discussion about the relationship of risk and the maintenance program. Mr. King stated that the maintenance program will reduce risk in a cost effective process.

l A Committee member stated that if we can't establish a relationship between a maintenance program and risk, how will we ever know if the maintenance program is effective? Mr. King responded that the regulato-ry analysis in November the package made an attempt to establish that.

6 -'

a

.. Minutes / Maintenance Practices 5

& Procedures Subcom. Mtg. March 30,1989 Mr. Michelson asked why not consider the availability of the systems as listed in the plant technical. specifications? Mr. King replied that the maintenance rule covers systems beyond the technical specifications. He noted a lot of the failures came from the balance of plant which is not covered by the technical specifications.

Mr. Dey noted that the licensee should set an overall objective related to risk, and set specific objectives. The rule states SSC but not for all components. The objectives are set at a high level. If the high levels aren't being met, then the licensee would perhaps set a goal at the component level to produce the desired results.

Mr. Dey noted that the staff expected the performance to be consistent with what's achievable in the industry with what the top performances are doing.

A subcommittee member noted that there wasn't any test of cost effective maintenance in the industry. Each utility has a unique situation. Mr.

King said that he wasn't suggesting that there was a single measure.

Mr. Michelson asked how the resident inspector decides whether the maintenance program meets the intent of the rule? Mr. King replied that the staff hasn't decided whether it would be just the inspector or a maintenance team inspection auditing the maintenance programs.

Mr. Dey said that the staff plans to develop an inspection guide.

N m

Minutes / Maintenance Practices .

L. 6

,,, & Procedures Subcom. Mtg., March 30,1989

,w .Mr. Carroll asked if the proposed maintenance inspection guide would be much different than the guide now used for maintenance team inspections?

Mr. King replied.that his personal view was that it would be enhanced in

-the area.of. goals and objectives monitoring.

L Dr. Kerr asked what fraction of the nuclear utilities have acceptable maintenance programs?. Mr. King replied that based upon the latest maintenance team inspections about 44% received the top rating from the-maintenance inspection team.

Mr. Dey noted that the rule has been modified to indicate scope for those components that would impact safety and security. The guide identifies those structures and systems relied upon for core cooling, pressure boundary protection, safe shutdown, prevention and mitigation.

The scope covers-those SSC's whose failure would initiate a transient or challenge a safety system. In addition are listed other systems required for safety, fire protection, security, safeguards, emergency preparedness and post-accident monitoring.

Tom Foley pointed out that he has been a senior resident inspector at Yankee Rowe, Indian Point and Calvert Cliffs. He said in many instances it was the resident inspectors interpretation of the regulations that counted in the long run.

The subcommittee discussed the documentation required by the maintenance rule. The staff maintained that 'their inspections are performance based inspections and not paper reviews. Mr. Foley noted that the amount of C~ _ _ _ - _ - - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _ - - - _ _ _ _ .

Minutes / Maintenance Practices 7

l. Procedures Subcom. Mtg. March 30,1989

. paper generated wasn't the important consideration. He said the impor-tent consideration was how well they are performing maintenance. If a licensee is not performing well, then it would get increased attention from the NRC, l

.The staff discussed Qualification and Training. Dr. Kerr asked if INPO accreditation would be required of all maintenance programs? Mr. Hart responded that it wasn't required. The INP0 accreditation.is an accept-able method of meeting the training and qualification requirements.

It's not necessarily meant to be the only way a licensee can do it.

The staff discussed performance monitoring and assessment. This section of the regulatory guide states that indicators should be used to track i

the performance of the maintenance program towards achieving the select-ed objectives and goals. The licensee should include definition of the goals and objectives so that the parameters that are being tracked are defined.

Moni Dey noted that the staff had looked at three types of indicators.

1 Plant level indicators, process indicators which indicate the mainte-nance program itself, and effectiveness indicators that are based upon component failure rates.

