**NRC INSPECTION MANUAL** IIPB

INSPECTION PROCEDURE 62706

MAINTENANCE RULE

PROGRAM APPLICABILITY: 2515

62706‑01 INSPECTION OBJECTIVE

To verify the implementation of 10 CFR 50.65, Athe maintenance rule@
(Ref. 1).

62706‑02 INSPECTION REQUIREMENTS

[Verify Implementation of the Maintenance Rule]{.underline}. Perform the
following reviews to verify the licensee\'s implementation of the
maintenance rule (i.e., the rule), following the guidance of Nuclear
Management and Resources Council (NUMARC) 93-01, AIndustry Guideline for
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,@
(Ref. 2).

02.01 [Goal Setting and Monitoring, 50.65(a)(1)]{.underline}. Verify
that the licensee has implemented goal setting and monitoring as
required by paragraph (a)(1) of the rule. The licensee is required by
the rule to perform the following:

a.  Monitor the performance or condition of structures, systems, and
    components (SSCs) against licensee-established goals, in a manner
    sufficient to provide reasonable assurance that such SSCs, as
    defined in 10 CFR 50.65(b), are capable of fulfilling their intended
    functions.

b.  Establish goals commensurate with safety and, where practical, take
    into account industry-wide operating experience.

c.  Take appropriate corrective action when the performance or condition
    of an SSC does not meet established goals.

02.02 [Preventive Maintenance, 50.65(a)(2)]{.underline}. For those SSCs
that are within the scope of the rule but are not monitored under
paragraph (a)(1) of the rule, verify that the licensee has demonstrated
the following:

a.  Performance or condition of a SSC is being effectively controlled
    through the performance of appropriate preventive maintenance such
    that the SSC remains capable of performing its intended function;
    or,

b.  The SSC is inherently reliable and has low safety significance;
    therefore, preventive maintenance may not be required (i.e., perform
    corrective maintenance only).

c.  The SSCs that provide little or no contribution to system safety
    function could be allowed to run to failure (i.e., perform
    corrective maintenance rather than preventive maintenance).

02.03 [Periodic Evaluation, 50.65(a)(3)]{.underline}. Verify that the
licensee is performing the periodic evaluations and safety assessments
required by paragraph (a)(3) of the maintenance rule.

a.  The licensee shall evaluate performance and condition monitoring
    activities, associated goals, and preventive maintenance activities
    at least every refueling cycle, provided that the interval between
    evaluations does not exceed 24 months. The evaluations shall
    consider industry-wide operating experience, where practical.

b.  The licensee shall make adjustments where necessary to ensure that
    the objective of preventing failures of SSCs through maintenance is
    appropriately balanced against the objective of minimizing
    unavailability of SSCs due to monitoring or preventative maintenance
    activities.

See Inspection Procedure 71111.12, AMaintenance Rule Implementation.@

02.04 [Safety Assessments Before Performing Maintenance,
50.65(a)(4)]{.underline}. Verify that the licensee assesses and manages
increases in risk before performing maintenance activities required by
paragraph (a)(4) of the maintenance rule.

See Inspection Procedure 71111.13, AMaintenance Risk Assessments and
Emergent Work Control.@

02.05 [Scope of the Rule, 50.65(b)]{.underline}. Verify that the
licensee has identified those SSCs that are required to be within the
scope of the maintenance rule, as defined in paragraph 50.65(b) of the
rule.

62706‑03 INSPECTION GUIDANCE

[General Guidance]{.underline}

[Inspection Requirements]{.underline}. All inspection requirements
listed in Section 02 do not have to be performed during each inspection.
NRC management may decide that specific inspection requirements be
reviewed for implementation of the maintenance rule based on plant
performance indicating a potential weakness in a particular inspection
requirement. In addition, NRC management may decide to select specific
inspection requirements to be performed based on the allocation of
resources available. The items selected for review will depend on the
intended scope of the inspection and the resources allotted for the
inspection. In addition, inspectors should also note that despite the
fact that items selected for review are listed under inspection
requirements, they may not be explicitly stated in the maintenance rule.
Rather, these items may be derived from Regulatory Guide 1.160,
AMonitoring the Effectiveness of Maintenance at Nuclear Power Plants,@
(Ref 3) or NUMARC 93-01, which are optional guidance documents and,
therefore, would not apply to those licensees who implement the rule
using other methods.

