ML18176A042: Difference between revisions
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{{#Wiki_filter:}} | {{#Wiki_filter:An Alternate Approach to NUMARC 93-01 Chuck Sibley (Wolf Creek) | ||
Jenna Burr (Exelon) | |||
Jim Zapetis (Exelon) | |||
Mike McLain (APS) | |||
Larry Ellgass (TVA) | |||
Roy Linthicum (PWROG) | |||
Steve Vaughn (NEI) | |||
June 20, 2018 | |||
© NEI 2018. All rights reserved. For use by NEI members only. | |||
Outline | |||
* Background | |||
* Purpose | |||
* Proposed Changes | |||
* Overall Process | |||
* Proposed Pilot Effort | |||
* Challenges | |||
* Project Schedule | |||
© NEI 2018. All rights reserved. For use by NEI members only. 2 | |||
=== | |||
Background=== | |||
* Delivering the Nuclear Promise Initiative (early 2017) | |||
* Focus resources on high safety significant functions | |||
* Gain efficiencies in the interface between the Maintenance Rule program and other station programs | |||
* Leverage improvements in data collection/analysis and system monitoring | |||
© NEI 2018. All rights reserved. For use by NEI members only. 3 | |||
Purpose | |||
* Provide members with a risk-informed framework that supports the implementation and monitoring of a maintenance effectiveness program that complies with 10 CFR 50.65, effectively and efficiently leverages utility resources, and is focused on equipment performance commensurate with safety. | |||
© NEI 2018. All rights reserved. For use by NEI members only. 4 | |||
Proposed Changes | |||
* Leverage the effectiveness of maintenance strategies and lessons learned from the equipment reliability process | |||
- Address every High Safety Significant functional failure in near real time | |||
- Trend Low Safety Significant failures in CAP and evaluate in the (a)(3) assessment | |||
- Leverage the (a)(4) configuration risk management program (i.e., | |||
CDF Trending) for unavailability insights during the (a)(3) assessment | |||
* Consider using the Birnbaum importance measure as an additional tool in determining safety significance | |||
© NEI 2018. All rights reserved. For use by NEI members only. 5 | |||
Proposed Changes | |||
* Perform causal evaluations commensurate with safety | |||
- All HSS functional failures and Plant Level Events warrant a near real time causal evaluation | |||
- A trend of low safety significant failures warrants an appropriate causal evaluation. | |||
© NEI 2018. All rights reserved. For use by NEI members only. 6 | |||
Overall Process - The Start | |||
* Scoping | |||
* Safety Significance Determination | |||
- Establish HSS and LSS functions/SSCs considering insights from the Birnbaum importance measure (evaluated during pilot) | |||
* Establish/Implement Maintenance Strategy | |||
- Currently well-established equipment reliability program | |||
* (a)(1)-(a)(2) Determination | |||
- Based on the effectiveness of the component-specific maintenance strategy | |||
© NEI 2018. All rights reserved. For use by NEI members only. 7 | |||
Overall Process - Steady State | |||
* (a)(1)-(a)(2) Determination | |||
- Based on the effectiveness of the component-specific maintenance strategy | |||
* (a)(1) | |||
- Components that are not currently effectively controlled via effective maintenance strategy | |||
* (a)(2) | |||
- Components that are currently effectively controlled via effective maintenance strategy | |||
* Perform Maintenance Strategy | |||
- Execute the defined maintenance strategy | |||
© NEI 2018. All rights reserved. For use by NEI members only. 8 | |||
Overall Process - Reacting to Failures - Part I | |||
* Issue Report (IR)/Condition Report (CR) Initiated | |||
* Plant Level Events (PLEs) receive Yes a CAP cause evaluation | |||
* If the failure is associated with an HSS SSC and is either a No Maintenance Rule Functional Yes Failure (MRFF) or a Condition Yes Monitoring Event (CME) a CAP cause evaluation is performed | |||
© NEI 2018. All rights reserved. For use by NEI members only. 9 | |||
Overall Process - Reacting to Failures - Part II Yes | |||
* LSS failures are inputs for trending under the (a)(3) | |||
No No assessment | |||
* HSS failures that are not MRFF or CME are inputs to determine adverse trends under the (a)(3) assessment | |||
* If an adverse trend is identified, a Yes CAP cause evaluation is performed | |||
© NEI 2018. All rights reserved. For use by NEI members only. 10 | |||
Overall Process - (a)(1) Loop | |||
* (a)(1) process is essentially the same | |||
