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MRUG Update - Winter 2010 Page 1
Winter 2010 Maintenance Rule Users Group Newsletter
MRUG Update
From the Chairby Denise Boyle
The Maintenance Rule Users Group (MRUG) continues to drive toward recognition as the industry expert for MRule program implementation. I would like to take this opportunity to highlight a few of the accomplishments that move us forward in that direction:
The MRUG EOP Working Group finalized the recommended language for a ■
NUMARC 93-01 revision regarding the scoping of SSCs used in EOPs. NEI formally submitted that proposed revision to NRC for its consideration on October 1, 2009.Through the (a)(3) assessment exchange program coordinated by the ■
Advisory Board, 10 plants provided and received peer support for MRule assessments. The Advisory Board and the participants in the exchange were pleased with the results and encourage all to consider participating in the next round of exchanges.At the MRUG 2009 summer meeting, a new working group was established to consider a streamlined ■
(a)(3) assessment process. The working group, chaired by Vicky Harte of Dominion Power, developed a new approach that will likely lead to a revision of the current EPRI (a)(3) assessment guideline.
We had an opportunity to meet the new NRC points of contact for MRule at the summer meeting in Baltimore, Maryland—Steve Vaughn and Paul Bonnett along with Branch Chief Tim Kobetz. We welcome their continued participation at the MRUG meetings; the interaction with NRC staff at the meetings is highly valued by the members.
Responsibility for the MRule has transferred from the Division of Risk Assessment to the Division of the Inspection and Regional Support, and there are further organization changes afoot for NRC staff. These changes have the potential to shift the focus of the NRC staff regarding MRule. I encourage you to share your plant experiences with NRC so that we can work together to understand the industry implication of these changes.
The MRUG 2010 winter meeting is scheduled for New Orleans, Louisiana on February 2–4, 2010. The Advisory Board is working with EPRI to develop a training module on PRA for Maintenance Rule Coordinators. I look forward to seeing you at the meeting.
Denise Boyle, the MRUG Chairperson, is the Maintenance Rule/EPIX Program Manager at the Salem Generator Station. She can be reached at 856.339.2170 or [email protected].
The MRUG Update newsletter communicates issues and information important to Maintenance Rule Coordinators (MRCs) and those involved in supporting Maintenance Rule programs. Articles are provided by Maintenance Rule Users Group (MRUG) members, industry experts, regulators, and EPRI personnel. MRUG Update is published twice a year and is available to all EPRI-member utilities, not just MRUG members. It encourages communication between all Maintenance Rule personnel.
If you have suggestions for articles or features, or if you’d like to contribute an article, contact Joe Curley at 919.649.3236 or [email protected].
Denise Boyle
MRUG Update - Winter 2010 Page 2
MRUG Meets New NRC MRule Staff at 2009 Summer Meeting in Baltimore, Marylandby Joe Curley
The 2009 MRUG summer meeting was held in Baltimore, Maryland on August 4–5, 2009. The two-day meeting consisted of presentations, round table discussion, and group breakout sessions; 42 attended.
Recent organizational changes in NRR resulted in new NRC staff as primary contacts for the Maintenance Rule. Steve Vaughn and Paul Bonnet, although not unfamiliar with the Rule, are new industry contacts. Both attended both days of the meeting. Tim Kobetz, their Branch Chief, attended the first day. This gave members an opportunity to introduce themselves—and MRUG—to the industry’s new NRC contacts. It also gave all a great forum to discuss the issues that MRUG and the industry are dealing with.
Constellation Energy was the corporate sponsor for the meeting, and Jim Spina, Site VP for Calvert Cliffs, was the keynote speaker. Jim focused on equipment reliability and the role of the Maintenance Rule in achieving higher levels of reliability. He referred to the Maintenance Rule Coordinator (MRC) as a “lynch pin” for other organizations on site, particularly in Maintenance Rule’s integration with AP-913 to improve reliability.
