ML19353B202

Comment on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Although Draft Closely Resembles Rev 1 to INPO 85-038,some Aspects Overly Prescriptive

ML19353B202
Person / Time
Site:	Kewaunee
Issue date:	12/01/1989
From:	Evers K WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
CON-NRC-89-142, FRN-54FR33983, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-DG1001, TASK-RE 54FR33983-00019, 54FR33983-19, NUDOCS 8912130217
Download: ML19353B202 (12)

Text

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December 1, 1989 l >

Regulatory Publications Branch

{ }l[ t Division of Freedom of information and Publications Services Office of Administration V. S. Nuclear Regulatory Commission  ;

Washington, D.C, 20555 i Gentlemen:

• Docket 50-305 i Operating License DPR-43 Kewaunee Nuclear Power Plart Commer.ts on Draf t Regelatory Guide DG-1001,

'Paintenance Programs for NJelear Power Plants"  !

Wisconsin Public Service Corporation (WPSC) participated in the formulation of the comments submitted to the NRC by the Wuclear Management and Resources Council (NUMARC) regarding the draf t regulatory guide on maintenance. Although WPSC is in general support of NUMARC's comments, we offer the attached addi-tional comments to stress our most significant areas of concern.

Attachment I contains our responses to the five questions which were included in the draf t regulatory guide cover letter. Attachment 2 contains our comments on the draft regulatory guide itself. Headings in attachment 2 correspond to headings in the draft regulatory guide.

We appreciate the opportunity to comment on this document.

Si rely, A

K. H. Evers Manager - Nuclear Power PEM/jms Attach, cc - Mr. Patrick Castleman, US NRC US NRC, Region III US NRC, Document Control Desk 0912130217 891201 PDR REGOD 01.XXX C PDR-

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4 N386.2 Attachment 1 To Letter from K. H. Evers (WPSC)

To Regulatory Publications Branch (NRC)

Dated December 1, 1989 i

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Regulatory Publications Branch (NRC) N386.3 December 1, 1989 Attachment 1 Page 1 '

1. WHAT LEVEL OF DETAIL SHOULD BE INCLUDED IN THE REGULATORY GUIDE?

I It would be appropriate to state general goals and objectives for main-tenance programs in the regulatory guide and simply endorse INP0 85-038 (Revision 1) as an acceptable means of attaining those goals. Although the draft regulatory guide closely resembles INP0 85-038 (Revision 1), there are some aspects that are overly prescriptive. In particular, administrative activities such as communication, interf acing, documentation, and data p;'o-cessing would bes?,be left to individual utility discretion.

The NRC's concern shtuld be with end results, not method of impleinentation.

Avoiding prescriptive implementation methods in the regulatory guide wculd afford utilities the opportunity to use innovetive techniques and to opti-mize resources in addressing site-specific problem areas. This would result in a more effective and efficient means for each utility to meet the NRC's and industry's mutual goal of improved maintenance. It would also allow inspectors to concentrate on end results and contributing factors to any observed deficiencies, rather than verification of detailed program ele-ments, i

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2. IS THE SCOPE OF SYSTEMS, STRUCTURES, AND COMPONENTS COVERED BY THE REGULA-l l TORY GUIDE APPROPRIATE?

1 No. The draf t regulatory guide states: "

... components in the balance of plant (B0P) whose failure would significantly impact plant safety or security are included". By including B0P in this draf t regulatory guide, j i

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- - Regulatory Publications Branch (NRC)

• December 1,1089 Attachment 1, Page 2 the NRC could potentially cross the boundaries of regulation and inappro-priately assume a management role, which rightfully belongs to each utility.

Also, "significantly" is an ambiguous term subject to interpretation. This type of wording would undoubtedly lead to inconsistent implementation and application by both the industry and the NRC.

3. WHAT CRITERIA COULD DE USED TO DETERMINE THAT A MAINTENANCE PROGRAM IS FULLY EFFECT!YE AND APDITIONAL IMPROVEMENT IS NOT ESSENTIAL FROM A SAFETV STANDPOItsT ? t I

Criterf a elobe would neither be adequate nor determinate in assessing the effectiveness of a maintensace program. Mr.intenance staff experien.:e and ,

judgement, as well as utility management support, are factors that cannot be quantified but have a large bearing on the success or failure of a program.

Tools such as performance indicators, self-assessments, INP0 assessments, SALPs, and other regulatory inspections can be used to assist in determining what areas need improvement.

