ATTACHMENT 71111.12

INSPECTABLE AREA: Maintenance Effectiveness

CORNERSTONE: Initiating Events

> Mitigating Systems
>
> Barrier Integrity

INSPECTION BASES: The Maintenance Rule (MR) requires licensees to
monitor the performance or condition of structures, systems and
components (SSCs) within the scope of the rule against
licensee-established goals to provide reasonable assurance that these
SSCs are capable of fulfilling their intended functions. These goals are
to be commensurate with safety and, where practical, should take into
account industry-wide operating experience. *Reliability* and
*availability* (note: all words in italics are defined in Appendix C to
this procedure) of SSCs as monitored or demonstrated under the MR
directly affect the reactor safety cornerstones listed above and are
dependent upon maintenance effectiveness (including *work practices* and
common cause problems). This baseline inspection supplements the
Unplanned Scrams, Unplanned Power Changes, Safety System Unavailability,
and Safety System Functional Failure performance indicators and/or the
Mitigating System Performance Index when implemented.

LEVEL OF EFFORT: [Routine Maintenance Effectiveness
Inspection]{.underline}. Review 8 to 10 maintenance effectiveness
performance issues a year with emphasis on high-risk-significant issues.
This is an annual goal, but available maintenance effectiveness issues
should be inspected at least four times throughout the year (the Afour
times throughout the year@ does not constitute a quarterly requirement).

71111.12-01 INSPECTION OBJECTIVE

01.01 To supplement performance indicators by providing for independent
oversight of licensee maintenance effectiveness including MR activities,
*work practices*, *extent of condition*, common cause issues, and
*corrective actions*.

01.02 To verify the licensee appropriately addresses SSC performance or
condition problems within the scope of the MR.

71111.12-02 INSPECTION REQUIREMENTS

02.01 [Routine Maintenance Effectiveness Inspection]{.underline}

a.  Independently verify the licensee=s appropriate handling of SSC
    performance or condition problems in terms of:

    1.  Appropriate *work practices*.

    2.  Identifying and addressing *common cause failures*.

    3.  Scoping in accordance with 10 CFR 50.65(b).

    4.  Characterizing *reliability* issues (performance).

    5.  Charging unavailability (performance).

    6.  Trending key parameters (condition monitoring).

    7.  10 CFR 50.65(a)(1) or (a)(2) classification and
        reclassification.

    8.  Appropriateness of performance criteria for SSCs/functions
        classified (a)(2) and/or appropriateness and adequacy of goals
        and *corrective actions* for SSCs/functions classified (a)(1).

Note: There are sources of information in the Inspection Guidance
section to assist inspectors in their review of maintenance
effectiveness.

b.  For the maintenance effectiveness attributes specified in Section
    02.01.a above, verify the licensee=s appropriate handling of the
    SSC=s degraded performance or condition.

    1.  Identify and screen equipment problems for review using an
        issue/problem-oriented approach.

        a.  Problems can relate to reliability, availability, condition
            monitoring, work practices, work control, or common cause
            failures.

        b.  Concentrate on issues/problems associated with SSCs of
            high-safety-significance,

            1.  SSCs not covered by performance indicators,

            2.  SSCs with declining performance or condition trends, and

            3.  SSCs with known equipment problems.

    2.  Based on the review of paragraph 02.01.b.1, select 8 to 10
        potentially risk-significant issues that will be reviewed in a
        year and perform detailed reviews.

    3.  In conjunction with the detailed review, assess the extent to
        which the problem(s) may affect other trains, systems, units, or
        similar components in other applications. For those problems
        recognized by the licensee, assess the accuracy with which the
        licensee has identified the *extent of condition*.

c.  After the detailed review of the problem history and surrounding
    circumstances, evaluate the role of *work practices* and common
    cause problems as follows:

    1.  For deficient work controls contributing to the degraded
        performance or condition of the affected SSC(s):

        a.  Determine the *extent of condition*.

        b.  If work practices are implicated, observe affected and/or
            related work activities, as appropriate.

        c.  As necessary, discuss the issue with licensee personnel at
            the appropriate level, and evaluate licensee corrective
            actions.