Glen Masters (INPO), Biff Bradley and Victoria Anderson (NEI), and Steve Vaughn (NRC) gave presentations in their respective areas.
On Day 2, Denise Boyle, Frank Zurvalec, and Vicky Harte shared plant experiences from Salem, Davis-Besse, and Kewaunee, respectively.
A new working group was formed to review requirements related to (a)(3) assessments and to determine whether a reduction in the assessment effort was justified. Currently, utilities engage in extensive reviews involving teams that often require several person-weeks of effort. It is felt that current regulation and guidance might allow a much simpler approach that takes credit for the many programs and processes that have been implemented since the implementation of the Maintenance Rule.
Following are the working groups that met at the winter meeting:
Working Group D – Developing Maintenance Rule Performance Metrics ■
Working Group L – NUMARC 93-01 Revisions ■
Working Group M (New) – Optimize (a)(3) Periodic Assessment ■
Another mentoring session was held to help new MRCs benefit from the great amount of experience present at these meetings. Feedback from both mentors and attendees was positive.
As always, a highlight of the meeting was the discussion group breakout sessions in which attendees break off into smaller groups to discuss a number of topics and share experiences.
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Constellation Energy’s corporate offices in Baltimore where the 2009 summer meeting was held.
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Glen Masters (INPO) presenting the INPO update at the summer meeting.
MRUG Update - Winter 2010 Page 3
More details about the 2009 summer meeting are provided in the meeting minutes accessible through the MRUG web site.
For more information, contact Joe Curley, 919.649.3236 or [email protected].
PeeR ASSeSSOR exChANGe
NOW ACCePtING ReqUeStS FOR 2010 PeeR ASSeSSORS
If you are seeking a peer or can support an assessment in 2010, please contact your MRUG Advisory Board member or Curt Fischer ([email protected]).
2010 Winter Meeting Planned for New Orleans, Louisianathe 2010 MRUG winter meeting will be held in New Orleans on February 2–4, 2010. the three-day event will include a one-day training workshop on PRA and risk. entergy is the corporate sponsor for the meeting.
A meeting notice with more details, including reservation information, has been sent out.
MRUG Winter 2010 training Workshop and Meeting February 2–4, 2010 New Orleans, Louisiana
Meeting Sponsor: Entergy
tuesday, February 2 2010 Training Workshop: PRA, Risk, and The Maintenance Rule
Wednesday–thursday, February 3–4 MRUG Meeting
hotel Information Ritz-Carlton New Orleans 921 Canal Street New Orleans, LA 70112
Contacts for Further Information
technical Information: Marty Bridges, EPRI, 704.595.2175, [email protected] Joe Curley, the Accuro Group, 919.649.3236, [email protected]
Conference Management questions: Debbie Rouse, EPRI, 704.595.2020, [email protected]
MRUG Update - Winter 2010 Page 4
Maintenance Rule–Related NRC Documents
The following are some of the Maintenance Rule–related NRC documents that should be consulted if readers have any questions about NRC policy. All items should be available on the NRC web site (www.nrc.gov). This is a revised reprint from the Spring/Summer 2005 Newsletter.