4. IS IT APPROPRIATE TO USE QUANTITATIVE G0ALS, WHICH ARE DESCRIBED IN REGULATORY POSITION 3 0F THE DRAFT REGULATORY GUIDE, DIRECTED TOWARD l

ACHIEVING A SATISFACTORY LEVEL OF PERFORMANCE IN PLANT MAINTENANCE PROGRAMS CONSISTENT WITH THE LEVEL ACHIEVED BY THE TOP PERFORMING U.S. PLANTS OF l SIMILAR DESIGN?

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. .- Regulatory Publications Branch lNRC) l December 1, 1989 Attachment 1, Page 3

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i No. Individual plant variations in definitions and interpretations would '

result in misleading comparisons. Quantitative measures should only be used to trend individual plant performance and even under those circumstances have limited value. They can aid in identifying where improvement might be needed, but by no means should.they be the sole indicators in assessing performance. Quantitative goals used for regulatory purposes could lead to goal management and inadvertent de-emphasis of safe plant operation.

5. WHAT QUANTITATIVE MEASURE WOULD BE APPROPRIATE FOR SUCH G0ALS? SHOULD THEY BE AT THE PLANT LEVEL, SYSTEM LEVEL, COMP 0NENT LEVEL, OR SOME COMBINATION THEREOF?

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None would be appropriate. The only quantitative measures which have mini-mum vulnerability to misinterpretation arc number of maintenance-related Incident Reports, LER's and LCO's. But even these would have to be screened to determine whether or not they resulted from maintenance. For example, 1 timely completion of a regulatory requirement (such as MOV testing) might necessitate entering an LCO. Even though this type of LC0 is maintenance-related, it is not the result of inadequate maintenance and therefore should not have an adverse affect on a maintenance goal or indicator. It should also be noted that in many cases plant-specific Incident Reports, LERs, and l LCOs have no industry-wide meaning. Therefore, screening criteria would l l have to be developed to eliminate impertinent data from any quantitative measure used for this purpose.

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N386.4 i,o 1

Attachment 2 5

To Letter from K. H. Evers (WPSC)

P To Regulatory Publications Branch (NRC)

Dated December 1, 1989-i..  !

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4 Regulatory Publications Branch (NRC) N386.5

.. December 1, 1989 Attachment 2 Page 1 3.2 Goals .

For the reasons delineated below, it is felt that the last two paragraphs of section 3.2 can be deleted without detracting from the~ intent of the draft regu-latory guide.

Our opinion is that general quantitative maintenance goals are adequate. Goals addressing forced outage rate, lost-time accident rate, equivalent availability factor, and yearly radiation dose provide a means to establish objectives and measure performance. If goals are not attained, contributing factor assessments can be performed and program modifications implemented as necessary. Implicit in this approach is goal trending from year to year to determine if measures are effective and appropriate.

The number of goals that a plant establishes should be commensurate with the benefit tnat can be derived from each. This is not to say that specific areas can be ignored, but rather that general goals along with proper goal assessment will yield the same result more effectively and efficiently.

The key to success for any phase of plant operation is to keep everyone focused on the overall picture. Goals that are too specific can lead to symptom cures which gloss over root causes of non-attainment. They tend to detract from inno-vative thinking and promote cookbook diagnoses.

General goals, by their nature, necessitate a thorough assessment when they are not met. Conclusions cannot typically be drawn without input from all plant groups. Because all plant groups have a significant bearing on the success or

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'- Regulatory Publications Branch (NRC)

. Dec;mber 1, 1989

, Attachment 2, Page 2 l

failure of a maintenance program, their input is essential in the goal assessment process.

l Because goal assessment is an involved process, it is imperative that only meaningful goals be established. Overly prescriptive goals are usually redun-dant and tend to stifle the assessment process. They also unouly add to the administrative tracking burden which diverts resources from program enhancement F

activities and from maintenance pecformance. ,

i 4.1.1 Maintenance Management and Organization  !

Delete the sentence that reads: "The program should include requirements for i communication and interface with other organizations."

It is agreed that communication is an essential element of an effective main- 1 However, it is not an activity that can be programmatically tenance program.

mandated. Formalizing comunications would only serve to squelch or limit the frankness, effectiveness, and volume of feedback from both within and outside the maintenance organization.

4.1.2 Communication I Delete the sentence that reads: "These lines and types of communication snould be defined in the maintenance program and should serve to keep personnel at all levels cognizant of the information needed in order to effectively perform their function."

