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=Text=
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{{#Wiki_filter:© NEI 2018. All rights reserved. For use by NEI members only.
{{#Wiki_filter:An Alternate Approach to NUMARC 93-01 Chuck Sibley (Wolf Creek)
An Alternate Approach to NUMARC 93
-01 Chuck Sibley (Wolf Creek)
Jenna Burr (Exelon)
Jenna Burr (Exelon)
Jim Zapetis (Exelon)
Jim Zapetis (Exelon)
Line 24: Line 22:
Roy Linthicum (PWROG)
Roy Linthicum (PWROG)
Steve Vaughn (NEI)
Steve Vaughn (NEI)
June 20, 2018 DRAFT 6/13/18  
June 20, 2018
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18


© NEI 2018. All rights reserved. For use by NEI members only.
Outline
Outline *Background
* Background
*Purpose *Proposed Changes  
* Purpose
*Overall Process
* Proposed Changes
*Proposed Pilot Effort
* Overall Process
*Challenges
* Proposed Pilot Effort
*Project Schedule 2  DRAFT 6/13/18  
* Challenges
* Project Schedule
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 2


© NEI 2018. All rights reserved. For use by NEI members only.
===
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. DRAFT 6/13/18 3


===Background===
Purpose
*Delivering the Nuclear Promise Initiative (early 2017)
* Provide utilities 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.
*Focus resources on high safety significant functions
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 4
*Gain efficiencies in the interface between the Maintenance Rule program and other station programs
*Leverage improvements in data collection/analysis and system monitoring 3  DRAFT 6/13/18  


© NEI 2018. All rights reserved. For use by NEI members only.
Proposed Changes
Purpose *Provide utilities with a risk
* Focus energy on determining the effectiveness of the maintenance strategy, not whether performance criteria are met
-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.
          - Address every High Safety Significant functional failure in near real time
4  DRAFT 6/13/18  
          - 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. DRAFT 6/13/18       5


© NEI 2018. All rights reserved. For use by NEI members only.
Proposed Changes
Proposed Changes
*Focus energy on determining the effectiveness of the maintenance strategy, not whether performance criteria are met -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
* Perform causal evaluations commensurate with safety
-Leverage the (a)(4) configuration risk management program (i.e., CDF Trending) for unavailability insights during the (a)(3) assessment
          - A trend of low safety significant failures warrants an appropriate causal evaluation.
*Consider using the Birnbaum importance measure as an additional tool in determining safety significance 5  DRAFT 6/13/18  
          - All HSS functional failures and Plant Level Events warrant a near real time causal evaluation
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18   6


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - The Start
Proposed Changes
* Scoping Establish/Implement Maintenance
*Perform causal evaluations commensurate with safety
* Safety Significance Determination Scoping Strategy      - Establish HSS and LSS functions/SSCs considering insights from the Birnbaum importance measure (evaluated during pilot)
-A trend of low safety significant failures warrants an appropriate causal evaluation.
* Establish/Implement Maintenance Safety                                                      Strategy (a)(1) - (a)(2)
-All HSS functional failures and Plant Level Events warrant a near real time causal evaluation 6  DRAFT 6/13/18  
Significance Determination      - Currently well-established Determination                                                            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.       DRAFT 6/13/18                           7


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - Steady State Establish/Implement                  Perform    *  (a)(1)-(a)(2) Determination Maintenance                    Maintenance    -   Based on the effectiveness of the Strategy                    Strategy          component-specific maintenance strategy
Overall Process - The Start *Scoping *Safety Significance Determination
                                                                          *  (a)(1)
-Establish HSS and LSS functions/SSCs considering insights from the Birnbaum importance measure (evaluated during pilot)
                                                                              -   Components that are not currently effectively controlled via preventive (a)(1) - (a)(2)                                     maintenance (a)(1)
*Establish/Implement Maintenance Strategy -Currently well
Determination                     (a)(2)    * (a)(2)
-established equipment reliability program
                                                                              -  Components that are currently effectively controlled via preventive maintenance
  *(a)(1)-(a)(2) Determination
* Perform Maintenance Strategy
-Based on the effectiveness of the component-specific maintenance strategy  ScopingSafety Significance DeterminationEstablish/Implement  Maintenance Strategy (a)(1) - (a)(2) Determination 7 DRAFT 6/13/18  
                                                                              -  Execute the planned preventive maintenance as described via the maintenance strategy
© NEI 2018. All rights reserved. For use by NEI members only.              DRAFT 6/13/18                               8