The Maintenance Rule itself—10 CFR 50.65 ■
Statements of Consideration ■ for the several revisions of the ruleReg. Guide 1.160, Rev. 2 (endorses NUMARC 93-01, Rev. 2) ■
Reg. Guide 1.182 (endorses revised Section 11 of NUMARC 93-01) ■
NRC Baseline Inspection Procedure 71111.12 [all MR except (a)(4)] ■
NRC Baseline Inspection Procedure 71111.13 [covers (a)(4)] ■
NRC Supplemental Procedure 62709 ■
Section 7.11 of the NRC Enforcement Manual ■
NRC Inspection Manual, Chapters 0609, 0612 and 9900 ■
NUREG 1648, Lessons Learned from Maintenance Rule Baseline Inspections ■
Section 17.6 (MR) and parts 17.4 (0-RAP) of NUREG-0800, The Standard Review Plan ■
Section 17.6 (MR) and parts 17.4 (0-RAP) of RG. 1.206 COLA Guidance for 10 CFR Part 52 ■
applicantsInspection Procedure (IP) 62706.52 for Maintenance Rule program implementation inspections ■
Any other Maintenance Rule–related NUREGs, or NRC generic communications ■
Revised 9/14/05
(cut out and save)
INPO Briefs by Glen Masters, INPO
During the last half of 2009, the use of EPIX to support analysis of industry trends and identify the causes of generation losses, forced transients, and equipment performance issues has continued to expand. As a result of that expanded use, the need for complete, timely, and high quality data has increased. To support that need, we are moving to a new set of EPIX data quality metrics starting in 2010. These metrics will focus on ensuring:
That all major loss events and transients, whether human or equipment induced, are reported ■
That the median delay between the discovery date and the initial failure report filing is less than or equal to ■
50 daysThat lingering quality and completeness issues in existing reports are addressed in a timely manner ■
Draft reporting metrics for these indicators have been published alongside the existing 2009 reporting metrics on the EPIX Coordinator’s blind web page since mid-2009. While change is always difficult, we are already seeing good progress in industry implementation of the new standards.
The modification to the MSPI calculation to apply the Unreliability Index risk cap in the green as well as the white performance band is on track for mid-February 2010 delivery. This change will make MSPI more intuitive and trendable. No longer will one have a situation in which the MSPI value appears to improve with an increasing number of failures or unavailable hours. As part of this change, we will also expand the URI and UAI values to three significant digits at the NRC’s request. Along with the three significant digit format change, CDE will
MRUG Update - Winter 2010 Page 5
now calculate the final MSPI value and include it in the ROP data submittal file. This will greatly simplify the calculation of margin within CDE.
Other initiatives to look forward to in 2010 include the inclusion of computer-based training within the failure reporting interface. For infrequent failure reporters, these short instructional videos on selected sections of the failure reporting interface provide a brief (less than 5-minute) tutorial on guidance and software use. We believe this will lower user frustration and improve data quality.
More information on these and other topics will be presented at the winter meeting.
For more information, contact Glen Masters at 770.644.8746 or [email protected].
NeI Updateby Victoria Anderson, NeI
At the last MRUG meeting, the working group tasked with developing new EOP scoping criteria guidance to reduce the potential for misunderstandings and issuance of unnecessary violations proposed some new language for Section 8.3.1.3 of NUMARC 93-01. Since then, NEI has been communicating with NRC to work toward formal endorsement of this language. Although some further revisions may be necessary to reach this formal endorsement, we are confident that a mutually agreeable revision to this section can be achieved. Based on communications with NRC, NEI anticipates a public meeting on the EOP scoping language as well as other Maintenance Rule topics in early 2010, and we will provide an update on this meeting at the February MRUG meeting.
One topic that we anticipate covering in significant detail at the public meeting is the treatment of risk and external events risk in (a)(4) assessments. Because implementation guidance as currently endorsed by NRC addresses internal events risk only, utilities need not consider the impact of fire and external events risk as part of their (a)(4) assessments at this time. However, we have found that several utilities developed programs and procedures to qualitatively assess configuration-specific risk from non-internal events initiators. We will be evaluating insights from the implementation of such programs and procedures as part of our planned update to the previously developed supplemental industry guidance on qualitative consideration of fire risk in (a)(4) assessments.
We will provide more information about this effort at the February meeting.
For more information, contact Victoria Anderson at 202.739.8101 or [email protected].
eOP Working Group Updateby Curt Fischer
At the August MRUG meeting, the EOP Working Group finalized proposed wording changes to NUMARC 93-01 to address the EOP scoping concerns. In early October, NEI officially submitted the wording to NRC and requested a public meeting to discuss the proposed revisions with the stakeholders. The NRC recently responded to the submittal and provided comments (see “NRC Corner” for a copy of the NRC response) and agreed with an open discussion at a public meeting expected in early 2010.