[Implementation Guidance]{.underline}. Except when the licensee proposes
an alternate method for complying with specified portions of the
maintenance rule, the methods described in Regulatory Guide 1.160 will
be used to evaluate the effectiveness of maintenance activities of
licensees who are required to comply with the maintenance rule.
Regulatory Guide 1.160 endorses NUMARC 93‑01 and provides methods
acceptable to the NRC for complying with the maintenance rule. The
inspector should also be aware that licensees may use methods other than
those described in Regulatory Guide 1.160 and NUMARC 93‑01 to satisfy
the requirements of the maintenance rule. Where other methods are used,
the licensee must demonstrate that those methods satisfy the
requirements of the rule.

[Requirements vs. Acceptable Methods]{.underline}. The information
provided in the specific guidance section of this procedure was derived
from information contained in the maintenance rule, the statements of
consideration (SOC) for the rule (Ref. 4), Regulatory Guide 1.160, and
the industry guideline, NUMARC 93‑01. Reference was made to the source
document, where possible, in order to help the inspector differentiate
between the regulatory requirements and recommendations. In general,
anything that is stated in the rule itself is a requirement. The SOC
does not contain requirements but does contain information that could be
used to clarify the intent of the requirements. Information derived from
Regulatory Guide 1.160 and its endorsed industry guideline, NUMARC
93-01, provide acceptable methods for complying with the rule, but they
are not regulatory requirements. If the licensee chooses not to
implement the maintenance rule in accordance with the regulatory guide
and the industry guideline, then the licensee must demonstrate that the
alternate methods satisfy the requirements of the rule.

Most licensees have implemented the maintenance rule using the guidance
contained in NUMARC 93-01. However, licensees have also used other
methods that the NRC staff has found acceptable for implementing the
rule. Inspectors should determine whether the licensee has taken
exceptions to NUMARC 93-01 and has documented justifications for these
exceptions. Exceptions to NUMARC 93-01 shall meet the requirements of
the rule.

[Decommissioned Plants]{.underline}. Manual Chapter 2561,
ADecommissioning Power Reactor Inspection Program,@ provides guidance
and requirements for the inspection of maintenance and surveillance
activities at power reactors that have submitted 10 CFR 50.82(a)(1)
certifications. Inspectors should use Inspection Procedure 62801,
AMaintenance and Surveillance at Permanently Shutdown Reactors,@ when
inspecting maintenance rule requirements at power reactors with
50.82(a)(1) certifications.

[Maintenance Rule Guideline Book]{.underline}. The Quality Assurance and
Maintenance Branch (IQMB) compiled a Maintenance Rule Guideline Book
which contains NRC and industry guidance on acceptable methods to
implement the individual requirements of the maintenance rule. The
inspection requirements for the maintenance rule are listed in Sections
2.01 through 2.05 of this procedure. The inspector should refer to the
Maintenance Rule Guideline Book for additional inspection guidance. The
Maintenance Rule Guideline Book includes information such as:

-   10 CFR 50.65, ARequirements for Monitoring the Effectiveness of
    Maintenance at Nuclear Power Plants@

-   Statements of Consideration for 10 CFR 50.65, Federal Register, Vol.
    56, No. 132, July 10, 1991, pages 31306C31323 (56 FR. 31306)

-   10 CFR 50.65(a)(1), ARule Change, Monitoring the Effectiveness of
    Maintenance at Plants in a Decommissioning Status@ Federal Register,
    Vol. 61, No 146, July 29,1996, pages 39278, 39288 & 39301 (61 FR
    39278)