(See comments on Section 4.1.1.)

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.* Regulatory Publications Branch (NRC)

, December 1, 1989 Attachment 2, Page 3-4.3.3 Control of Radiological Exposure The following sentences from Section 4.3.3 should be deleted: " Exposure goals should be set for each major work activity and work order. When goals are exceeded, an analyses should be performed to determine the reason; this infor- i mation should then be fed back into the maintenance program to achieve future ALARA improvement."

Exposure goals are not necessary for every major work activity and work order.

• l Instead, we would recommend that the draft regulatory guide be revised to state that extensive pre-work planning should be done for all major work activities, j

This planning should include consideration and incorporation of exposure minimi- j zation techniques. Work areas shoulo be surveyed prior to commencement of the li work. Exposures should be estimated and protective clothing prescribed based on the results of the survey. Exposures should be monitored as the work progresses l and any unanticipated changes should result in evaluation and corrective actions i

as necessary.

Tnis approach focuses on protection of the worker. It also prioritires proper a

completion of the job rather than attainment of an exposure goal.

4.6.3 Predictive Maintenance Add the following sentences at the end of this section:

A separate predictive maintenance program is not necessary. These activities

-may be included as part of a preventive maintenance program.

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?AA Regulatory Publications Branch (NRC) c December 1,1989 ,

Attachment 2, Page 4 4.6.4 Maintenance Surveillance The intent of the term " maintenance surveillance" in the draft regulatory guide is not clear, We suggest deleting this section due to its ambiguity.

4.8 Recordkeeping Rather than waste valuable resources on extensive data analysis and trending, we have developed a simple, effective, and efficient method to detect equipment degradation prior to failure. Acceptance bands are established for parameters that are measured during the performance of a component's preventive maintenance procedure and/or surveillance procedure. These acceptance bands are usually conservative. Therefore, any data points that fall outside an acceptance band would initiate evaluation and any necessary corrective actions prior to equip-ment failure. Historical data are available for review and are trended when appropriate.

Section 4.8 is overly prescriptive in that it would not allow for a system as described above even though it is very effective.

5'.2.3 Maintenance Effectiveness Indicators i

Delete section 5.2.3.

1 Maintenance effectiveness indicators, based on component failure data, are not necessary. Maintenance supervisors are well aware of recurring failures through verbal communication with workers, input from other plant organizations, and their review of work requests. After a concern about a recurring failure is

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Regulatory Publications Brandh (NRC)

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Attachment 2, Page 5 '

identified, the maintenance history of the component in question is reviewed and appropriate corrective actions, such as revision of the associated preventive maintenance procedure, are initiated.

Methods are already in place to determine maintenance effectiveness. Additional administrative burdens'are not required, 5.2.4 Maintenance Process Indicators 1

We suggest the following for Maintenance Process Indicators:

1. Minor Injury Reports

2. Radiation Exposure Reports

3. Work Request Backlog

4. Overtime Reports

5. Maintenance-related LCOs

6. Mainter.snce-related Incident Reports 1

7. Maintenance-related LERs i Time to restoration is meaningless due to the varying significance, and there-fore priority, of components. Frequency of rework would not be a good indicator because it is subject to interpretation. it must be stressed that indicators are not valid for plant-to-plant or plant-to-industry average comparisons.

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6.1 Feedback l

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The following sentence in Section 6.1 snould be deleted: "The specific groups l or individuals responsible for feedback of information and the specific channels i l

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Regulatory Publications Branch (NRC)

,. December 1, 1989 Attachment 2, Page 6 of comunication for feedback should be clearly established and defined in the maintenance program."

i Feedback is an inherent part of all plant activities. It is obtained by reviewing maintenance histories and indicators, and through communication with members of the maintenance group and other departments. Again, trying to j formalize the communications would only serve to squelch or limit the frankness,  ;

i effectiveness, and volume of the feedback, j Summary i

incorporation of these comments would reduce the prescriptiveness of the draft l i

regulatory guide, enabling utilities to optimize their resources in addressing (

maintenance concer'ns. Site-specific problem areas could be addressed in a more i effective and efficient manner. Implementation methods could be selected based l on what is best suited for a given utility's program. This approach is desirable and necessary. It will ensure that all NRC concerns are addressed

while allowing utilities the flexibility to allocate resources as determined by site-specific needs. This undoubtedly would result in tne most expeditious improvement of maintenance.

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