The staff also expressed the desire to include discussion on risk for external events and shutdown/low power operation as well as unavailability monitoring. As previously identified by NEI, tying these issues with the EOP scoping issue can be expected to impact the timeliness of resolution of the EOP issue. I hope to have more information no later than the next meeting.
For more information, contact Curt Fischer at 315.349.2806 or [email protected].
MRUG Update - Winter 2010 Page 6
NRC Cornerby Steve Vaughn (NRC)
For this newsletter, it was decided to provide the MRUG with a recent letter from NRC to NEI. The letter is in response to a recent letter sent by NEI regarding EOP scoping and other Maintenance Rule issues.
B. Bradley 2
November 4, 2009
Mr. Biff Bradley, Director Risk Assessment Nuclear Generation Division Nuclear Energy Institute SUBJECT: PROPOSED REVISION TO LANGUAGE SCOPING OF EQUIPMENT USED IN EMERGENCY
OPERATING PROCEDURES (EOP) IN NUMARC 93-01, “INDUSTRY GUIDELINE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS”
Dear Mr. Bradley: As requested in your letter dated October 1, 2009, we have reviewed the proposed revision to the EOP scoping criteria guidance in NUMARC 93-01. There are some portions of the proposed guidance which we request clarification on, and we would like to discuss the issues during a public meeting. Please be prepared to discuss any specific examples that you believe supports the wording in the proposed revision. The items we would like to discuss include:
• The proposed revision limits systems structures or components (SSCs) used in Emergency Operating Procedures (EOPs) to “only installed equipment.” We believe this potentially removes equipment that should be scoped under the rule.
• The phrase “SSCs used in plant EOPs” is quoted and defined in the proposed revision. This phrase is part of exact wording that is used in Title 10 of the Code of Federal Regulations (10 CFR), part 50.65(b)(2)(i). Quoting this phrase implies an attempt to define the meaning of the rule rather than to clarify an earlier portion of the NUMARC guidance. The staff also feels that the proposed clarifying language of “essential to mitigation” is less conservative than the existing language of “must add significant value to the mitigation function.”
• When multiple means of achieving an implied function are available, the proposed revision states that only one means needs to be included in the scope. It is not clear to the staff how it would be determined which means would be included and why it is acceptable to exclude the other means.
• Regarding the note at the end of the proposed revision – the basis for allowing exclusion of SSCs from the scope of the rule when it can be “demonstrated that a failure of the SSC will not cause a significant change in the expectation of success in accomplishing the EOP mitigating function” is not clear to the staff.
We would also like to discuss the agency’s plan to address some outstanding issues with regard to maintenance rule implementation and guidance. These include:
• The treatment of external events in risk assessments • Management of risk during shutdown or low power operations • Monitoring of unavailability during shutdown My staff will be contacting you in the near future to arrange a date for a public meeting. If you have any questions, please feel free to contact me at 301-415-1932 or [email protected].
Sincerely,
Timothy J. Kobetz, Chief Reactor Inspection Branch Division of Inspection and Regional Support
Office of Nuclear Reactor Regulation
MRUG Update - Winter 2010 Page 7
In addition, the NRC has a new staff member assigned to the Maintenance Rule—Jeremy Bowen, in Tim Kobetz’s branch (Reactor Inspection Branch). Our division (Division of Inspection and Regional Support) went through a reorganization, and Paul Bonnett and I were moved to the Performance Assessment Branch but retained our involvement with the Maintenance Rule. The Reactor Inspection and Performance Assessment branches both provide support for the Reactor Oversight Process (ROP).