* Ensure that monitoring performance to goals is focused on the effectiveness of changes to the Maintenance Strategy No Yes | |||
© NEI 2018. All rights reserved. For use by NEI members only. 11 | |||
Overall Process - CDF Trending | |||
* Core Damage Frequency (CDF) | |||
Trending uses the (a)(4) configuration risk management process to provide unavailability Yes data for evaluation | |||
* Both a high-level and detailed assessment of unavailability data No | |||
© NEI 2018. All rights reserved. For use by NEI members only. 12 | |||
Overall Process - CDF Trending | |||
* Actual average CDF compared to present limits | |||
* Evaluate periods of higher risk | |||
- Could they have been avoided? | |||
- Indications of higher than average risk | |||
- If evaluation results in changes to maintenance strategy, evaluate for (a)(1) | |||
© NEI 2018. All rights reserved. For use by NEI members only. 13 | |||
Overall Process - Example #1 | |||
* Component: HPSI Injection Valve | |||
* Function: Indirect Radiation Release | |||
* Safety Significance: High | |||
* | |||
== Description:== | |||
Body to bonnet leak estimated to exceed the TRM limit. Determined to be a MRFF. Cause: failure to follow work instructions resulting in an inadequate weld. | |||
* NUMARC 93-01: Performance criteria: 3 failures, 36 months, remained in (a)(2). | |||
* Proposed Process: (a)(1)-(a)(2) determination would consider changes to the maintenance strategy given the ineffectiveness of maintenance (inadequate weld). | |||
© NEI 2018. All rights reserved. For use by NEI members only. 14 | |||
Overall Process - Example #2 | |||
* Component: Radiation Monitor RU148 (Containment Monitor) | |||
* Function: Monitor plant radiological conditions for assessment of site boundary radiation exposure levels | |||
* Safety Significance: Low | |||
* | |||
== Description:== | |||
Monitor taken offline due to excessive spiking and several ALERT alarms - due to apparent electronic interference. | |||
* NUMARC 93-01: Third failure against performance criteria of 4 failures in 12 months - remain in (a)(2). | |||
* Proposed Process: LSS failure would be slated for review in (a)(3) | |||
Assessment. CAP trending or (a)(3) review could identify or determine adverse trend. | |||
© NEI 2018. All rights reserved. For use by NEI members only. 15 | |||
Overall Process - Example #3 | |||
* Component: Station Battery | |||
* Function: Provide 125V DC for use in EOPs | |||
* Safety Significance: HSS | |||
* | |||
== Description:== | |||
Failure is unacceptable. Use condition monitoring (i.e., CME). Specific gravity and other parameters are monitored to detect adverse trends and allow corrective actions prior to failure. | |||
* NUMARC 93-01: Criteria: 2 CMEs in 24 months. | |||
* Proposed Process: Each battery CME has a CAP cause evaluation performed and assess for (a)(1) - (a)(2) | |||
© NEI 2018. All rights reserved. For use by NEI members only. 16 | |||
Proposed Pilot Effort | |||
* At least one pilot in each Region | |||
* Some stations will pilot the entire MR program while others will pilot just several systems | |||
* Pilots are not required to implement the NUMARC 93-01 process in parallel for the systems being piloted | |||
* Pilot starts in 4th quarter 2018 or 1st quarter 2019 | |||
* Continued interactions with the staff | |||
© NEI 2018. All rights reserved. For use by NEI members only. 17 | |||
Challenges | |||
* Change management | |||
- Impact to other station processes | |||
- Defining responsibilities | |||
- Other efficiencies | |||
* Applicability of current enforcement and inspection guidance | |||
* 50.65 is a performance-based rule | |||
© NEI 2018. All rights reserved. For use by NEI members only. 18 | |||
Project Schedule | |||
* September- Workshop/Training for pilot plants | |||
* Fall 2018 - Pilots develop station procedures | |||
* 4th quarter 2018/1st quarter 2019 - Begin pilot process (1 year duration) | |||
* 1st quarter 2019 - Public meeting to review initial pilot plant results | |||
© NEI 2018. All rights reserved. For use by NEI members only. 19 | |||
QUESTIONS? | |||
© NEI 2018. All rights reserved. For use by NEI members only.}} |
Revision as of 22:51, 20 October 2019
ML18176A042 | |
Person / Time | |
---|---|
Site: | Nuclear Energy Institute |
Issue date: | 06/25/2018 |
From: | Vaughn S Nuclear Energy Institute |
To: | Division of Inspection and Regional Support |
Lewin A, NRR/DIRS, 415-2259 | |
References | |
Download: ML18176A042 (20) | |
Text