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - Reacting to Failures - Part I IR/CR for Scoped
Overall Process - Steady State
* Issue Report (IR)/Condition SSC          Report (CR) Initiated
*(a)(1)-(a)(2) Determination
* Plant Level Events (PLEs) receive Yes                      a CAP cause evaluation Plant Level
-Based on the effectiveness of the component-specific maintenance strategy *(a)(1) -Components that are not currently effectively controlled via preventive maintenance
* If the failure is associated with an CAP Cause Event?
*(a)(2) -Components that are currently effectively controlled via preventive maintenance
Evaluation                                                      HSS function and is either a No    Maintenance Rule Functional Yes                                                                  failure (MRFF) or a Condition Yes                        Monitoring Event (CME) a CAP MRFF or HSS?        cause evaluation is performed CME?
  *Perform Maintenance Strategy
© NEI 2018. All rights reserved. For use by NEI members only.            DRAFT 6/13/18                         9
-Execute the planned preventive maintenance as described via the maintenance strategy Establish/Implement  Maintenance Strategy (a)(1) - (a)(2) DeterminationPerform Maintenance Strategy (a)(2)(a)(1)8  DRAFT 6/13/18  


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - Reacting to Failures - Part II MRFF or                  Yes HSS?
Overall Process - Reacting to Failures  
* LSS failures are inputs for CME?
- Part I *Issue Report (IR)/Condition Report (CR) Initiated
trending under the (a)(3)
*Plant Level Events (PLEs) receive a CAP cause evaluation
No                No        assessment
*If the failure is associated with an HSS function and is either a Maintenance Rule Functional failure (MRFF) or a Condition Monitoring Event (CME) a CAP cause evaluation is performed IR/CR for Scoped SSCPlant Level Event?HSS?MRFF or CME?CAP Cause EvaluationYes Yes Yes No 9  DRAFT 6/13/18  
* HSS failures that are not MRFF or CAP Cause                                                        CME are inputs for trending under Evaluation                                                        the (a)(3) assessment
* If a trend is identified, a CAP cause evaluation is performed Yes Trend                                    (a)(3) Assessment Identified?
© NEI 2018. All rights reserved. For use by NEI members only.          DRAFT 6/13/18                   10


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - (a)(1) Loop (a)(1)                    (a)(1) - (a)(2)
Overall Process - Reacting to Failures
Determination
- Part II *LSS failures are inputs for trending under the (a)(3) assessment
                                                                                * (a)(1) process is essentially the same Establish
*HSS failures that are not MRFF or CME are inputs for trending under the (a)(3) assessment
* Ensure that monitoring Corrective                                      performance to goals is focused Actions and Goals                                        on the effectiveness of changes to the Maintenance Strategy Monitor Performance to Goals No                      Yes Perform Cause Are Goals Met?
  *If a trend is identified, a CAP cause evaluation is performed HSS?MRFF or CME?(a)(3) AssessmentTrend Identified
Evaluation
?CAP Cause EvaluationYes Yes No No 10  DRAFT 6/13/18  
  © NEI 2018. All rights reserved. For use by NEI members only.                  DRAFT 6/13/18                     11


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - CDF Trending CAP Cause
Overall Process - (a)(1) Loop
* Core Damage Frequency (CDF)
*(a)(1) process is essentially the same *Ensure that monitoring performance to goals is focused on the effectiveness of changes to the Maintenance Strategy (a)(1) - (a)(2) Determination (a)(1)Establish Corrective Actions and GoalsMonitor Performance to GoalsAre Goals Met
Evaluation                                                      Trending uses the (a)(4) configuration risk management process to provide unavailability Yes                                                                  data for trending Trend                                  (a)(3) Assessment Identified?
?Perform Cause Evaluation No Yes 11  DRAFT 6/13/18  
* Both a holistic and detailed suite of unavailability data No CDF Trending
© NEI 2018. All rights reserved. For use by NEI members only.                DRAFT 6/13/18                       12


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - CDF Trending
Overall Process - CDF Trending
*Core Damage Frequency (CDF) Trending uses the (a)(4) configuration risk management process to provide unavailability data for trending
* Actual average CDF compared to present limits
*Both a holistic and detailed suite of unavailability data (a)(3) AssessmentTrend Identified
* Evaluate periods of higher risk
?CAP Cause EvaluationYes No CDF Trending 12  DRAFT 6/13/18  
                                                                        - 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. DRAFT 6/13/18                       13