-   Statements of Consideration for 10 CFR 50.65(a)(4), Federal
    Register, Vol 64, No. 137, dated July 19, 1999, pages 38551-38557
    (64 FR 38551)

-   Regulatory Guide 1.160, AMonitoring the Effectiveness of Maintenance
    at Nuclear Power Plants@

-   Regulatory Guide 1.182, AAssessing and Managing Risk Before
    Maintenance Activities at Nuclear Power Plants, dated May, 2000

-   NUMARC 93-01, AIndustry Guideline for Monitoring the Effectiveness
    of Maintenance at Nuclear Power Plants@

-   Inspection Procedure (IP) 62706, AMaintenance Rule.@

-   Inspection Procedure (IP) 62707, AMaintenance Observations,@ April
    22, 1996

-   IP 71111, Attachment 12, AMaintenance Rule Implementation.@

-   IP 71111, Attachment 13, AMaintenance Risk Assessments and Emergent
    Work Control.@

-   Maintenance Rule Enforcement Guidance

-   Simplified Maintenance Rule Flow Chart

[Historical Information]{.underline}. In addition to the Maintenance
Rule Guideline Book, historical information is contained in NUREG-1526,
ALessons Learned From Early Implementation of the Maintenance Rule at
Nine Nuclear Power Plants,@ dated June 1995 (Ref. 6). Temporary
Instruction 2515/126, \"Evaluation of On-Line Maintenance,\" was used by
inspectors to verify the level of utility control for on-line
maintenance activities while at power.

[Lessons Learned from Maintenance Rule Baseline
Inspections]{.underline}. Licensees are expected to have reviewed
information contained in NUREG-1648, ALessons Learned from Maintenance
Rule Baseline Inspections,@ dated October 1999 (Ref 7). This document
contains information on unique and diverse methods licensees used to
implement the maintenance rule that went beyond the guidance contained
in the documents noted above. Licensees can use this information to
improve site-specific maintenance rule programs.

[Specific Guidance]{.underline}

03.01 [Goal Setting and Monitoring, 10 CFR 50.65(a)(1)]{.underline}. The
licensee is required to set goals and monitor the performance or
condition of those SSCs handled under paragraph (a)(1) of the rule.

The licensee should consider monitoring SSCs under the requirements of
paragraph (a)(1) of the maintenance rule when failures occur,
performance criteria are not being met under paragraph (a)(2), adequate
preventive maintenance has not been established, or cause determinations
and corrective actions are needed to improve SSC performance. If any of
the above conditions exist, the licensee should consider establishing
goals commensurate with safety and, where practical, take into account
industry wide-operating experience.

03.02 [Preventive Maintenance, 50.65(a)(2)]{.underline}. The maintenance
rule states that monitoring of an SSC as specified in paragraph (a)(1)
is not required if it has been demonstrated that the performance or
condition of the SSC is being effectively controlled through the
performance of appropriate preventive maintenance so that the SSC
remains capable of performing its intended function. The SOC clarify
that licensees are not required to monitor under paragraph (a)(1) of the
rule if they have demonstrated that preventive maintenance has been
effective or if an SSC has inherent high reliability and availability.

The licensees must be able to demonstrate that an effective preventive
maintenance program exists in controlling the performance or condition
of an SSC so that the SSC remains capable of performing its intended
function. Although no monitoring process is required by paragraph
(a)(2), in order to assure itself, the licensee needs to establish some
evaluation or monitoring process under paragraph (a)(2) of the
maintenance rule to verify that preventive maintenance is effective.

03.03 [Periodic Evaluations Under]{.underline} [50.65
(a)(3)]{.underline}. The licensee is required by paragraph (a)(3) of the
maintenance rule to perform the following periodic evaluations:

The licensee must perform the periodic evaluations at least once per
refueling cycle, not to exceed an interval of 24 months. Adjustments
shall be made to goals, performance criteria, or preventive maintenance
when equipment performance has not met established goals or performance
criteria. The licensee should consider industry operating experience,
where practical, when establishing goals. Adjustments shall be made
where necessary to ensure that the objective of preventing failures of
SSCs through maintenance is appropriately balanced against the objective
of minimizing unavailability of SSCs due to monitoring or preventive
maintenance activities.