An Alternate Approach to NUMARC 93-01 Chuck Sibley (Wolf Creek)
Jenna Burr (Exelon)
Jim Zapetis (Exelon)
Mike McLain (APS)
Larry Ellgass (TVA)
Roy Linthicum (PWROG)
Steve Vaughn (NEI)
June 20, 2018
© NEI 2018. All rights reserved. For use by NEI members only.
Outline
- Background
- Purpose
- Proposed Changes
- Overall Process
- Proposed Pilot Effort
- Challenges
- Project Schedule
© NEI 2018. All rights reserved. For use by NEI members only. 2
=
Background===
- Delivering the Nuclear Promise Initiative (early 2017)
- Focus resources on high safety significant functions
- Gain efficiencies in the interface between the Maintenance Rule program and other station programs
- Leverage improvements in data collection/analysis and system monitoring
© NEI 2018. All rights reserved. For use by NEI members only. 3
Purpose
- Provide members with a risk-informed framework that supports the implementation and monitoring of a maintenance effectiveness program that complies with 10 CFR 50.65, effectively and efficiently leverages utility resources, and is focused on equipment performance commensurate with safety.
© NEI 2018. All rights reserved. For use by NEI members only. 4
Proposed Changes
- Leverage the effectiveness of maintenance strategies and lessons learned from the equipment reliability process
- Address every High Safety Significant functional failure in near real time
- Trend Low Safety Significant failures in CAP and evaluate in the (a)(3) assessment
- Leverage the (a)(4) configuration risk management program (i.e.,
CDF Trending) for unavailability insights during the (a)(3) assessment
- Consider using the Birnbaum importance measure as an additional tool in determining safety significance
© NEI 2018. All rights reserved. For use by NEI members only. 5
Proposed Changes
- Perform causal evaluations commensurate with safety
- All HSS functional failures and Plant Level Events warrant a near real time causal evaluation
- A trend of low safety significant failures warrants an appropriate causal evaluation.
© NEI 2018. All rights reserved. For use by NEI members only. 6
Overall Process - The Start
- Scoping
- Safety Significance Determination
- Establish HSS and LSS functions/SSCs considering insights from the Birnbaum importance measure (evaluated during pilot)
- Establish/Implement Maintenance Strategy
- Currently well-established equipment reliability program
- (a)(1)-(a)(2) Determination
- Based on the effectiveness of the component-specific maintenance strategy
© NEI 2018. All rights reserved. For use by NEI members only. 7
Overall Process - Steady State
- (a)(1)-(a)(2) Determination
- Based on the effectiveness of the component-specific maintenance strategy
- (a)(1)
- Components that are not currently effectively controlled via effective maintenance strategy
- (a)(2)
- Components that are currently effectively controlled via effective maintenance strategy
- Perform Maintenance Strategy
- Execute the defined maintenance strategy
© NEI 2018. All rights reserved. For use by NEI members only. 8
Overall Process - Reacting to Failures - Part I
- Issue Report (IR)/Condition Report (CR) Initiated
- If the failure is associated with an HSS SSC and is either a No Maintenance Rule Functional Yes Failure (MRFF) or a Condition Yes Monitoring Event (CME) a CAP cause evaluation is performed
© NEI 2018. All rights reserved. For use by NEI members only. 9
Overall Process - Reacting to Failures - Part II Yes
- LSS failures are inputs for trending under the (a)(3)
No No assessment
- HSS failures that are not MRFF or CME are inputs to determine adverse trends under the (a)(3) assessment
- If an adverse trend is identified, a Yes CAP cause evaluation is performed
© NEI 2018. All rights reserved. For use by NEI members only. 10
Overall Process - (a)(1) Loop
- (a)(1) process is essentially the same
- Ensure that monitoring performance to goals is focused on the effectiveness of changes to the Maintenance Strategy No Yes
© NEI 2018. All rights reserved. For use by NEI members only. 11
Overall Process - CDF Trending
- Core Damage Frequency (CDF)
Trending uses the (a)(4) configuration risk management process to provide unavailability Yes data for evaluation
- Both a high-level and detailed assessment of unavailability data No
© NEI 2018. All rights reserved. For use by NEI members only. 12
Overall Process - CDF Trending
- Actual average CDF compared to present limits
- Evaluate periods of higher risk
- Could they have been avoided?