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - (a)(1) - (a)(2) Determination
Overall Process
* If (a)(1) goals are met or there is a (a)(1)
- CDF Trending *Actual average CDF compared to present limits *Evaluate periods of higher risk
(a)(1) - (a)(2)                (a)(2)    CAP cause evaluation performed Determination                              resulting from a PLE, HSS functional failure or CME, or identified trend from the (a)(3) assessment, then an (a)(1)-(a)(2)
-Could they have been avoided? -Indications of higher than average risk
Yes                                              determination is performed CAP Cause Are Goals Met?                                          Evaluation
-If evaluation results in changes to maintenance strategy, evaluate for (a)(1) 13  DRAFT 6/13/18  
* Based on the (a)(1)-(a)(2) determination, the SSC is either placed in (a)(1) or (a)(2)
© NEI 2018. All rights reserved. For use by NEI members only.               DRAFT 6/13/18                       14


© NEI 2018. All rights reserved. For use by NEI members only.
Overall Process - Example #1
Overall Process - (a)(1) - (a)(2) Determination
* Component: HPSI Injection Valve
*If (a)(1) goals are met or there is a CAP cause evaluation performed resulting from a PLE, HSS functional failure or CME, or identified trend from the (a)(3) assessment, then an (a)(1)
* Function: Indirect Radiation Release
-(a)(2) determination is performed
* Safety Significance: High
*Based on the (a)(1)-(a)(2) determination, the SSC is either placed in (a)(1) or (a)(2)
  *   
CAP Cause EvaluationAre Goals Met
?(a)(1) - (a)(2) Determination (a)(1)(a)(2)Yes 14 DRAFT 6/13/18


© NEI 2018. All rights reserved. For use by NEI members only.
== Description:==
Overall Process
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.
- Example #1
* NUMARC 93-01: Performance criteria: 3 failures, 36 months, remained in (a)(2).
*Component: HPSI Injection Valve
* Proposed Process: (a)(1)-(a)(2) determination would consider changes to the maintenance strategy given the ineffectiveness of maintenance (inadequate weld).
*Function: Indirect Radiation Release
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 15
*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).
15  DRAFT 6/13/18  


© NEI 2018. All rights reserved. For use by NEI members only.
Proposed Pilot Effort
Proposed Pilot Effort
*At least one pilot in each Region
* At least one pilot in each Region
*Some stations will pilot the entire MR program while others will pilot just several systems
* Some stations will pilot the entire MR program while others will pilot just several systems
*Pilots will not be implementing the NUMARC 93
* Pilots will not be implementing the NUMARC 93-01 process in parallel for the systems being piloted
-01 process in parallel for the systems being piloted
* Pilot starts in 4th quarter 2018 or 1st quarter 2019
*Pilot starts in 4 th quarter 2018 or 1 st quarter 2019 16  DRAFT 6/13/18  
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 16


© NEI 2018. All rights reserved. For use by NEI members only.
Challenges
Challenges
*Change management
* Change management
*Applicability of current enforcement and inspection guidance *50.65 is a performance
* Applicability of current enforcement and inspection guidance
-based rule 17  DRAFT 6/13/18  
* 50.65 is a performance-based rule
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 17


© NEI 2018. All rights reserved. For use by NEI members only.
Project Schedule
Project Schedule
*September- Workshop/Training for pilot plants *Fall 2018  
* September- Workshop/Training for pilot plants
- Pilots develop station procedures
* Fall 2018 - Pilots develop station procedures
*4 th quarter 2018/1 st quarter 2019  
* 4th quarter 2018/1st quarter 2019 - Begin pilot process (1 year duration)
- Begin pilot process (1 year duration) 18  DRAFT 6/13/18  
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 18


© NEI 2018. All rights reserved. For use by NEI members only.
© NEI 2018. All rights reserved. For use by NEI members only.
QUESTIONS?
QUESTIONS?
DRAFT 6/13/18}}
© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18}}

Revision as of 23:18, 20 October 2019

2018-6-20 Public Meeting - NEI Draft Presentation - an Alternate Approach to NUMARC 93-01
ML18166A093
Person / Time
Site: Nuclear Energy Institute
Issue date: 06/20/2018
From: Burr J, Ellgass L, Linthicum R, Mclain M, Sibley C, Vaughn S, Zapetis J
Arizona Public Service Co, Exelon Corp, Nuclear Energy Institute, PWR Owners Group, Tennessee Valley Authority, Wolf Creek
To:
Office of Nuclear Reactor Regulation
Lewin A, NRR/DIRS, 415-2259
References
Download: ML18166A093 (19)
v • d • e