    2.  For those issues with common cause or generic implications:

        a.  Determine the extent of condition.

        b.  If the issues have the potential to result in, for example,
            failures of multiple or diverse trains of SSCs, evaluate
            adequacy of licensee corrective actions.

d.  Evaluate the licensee\'s treatment of the SSCs/issues being reviewed
    under the requirements of the MR and, where applicable, 10 CFR Part
    50, Appendix B.

    1.  Determine whether the SSCs/functions of interest are within the
        licensee\'s MR scope.

        a.  If they are, evaluate the licensee\'s treatment of the
            issues under the MR.

        b.  If not, determine whether they should be in scope and
            conduct a regulatory review (See Appendix D for guidance) if
            they should. If they are not required to be in scope, there
            is no MR issue.

    2.  Independently evaluate SSC performance in terms of *reliability*
        and *availability*.

        a.  Compare documented functional failures with those being
            tracked by the licensee under the MR.

        b.  Compare unavailable hours (when required) to those being
            charged by the licensee.

        c.  For SSCs under condition monitoring, evaluate the
            effectiveness of the licensee\'s tracking and trending SSC
            condition and recognition of declining trends.

    3.  Evaluate licensee corrective action that may be required by the
        MR for degraded SSC/function performance or condition.

        a.  Appropriate corrective actions must be taken where
            established goals under (a)(1) are not met. Appropriate
            means that (a)(1) corrective actions should be broader than
            repair of the failed SSC and address the cause of poor
            maintenance effectiveness.

        b.  Evaluate any corrective action that may be required by 10
            CFR Part 50, Appendix B, or licensee procedures.

        c.  Evaluate use of industry standards, guidance, and operating
            experience (important, but not regulatory requirements,
            except operating experience where its use is required by the
            MR).

    4.  Evaluate *functional failures* and *unavailable hours* against
        the licensee\'s goals or performance criteria as applicable.

        a.  Determine, as applicable, if goals are being met or if
            SSC/function performance or condition is being effectively
            controlled through the performance of appropriate preventive
            maintenance.

    5.  Based on the performance and condition review above, determine
        if the affected SSC(s) has/have been properly classified in
        terms of monitoring under 50.65(a)(1) or effectively controlling
        performance by appropriate preventive maintenance under (a)(2).
        (a)(1) is used to focus activities on areas needing additional
        attention. The SSC may be transferred back to (a)(2) if
        monitoring under (a)(1) demonstrated that performance has
        improved and the cause of the failure has been corrected. See
        Appendix C, (a)(2) Performance Criteria, for more explanation.

    6.  Determine if (a)(1) goals are (1) commensurate with safety, (2)
        reasonable, and (3) take relevant industry operating experience
        into account.

        a.  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 relevant industry operating
            experience.

    7.  Similarly, evaluate *(a)(2) performance criteria* for SSCs in
        (a)(2).

        a.  Determine if effective preventive maintenance can be
            reasonably demonstrated or degraded performance detected.

        b.  The MR states that monitoring of an SSC as specified in
            (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 MR statement of consideration
            (SOC) clarified that licensees are not required to monitor
            under (a)(1) if they have demonstrated that preventive
            maintenance has been effective or if an SSC has inherent
            high *reliability* and *availability*.

> If the results of any of the above determinations are unsatisfactory,
> conduct a discussion with licensee and perform a regulatory review.
> (See Appendix D for guidance).

02.02 [Identification and Resolution of Problems]{.underline}.
Inspection activities under this procedure include independent
verification that the licensee is identifying problems related to this
inspection area and entering them in the corrective action program. For
a sample of selected problems documented in the corrective action
program, verify that the *corrective actions* and resolutions are
appropriate and adequate. Problem identification and resolution (PI&R)
activities inspected per this procedure can count toward satisfaction of
the PI&R inspection requirements of Inspection Procedure 71152,
AIdentification and Resolution of Problems.@

71111.12-03 INSPECTION GUIDANCE

03.01 [Maintenance Effectiveness]{.underline}.

The steps referenced in this section of the procedure provide guidance
for completing the corresponding blocks in Flowchart 1 (See Appendix A
to this procedure).

[Start]{.underline}

There are concerns involving degraded performance or condition of SSCs
or the licensee=s proposed *corrective actions*. These concerns may be
inspector or licensee identified. Place emphasis on SSCs with high
safety significance.

[Blocks 1 & 2]{.underline} - Routine Inspection, Screening

Identify and screen equipment problems for review.