- Indications of higher than average risk
- If evaluation results in changes to maintenance strategy, evaluate for (a)(1)
© NEI 2018. All rights reserved. For use by NEI members only. 13
Overall Process - Example #1
- Component: HPSI Injection Valve
- Function: Indirect Radiation Release
- Safety Significance: High
Description:
Body to bonnet leak estimated to exceed the TRM limit. Determined to be a MRFF. Cause: failure to follow work instructions resulting in an inadequate weld.
- NUMARC 93-01: Performance criteria: 3 failures, 36 months, remained in (a)(2).
- Proposed Process: (a)(1)-(a)(2) determination would consider changes to the maintenance strategy given the ineffectiveness of maintenance (inadequate weld).
© NEI 2018. All rights reserved. For use by NEI members only. 14
Overall Process - Example #2
- Component: Radiation Monitor RU148 (Containment Monitor)
- Function: Monitor plant radiological conditions for assessment of site boundary radiation exposure levels
- Safety Significance: Low
Description:
Monitor taken offline due to excessive spiking and several ALERT alarms - due to apparent electronic interference.
- NUMARC 93-01: Third failure against performance criteria of 4 failures in 12 months - remain in (a)(2).
- Proposed Process: LSS failure would be slated for review in (a)(3)
Assessment. CAP trending or (a)(3) review could identify or determine adverse trend.
© NEI 2018. All rights reserved. For use by NEI members only. 15
Overall Process - Example #3
- Component: Station Battery
- Safety Significance: HSS
Description:
Failure is unacceptable. Use condition monitoring (i.e., CME). Specific gravity and other parameters are monitored to detect adverse trends and allow corrective actions prior to failure.
- NUMARC 93-01: Criteria: 2 CMEs in 24 months.
- Proposed Process: Each battery CME has a CAP cause evaluation performed and assess for (a)(1) - (a)(2)
© NEI 2018. All rights reserved. For use by NEI members only. 16
Proposed Pilot Effort
- At least one pilot in each Region
- Some stations will pilot the entire MR program while others will pilot just several systems
- Pilots are not required to implement the NUMARC 93-01 process in parallel for the systems being piloted
- Pilot starts in 4th quarter 2018 or 1st quarter 2019
- Continued interactions with the staff
© NEI 2018. All rights reserved. For use by NEI members only. 17
Challenges
- Change management
- Impact to other station processes
- Defining responsibilities
- Other efficiencies
- Applicability of current enforcement and inspection guidance
- 50.65 is a performance-based rule
© NEI 2018. All rights reserved. For use by NEI members only. 18
Project Schedule
- September- Workshop/Training for pilot plants
- Fall 2018 - Pilots develop station procedures
- 4th quarter 2018/1st quarter 2019 - Begin pilot process (1 year duration)
- 1st quarter 2019 - Public meeting to review initial pilot plant results
© NEI 2018. All rights reserved. For use by NEI members only. 19
QUESTIONS?
© NEI 2018. All rights reserved. For use by NEI members only.