03.04 [Assessing and Managing Increases in Risk Before Performing
Maintenance, 50.65(a)(4).]{.underline} The licensee is required by
paragraph (a)(4) to assess and manage the increase in risk that may
result from the proposed maintenance activities before these maintenance
activities are performed. These maintenance activities include but are
not limited to surveillances, post-maintenance testing, and corrective
and preventive maintenance activities. The licensee may limit the scope
of the assessment to SSCs that a risk-informed evaluation process has
shown to be significant to public health and safety.

The licensee should implement the requirements of this section using the
guidance contained in NUMARC 93-01, Section 11, AAssessment of Risk
Resulting from the Performance of Maintenance Activities,@ dated
February 22, 2000, as endorsed of RG 1.182, dated May 2000.

03.05 [Scope of the Rule, 50.65(b)]{.underline}. Under paragraph (b) of
the maintenance rule, the licensee must identify safety-related SSCs
that are relied upon to remain functional during and following design
basis events to ensure the integrity of the reactor coolant pressure
boundary, the capability to shut down the reactor and maintain it in a
safe shutdown condition, or the capability to prevent or mitigate the
consequences of accidents that could result in potential offsite
exposures comparable to 10 CFR Part 100 guidelines. In addition, the
licensee must identify non-safety-related SSCs that: (1) are relied upon
to mitigate accidents or transients or are used in the plant emergency
operating procedures, or (2) whose failure could prevent safety-related
systems from performing their intended safety-related function, or (3)
whose failure could cause a reactor scram or actuation of a
safety-related system.

The licensee must document all SSCs that have been identified as being
under the scope of the maintenance rule. The licensee should use the
guidance contained in RG 1.160 and NUMARC 93-01 to implement their
program for identifying safety-related and non-safety-related SSCs under
the scope of the maintenance rule but may consider other methods.

62706‑04 RESOURCE ESTIMATE

A maintenance rule baseline inspection team utilizes five to six
inspectors to complete the inspection. The team consists of one team
leader, three to four inspectors performing maintenance rule program
reviews and sample reviews of SSCs under the scope of the maintenance
rule to verify that all maintenance rule requirements have been
implemented for each SSC. In addition, one specialist inspector,
utilizing probabilistic risk assessment (PRA) expertise, determines if
the licensee is appropriately using PRA to implement maintenance rule
requirements for high safety (risk) significant (HSS) and low safety
(risk) significant (LSS) SSCs under the scope of the maintenance rule.

Completion of this inspection procedure is expected to take a minimum of
600 inspection hours: five inspectors for 3 weeks performing 1 week of
inspection preparation, 1 week on-site, and 1 week of inspection
documentation.

62706‑05 REFERENCES

U.S. Nuclear Regulatory Commission, 10 CFR 50.65, \"Requirements for
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants\"
(the maintenance rule)

Nuclear Management and Resources Council, NUMARC 93‑01, \"Industry
Guideline for Monitoring the Effectiveness of Maintenance at Nuclear
Power Plants.\"

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.160, \"Monitoring
the Effectiveness of Maintenance at Nuclear Power Plants\"

U.S. Nuclear Regulatory Commission, Statements of Consideration,
\"Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,\"
[Federal]{.underline} [Register]{.underline}, Vol. 56, No. 132,
Wednesday July 10, 1991, pages 31306 to 31323

Maintenance Rule Guideline Handbook

U.S. Nuclear Regulatory Commission, NUREG 1526, \"Lessons Learned From
Early Implementation of the Maintenance Rule at Nine Nuclear Power
Plants,\" June 1995

U.S. Nuclear Regulatory Commission, NUREG-1648, ALessons Learned from
Maintenance Rule Baseline Inspections,@ dated October, 1998

END