> Problems to be selected involve concerns with *reliability*,
> *availability*, *work practices*, or *common cause failures*. Note
> that these reviews are similar to and can be completed during
> performance of Inspection Manual Chapter 2515, Appendix D, APlant
> Status.@

[Block 1]{.underline} - Issue/Problem-Oriented Approach

Identify problems with the performance (*reliability* and/or
*availability*) or condition of SSCs within the *scope of the MR* using
the sources of information listed below (or others as available).

Review those instances that appear to have maintenance effectiveness
implications, warrant further assessment of *work practices*, and/or may
be related to *common cause failures*, independent of whether the
licensee has identified them as such.

[Block 2]{.underline} - SSC/Function-Oriented Approach

Review the performance or condition history of selected SSCs to identify
degraded or declining performance or condition independent of licensee
recognition.

Review instances that have maintenance effectiveness implications,
warrant further assessment of *work practices*, and/or may be related to
*common cause failures*, independent of whether the licensee has
identified them as such.

The SSCs may be selected and even scheduled for review. The more
significant maintenance effectiveness issues involving these SSCs should
be considered for further review, particularly those that may not have
been recognized or appropriately dispositioned by the licensee.

[Sources of Information]{.underline}

The following list is not meant to be all-inclusive, but is intended to
provide the inspector with potential sources of information regarding
equipment problems for evaluation:

-   Operating logs (manual and automated)

-   Plant event reports/condition reports

-   Technical specification action statement logs

-   System or component work order history

-   Safety system unavailability and unreliability performance indicator
    data

-   Other reliability and availability data (MR, PRA, INPO/WANO)

-   Corrective action program documents

-   Operability evaluations or non-conformance reports

-   Temporary system modification documents

-   Maintenance (or component) history databases

-   System Ahealth@ reports

-   Predictive maintenance test or condition monitoring results (e.g.
    thermography, lubricating oil analysis, vibration analysis, other
    in-service test results)

-   Maintenance Rule program documents

-   Plant walkdown observations and plant status information

-   Licensee personnel interviews (e.g., maintenance personnel, work
    planning staff, system engineers, operators)

-   Information discussed at licensee meetings

-   Industry operating experience (IOE) information

-   Operator workarounds log

-   Control room equipment deficiency log

The following are some sources of IOE information:

-   NRC generic communications

-   10 CFR Part 21 notifications (and those posted on the NRC external
    website)

-   Notifications from the Institute for Nuclear Power Operations (INPO)

-   INPO=s Equipment Performance Information Exchange (EPIX)

-   Nuc Net

-   Vendor technical bulletins or other correspondence (Vendor Equipment
    Technical Information Program (VETIP) - see also NRC Generic Letter
    90-03)

-   Owners and users group information

-   IOE information published by the Electric Power Research Institute
    (EPRI)

Consider the following when selecting samples:

-   the risk significance of the problems/issues or of the affected
    SSC(s)/function(s),

-   the duration and frequency of the problem,

-   the impact of the problem on the SSC performance (i.e., reliability
    and unavailability) or condition,

-   whether the problem results in frequent or repeated technical
    specification limiting condition for operations entries,

-   the impact of the problem on the licensee=s organization (i.e., are
    operators and maintenance personnel challenged by frequent emergent
    work activities to resolve the issue?),

-   whether the apparent cause of the problem could result in a common
    cause failure, and

-   the extent to which the problem has been previously inspected.

[Block 3]{.underline} - Detailed Historical Review

Detailed review includes examining work orders and associated records
for corrective and preventive maintenance and related corrective action
documents. The inspector should be able understand the duration and
extent of the problem(s) being evaluated and the effectiveness of the
licensee=s *corrective actions* to improve SSC performance or to correct
the identified problem.

Obtaining an adequate understanding of the problem may require review of
those applicable work orders and/or corrective action documents
generated in at least the past 2 years. Reviews of up to 5 years may be
considered for SSCs that are rarely operated or tested.

[Block 4]{.underline} - *Extent of Condition*

In conjunction with the detailed historical review, independent review
of the problem(s) will enable the inspector to judge the accuracy with
which the licensee has assessed the *extent of condition*.

[Block 5]{.underline} - *Work Practices* Implicated

Deficient *work practices* can cause or contribute to an SSC performance
or condition problem. Note that the licensee\'s *maintenance preventable
functional failure* (MPFF) evaluations and/or root cause analyses, if
any, may contain insights in this area. If *work practices* are not
implicated, continue inspecting for common cause implications.