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. DRAFT 6/13/18

Outline

  • Background
  • Purpose
  • Proposed Changes
  • Overall Process
  • Proposed Pilot Effort
  • Challenges
  • Project Schedule

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 2

=

Background===

  • Delivering the Nuclear Promise Initiative (early 2017)
  • Focus resources on high safety significant functions
  • Leverage improvements in data collection/analysis and system monitoring

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 3

Purpose

  • Provide utilities 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. DRAFT 6/13/18 4

Proposed Changes

  • Focus energy on determining the effectiveness of the maintenance strategy, not whether performance criteria are met

- 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. DRAFT 6/13/18 5

Proposed Changes

  • Perform causal evaluations commensurate with safety

- A trend of low safety significant failures warrants an appropriate causal evaluation.

- All HSS functional failures and Plant Level Events warrant a near real time causal evaluation

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 6

Overall Process - The Start

  • Scoping Establish/Implement Maintenance
  • Safety Significance Determination Scoping Strategy - Establish HSS and LSS functions/SSCs considering insights from the Birnbaum importance measure (evaluated during pilot)
  • Establish/Implement Maintenance Safety Strategy (a)(1) - (a)(2)

Significance Determination - Currently well-established Determination 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. DRAFT 6/13/18 7

Overall Process - Steady State Establish/Implement Perform * (a)(1)-(a)(2) Determination Maintenance Maintenance - Based on the effectiveness of the Strategy Strategy component-specific maintenance strategy

  • (a)(1)

- Components that are not currently effectively controlled via preventive (a)(1) - (a)(2) maintenance (a)(1)

Determination (a)(2) * (a)(2)

- Components that are currently effectively controlled via preventive maintenance

  • Perform Maintenance Strategy

- Execute the planned preventive maintenance as described via the maintenance strategy

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 8

Overall Process - Reacting to Failures - Part I IR/CR for Scoped

  • Issue Report (IR)/Condition SSC Report (CR) Initiated
  • Plant Level Events (PLEs) receive Yes a CAP cause evaluation Plant Level
  • If the failure is associated with an CAP Cause Event?

Evaluation HSS function and is either a No Maintenance Rule Functional Yes failure (MRFF) or a Condition Yes Monitoring Event (CME) a CAP MRFF or HSS? cause evaluation is performed CME?

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 9

Overall Process - Reacting to Failures - Part II MRFF or Yes HSS?

  • LSS failures are inputs for CME?

trending under the (a)(3)

No No assessment

  • HSS failures that are not MRFF or CAP Cause CME are inputs for trending under Evaluation the (a)(3) assessment
  • If a trend is identified, a CAP cause evaluation is performed Yes Trend (a)(3) Assessment Identified?

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 10

Overall Process - (a)(1) Loop (a)(1) (a)(1) - (a)(2)

Determination

  • (a)(1) process is essentially the same Establish
  • Ensure that monitoring Corrective performance to goals is focused Actions and Goals on the effectiveness of changes to the Maintenance Strategy Monitor Performance to Goals No Yes Perform Cause Are Goals Met?

Evaluation

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 11

Overall Process - CDF Trending CAP Cause

  • Core Damage Frequency (CDF)

Evaluation Trending uses the (a)(4) configuration risk management process to provide unavailability Yes data for trending Trend (a)(3) Assessment Identified?

  • Both a holistic and detailed suite of unavailability data No CDF Trending

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 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. DRAFT 6/13/18 13

Overall Process - (a)(1) - (a)(2) Determination

  • If (a)(1) goals are met or there is a (a)(1)

(a)(1) - (a)(2) (a)(2) CAP cause evaluation performed Determination resulting from a PLE, HSS functional failure or CME, or identified trend from the (a)(3) assessment, then an (a)(1)-(a)(2)

Yes determination is performed CAP Cause Are Goals Met? Evaluation

  • Based on the (a)(1)-(a)(2) determination, the SSC is either placed in (a)(1) or (a)(2)

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 14

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. DRAFT 6/13/18 15

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 will not be implementing the NUMARC 93-01 process in parallel for the systems being piloted
  • Pilot starts in 4th quarter 2018 or 1st quarter 2019

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 16

Challenges

  • Change management
  • 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. DRAFT 6/13/18 17

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)

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18 18

QUESTIONS?

© NEI 2018. All rights reserved. For use by NEI members only. DRAFT 6/13/18

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