Here is all of our contact information:
Jeremy Bowen, 301.415.3471, [email protected] Paul Bonnett, 301.415.4107, [email protected] Steve Vaughn, 301.415.3640, [email protected] Tim Kobetz, 301.415.1932, [email protected]
What Is the MRUG?
The Maintenance Rule Users Group (MRUG) was established by EPRI and is supported by national and international member utilities to provide a forum for information exchange among utilities through periodic meetings, an interactive web site, and routine day-to-day communication. Participants are able to have their individual questions answered by a large targeted population of Maintenance Rule experts—the Maintenance Rule Coordinators from EPRI-member utilities. In addition, this information exchange among utilities, and between utilities and EPRI, provides a vehicle to resolve technical issues that arise during ongoing plant operation and continuing regulatory inspection.
As the membership directs, EPRI facilitates the development of technical guides and the documentation of good practices that can reduce costs of implementation, increase consistency among utilities, leverage Maintenance Rule activities to improve plant performance, and reduce vulnerability to regulatory compliance issues. Technical guides and other users group products are selected for development by the group membership. Resources come from subcommittees of MRUG, EPRI staff, or contractors as appropriate.
EPRI sponsors two workshop/meetings each year, which members are encouraged to attend. Each plant site is allowed two attendees from the plant or corporate staff. Nonmembers are invited to attend for a small fee that can be applied toward annual membership. NEI, INPO, and NRC are invited to participate in resolving issues raised by MRUG as well as to communicate progress and issues regarding Maintenance Rule activities. Participants clearly want MRUG to work with NEI, INPO, and NRC to achieve consistent expectations among utilities and across NRC regions. They also want MRUG to help identify and avoid unjustified ratcheting of requirements and expectations.
The MRUG web site, operated as part of www.epri.com, serves not only as a forum for information exchange, but also as a convenient location to post solutions to problems or issues. Instructions for accessing epri.com, the MRUG web site, and the MRUG Collaboration web site are provided in this newsletter.
MRUG also provides a way to address solutions to generic technical issues. High-priority issues identified by the participants have included guidance on (a)(3) assessments, guidance on run-to-failure justification, and clarification of unavailability times for standby equipment. Another useful role is the identification of best practices for such issues as:
Balancing availability and reliability ■
Monitoring structures ■
Improving timeliness of (a)(1) actions ■
Coordinating with EPIX ■
Using condition monitoring for performance criteria ■
MRUG Update - Winter 2010 Page 8
The purpose of these efforts is not to bring plants to a single approach, but rather to identify cost-effective options.
For more information on MRUG activities, meetings, or membership, contact Marty Bridges, 704-595-2672, [email protected], or Joe Curley, 919.649.3236, [email protected].
how to Obtain an ePRI ID and Password
To obtain an EPRI ID and password so you can access the Maintenance Rule Users Group (MRUG) web site, follow these steps:
1. Go to www.epri.com. The Welcome screen asks for your user name and password.
2. Click on “Register Now.” The next screen is Create an Account.
3. Follow the instructions; you should receive your ID and password within three working days.
If you have any problems, contact Deborah Rouse at 704-595-2520 or [email protected].
MRUG Update - Winter 2010 Page 9
how to Access the MRUG Web Site
After you have your EPRI ID and password, use the following steps to access the MRUG web site:
1. Go to www.epri.com.
2. Under “Portfolio Overviews,” click on Nuclear.
3. Under “Subscriber Websites,” click on MRUG—Maintenance Rule User Group.
While you are at the MRUG web site, bookmark it for direct access next time.
Remember that, although many features of the MRUG web site (including publications and contact lists) are available only to MRUG-member utilities, all EPRI-member utilities have access to membership information and upcoming meetings. So if you are a member of MRUG, scan the web site and sample its features. If you are not an MRUG member, review Justification for Utility Participation and consider the benefits—and of course, share this information with your management.
If you have any problems, contact Deborah Rouse at 704-595-2520 or [email protected].
1020599 Winter 2010
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