[Block 6]{.underline} - Observation of Work Activities

If *work practices* are implicated, observation of affected and/or
similar activities (as necessary) will enable the inspector to assess
the extent and/or the impact of the maintenance problem.

For instance, the inspector may determine that it is necessary to review
a specific activity such as motor alignments, or perhaps it is necessary
to look more broadly at electrical *maintenance activities* to ensure
that the nature and extent of the maintenance problem is fully
understood.

[Block 7]{.underline} - *Work Practices* OK?

If *work practices* are found to be acceptable, continue inspecting for
common cause implications. If not, go to Regulatory Review (Appendix D)
for this issue, but continue inspection in other paths as appropriate.

[Block 8]{.underline} - Common Cause

For those issues with common cause or generic implications,
determination of the *extent of condition* will reveal the issues=
potential to result in, for example, failures of multiple or diverse
trains of SSCs.

Note that common cause problems may be related to maintenance support
activities, including plant design, application engineering, procurement
and acceptance, material control, and commercial-grade dedication.
However, problems may occur that are ultimately determined to be related
to latent component design and manufacturing deficiencies that were not
or would not reasonably expected to be identified by the licensee.

This distinction may become important in determining if any resultant
*functional failures* were maintenance preventable. If there are no
apparent common cause implications, continue the inspection in the MR
implementation area. If there are, proceed in this path.

[Block 9]{.underline} - *Corrective Actions*

Detailed review includes evaluation of the licensee\'s *corrective
actions* for the common cause problem(s). The licensee should ensure
that the entire *extent of condition* is identified and adequately
addressed.

In addition, overall maintenance effectiveness is in part dependent upon
feeding the insights gained in dealing with common cause issues back
into other maintenance-related or support areas.

If *corrective actions* are adequate, continue the inspection in the MR
implementation area. If not, go to Regulatory Review (Appendix D) for
the issue(s) in question, but then continue inspecting MR
implementation.

[Block 10]{.underline} - MR Scope Determination

Is/are the SSC(s) being reviewed classified by the licensee as being
within the *scope of the MR*? If so, continue inspecting and evaluating
SSC/function performance (i.e., *reliability* and *availability*) or
degraded condition issues if any. If not, go to block 11.

[Block 11]{.underline} - Should the SSC(s)/function(s) be in *scope of
the MR*?

Determine if the SSCs in question should be in scope. If they should,
regulatory review and licensee engagement will facilitate development of
a regulatory position. Continue evaluating SSC performance (i.e.,
*reliability* and *availability*) and/or condition. If the SSC(s) in
question are not required to be in scope, MR compliance is not a
regulatory issue. Go to Block 22.

[Block 12]{.underline} - *Reliability*

SSC *reliability* may be evaluated by reviewing failure history
independent of the licensee\'s recognition of failures as *MR functional
failures* (MRFFs) (i.e., failures of one or more functions for which the
SSC was included in the MR scope).

-   Compare documented failures with those being tracked by the licensee
    under the MR.

-   Evaluate these failures against the licensee=s *reliability
    performance criteria* for SSCs in (a)(2), or goals for SSCs in
    (a)(1), and evaluate licensee *corrective actions*.

Note that for MR purposes, *reliability* or unreliability is tracked
under all plant conditions for which the scoped SSC(s) or function(s)
are expected to start and run, or remain running while meeting the
appropriate success criteria for their required mission time. Valid
demands may include automatic or manual operation in-service or during
testing. When in doubt with regard to licensee recognition or
categorization of *functional failures*, inspectors are encouraged to
consult with MR experts in the region and/or NRR. If *reliability* is
not an issue, review *availability*/unavailability. If *reliability* is
an issue, continue in this flowchart path.

Note that for MR purposes, *run-to-failure* applies to SSCs that have
little safety significance, for which there is little or no meaningful
preventive maintenance established, for which conditions indicative of
degradation prior to failure are not readily detectable, have fairly
predictable failure rates or expected limited service life, and for
which failure is self revealing so that the component can be promptly
replaced, i.e. no testing would be required to identify a failed
component that could impact any function important to safety were it to
remain undetected and uncorrected. Examples would be components such as
light bulbs, fuses with blown-fuse indicators, etc. For such SSCs, the
inspector may wish to review the categorization for appropriateness.