Mr. Dey said the staff viewed management involvement in the maintenance program as oversight and self assessment. This would be sampling of maintenance activities, looking at trends, and using that as input toward determining the effectiveness of the program.

b- --__i____-___-.-_---_-_---.-__--- - ---.-- ----. - _ - - -- - - - - - - - - - - - - - - _ - - - - - - - -

Minutes / Maintenance Practices 8

. & Procedures Subcom. Mtg. March 30,1989

. The staff discussed the section of the regulatory guide on feedback and corrective action. The licensee would monitor the performance of the plant and the maintenance activities and determine how well the equip-ment is performing and how well the maintenance program is performing.

Mr. Williams, AE0D, discussed the aiaintenance indicators. He noted-that AE0D found the best correlation to overall performance in component failure rate information. They ran statistical analyses to verify the correlation. The end result was development of process indicators that are valid to monitor the maintenance process and effectiveness indica-tors that monitors the results of maintenance.

Mr. Dey noted the purpose of feedback is to oetennine the need for corrective action. The people responsible should be -identified and corrective action should be directed toward the correction of defi-ciencies. The corrective action process determines the cause of the i

deficiency, provides timely action, and provides documentation of what actions have been taken. ,

i l

Tom King discussed the backfit analyses. He noted that the staff is no l

longer justifying the maintenance rule on an adequate protection basis. )

The maintenance rule is justified on enhanced safety. He noted it can be justified on a qualitative basis. The staff believes that mainte-nance has a direct impact on plant safety. This can be determined by looking at existing performance and past performance and using engineer-ing judgement. He said that maintenance affects the reliability of the safety systems and maintenance can affect the number of challenges to I r_. . j

L , ,

Minutes /Maint: nance. Practices 9

~*

. & Procedures Subcom. Mtg., March 30,1989 those safety systems and to the operators. He concluded that it was reasonable and proper for NRC to regulate maintenance provided that its done in a fashion that will result in an improvement in safety.

l Mr. King remarked that there is a variance across the industry in maintenance, and the staff believes the rule will facilitate the Com-mission's taking action in the maintenance area to achieve improvement where such improvement is needed.

He said a regulation will, better define the requirements for mainte-nance that will help insure good maintenance practices are achieved and sustained. The regulation will help insure the effects of aging are ,

factored into plant maintenance programs.

He concluded that it was cost beneficial to have a good maintenance program.

Brian Richter, Research, discussed the public comments on the draft regulatory analyses.. He noted the NUMARC comments. NUMARC commented that:

The regulatory analysis overrelied on NUREG 1212, the costs were under-estimated, th6 benefits of risk reduction were over estimated, and many of the assumptions were uncertain.

~ Minutes / Maintenance Practicas 10

.... & Procedures Subcom. Mtg., March 30,1989 q

{

, He noted that in the revised regulatory analysis, the staff is working with' draft regulatory guides instead of NUREG 1212 for the cost ele-t ments.

i 1

Maintenance team inspections are being used for data instead of

-NUREG-1212 with regard to risk analysis. He pointed out that mainte- j nance doesn't lend itself to PRA techniques.

The meeting was concluded at 3:53 p.m.

• • • • • • ****** ****** l NOTE: A transcript of the meetin ment Room, Gelman Bldg. 2120 "L"g is available Street, at the NRC NW., Washington, D.C.Public Docu-Telephone (202) 634-3303 or can be purchased from Heritage Reporting Corporation, 1220 t Street, N.W., Washington, D.C. 20005, Telephone (202) 628-4888.

1 l

r

.q .

[Mihutes/MaintenancePractices~. 11' M .3 j. .a

. .,., & Procsdures Subcom. Mtg.. March 30,1989l t

e

^

Actions, Agreements and Comitments:

g'- 1. 'Mr. Michelson noted that the ACRS subconnittee would like to see L the inspection module after it is drafted.-

1.

1 l'

e

[i g ,.:.. . Minutes / Maintenance., Practices . 11 "1,~ ~ ~

.& Procedures Subcom, Mtg., March 30,1989 JS: ,j

,..,1 Actions, Agreements and Commitments:

1. -Mr. Michelson noted that the ACRS subcommittee would like to see the inspection module after it is drafted.

1

"~

, . . _.. _,