[Block 13]{.underline} - *Availability*

If *availability* is affected, continue in this path. If not, proceed to
assessment of MR (a)(1) or (a)(2) classification, (i.e., MR monitoring
category). If neither *availability* nor *reliability* is affected, go
to Block 22.

[Block 14]{.underline} - Exceed performance criteria?

Comparison of identified failures and unavailability with the licensee=s
(a)(1) SSC/function goals and/or (a)(2) SSC/function performance
criteria (i.e., *reliability* and *availability*) will enable the
inspector to determine whether failures or unavailability exceeded them
as applicable.

a.  If goals are not met or unreliability and/or unavailability goals
    are exceeded:

    1.  The licensee must take corrective actions under the MR for SSCs
        in (a)(1).

    2.  Note that prompt corrective actions may also be required for
        SSCs in (a)(2) by other regulations (e.g., Criterion XVI of 10
        CFR Part 50, Appendix B, or technical specifications).

b.  If there are MRFFs or MPFFs, and/or unavailability incurred for SSCs
    in (a)(2) status, particularly if unreliability or unavailability
    performance criteria are exceeded:

    1.  The licensee must determine whether effective control of SSC
        performance or condition is being demonstrated.

    2.  If not, the licensee must at least consider placing (a)(2) SSCs
        into (a)(1).

    3.  If reliability and availability goals or performance criteria
        are appropriate and are being met as applicable, reliability
        and/or availability are not an issue unless the performance
        criteria are inappropriate and cannot be relied upon to identify
        degraded performance. In this case, the validity of the (a)(2)
        demonstration may be in doubt even when performance criteria are
        met and regulatory review must include consultation with Office
        of Nuclear Reactor Regulation (NRR) maintenance rule staff and
        Office of Enforcement (OE) staff as necessary.

    4.  If reliability and availability is not an issue, go to Block 22
        ; otherwise continue.

[Block 15]{.underline} - Licensee Aware?

a.  Of exceeding unreliability goals or performance criteria, as
    applicable.

> When the licensee miscounts failures and is unaware of exceeding
> unreliability goals or performance criteria as applicable, or when the
> licensee counts correctly, but still fails to recognize that goals or
> performance criteria have been exceeded, go to Regulatory Review
> (Appendix D) for this issue, but continue inspecting in this path.
> Regulatory review must include consultation with the headquarter
> maintenance rule staff in the Division of Risk Assessment (DRA) when
> the inspector has reason to believe that unreliability is excessive,
> but licensee goals or performance criteria have not been exceeded.

b.  Of exceeding unavailability goals or performance criteria as
    applicable

> Actual *unavailable hours* (or as determined by the inspector from
> records and applying applicable criteria) may not be consistent with
> those being tracked and counted by the licensee. When the licensee
> incorrectly tracks unavailability, but is unaware that goals or
> performance criteria have been exceeded or when the accounting is
> correct, but the licensee still fails to recognize that goals or
> performance criteria have been exceeded, go to Regulatory Review
> (Appendix D) for this issue, but continue inspecting in this path.
> Regulatory review must include consultation with the headquarter
> maintenance rule staff in the DRA when the inspector has reason to
> believe that unavailability is excessive, but licensee goals or
> performance criteria have not been exceeded.

[Block 16]{.underline} - Licensee Actions

a.  For exceeding unreliability goals or performance criteria as
    applicable.

> If the SSC performance trend is poor and not improving, the licensee=s
> *corrective actions* for this problem likely have not been timely and
> adequate. In cases where an SSC has experienced an apparently high
> number of failures, consult with a regional senior reactor analyst
> (SRA) to determine whether the SSC *reliability* problems are likely
> to result in a significant risk increase. If licensee actions are
> acceptable, proceed to assess *availability*. If not, go to Regulatory
> Review (Appendix D) for this issue, but continue inspecting in this
> path.

b.  For exceeding unavailability goals or performance criteria as
    applicable.

> Unavailability trend data should show whether system performance is
> improving.
>
> If performance is not improving,

1.  ideally, the licensee should take timely and reasonable corrective
    actions for this problem.

2.  Depending on the circumstances, this situation may or may not amount
    to an MR violation, but it reflects negatively upon maintenance
    effectiveness and should be pursued through regulatory review.

3.  In cases where an SSC has experienced an apparently large amount of
    unavailability, the licensee=s PRA may provide some insight as to
    the risk significance of this condition.

4.  Also, use of the SDP or consultation with a regional SRA may be
    necessary to determine whether the SSC availability performance
    problems are likely to result in a significant risk increase.

5.  If licensee actions are not acceptable, go to Regulatory Review
    (Appendix D) for this issue, but continue to review MR disposition
    of the issue(s) in question.

[Block 17]{.underline} - MR Monitoring Category

If the SSC is already classified as (a)(1), continue to evaluate; if
not, the inspector must decide if it should have been in (a)(1).

The inspector should determine independently whether the licensee has
demonstrated effective control of SSC or function performance through
appropriate preventive maintenance for SSCs/functions in (a)(2),
independent of whether performance criteria were exceeded. If the
inspector has reason to believe that the (a)(2) demonstration is
invalid, yet licensee performance criteria are being met, regulatory
review must include consultation with NRR.

[Block 18]{.underline} - Should it be?

A Regulatory Review (Appendix D) will take place if it is determined
that the affected SSC should have been in (a)(1), but was instead was
being carried in (a)(2) status even when effective control of SSC
performance or condition was not being demonstrated.

[Block 19]{.underline} - Evaluate Goals and *Corrective Actions*

The (a)(1) monitoring goals must be appropriate, commensurate with
safety and take industry operating experience into account where
practicable. *Corrective actions* must be timely and must address the
cause of the degraded performance or condition. For example, in setting
goals, the licensee (expert panel) should have considered:

a.  Both *reliability* and *availability*

b.  Balancing of *reliability* and *availability*

c.  Industry operating experience (IOE) information

d.  Actual performance history

e.  Frequency of valid demands or expected operation within the
    monitoring period

f.  PRA or some other reasonable risk/safety consideration(s)

If (a)(1) goals are not appropriate, not commensurate with safety, or
did not take IOE into account where practicable, go to Regulatory Review
(RR) (Appendix D).

If (a)(1) goals are satisfactory, but have not been met, evaluate the
licensee=s *corrective actions*. Repeated failure to meet goals may be
indicative of inadequate corrective action. However, note that failure
to meet (a)(1) goals is not, by itself, an MR violation. However,
failure to take timely and adequate corrective action when (a)(1) goals
are not met (corrective action that addresses the cause(s) of the
problem(s)) may constitute a 50.65(a)(1) violation (depending on the
circumstances) in addition to any other safety-significant findings.

[Block 20]{.underline} - Evaluate *(a)(2) Performance Criteria*

For SSCs that remain in (a)(2) following the current problem, the
licensee=s performance criteria should be appropriate, i.e.,
*technically justifiable*. They should be sensitive enough to identify
unacceptably degraded performance while allowing a reasonable,
technically defensible (in terms of both deterministic and risk factors)
and balanced amount of unreliability and/or unavailability without
invalidating the (a)(2) demonstration. In general, the licensee (expert
panel) should consider factors similar to those used to establish (a)(1)
goals.

For example, it would be unreasonable if the number of MPFFs required to
exceed the *reliability* performance criterion or goal for a given SSC
exceeds the number of expected (or possible) valid demands during the
monitoring period. In this case, the goal or performance criterion could
never be reached, let alone exceeded, despite clearly degraded
performance or condition of the affected SSC. After consultation with
appropriate regional and possibly headquarters staff, such issues can be
addressed with the licensee, who should have a sound technical basis for
its goals and performance criteria. This area, if suspect, may also be a
candidate for further and more in-depth examination of the licensee\'s
(a)(3) *periodic evaluation* activities.

Note that condition monitoring or predictive maintenance is generally
desirable, but when performance criteria allow no failures or
unavailability during the monitoring period, typically for very high
safety-significant and/or Amission-critical@ SSCs, then the condition of
the SSC should be monitored or tracked using condition monitoring or
Apredictive maintenance@ parameters that, to the extent practicable,
alert the licensee to degradation in time for preventive maintenance
prior to failure. For example, some licensees allow no failures of
either offsite power source and/or their in-plant distribution SSCs.
Therefore, they will track voltage and frequency of the offsite power
sources closely, particularly during periods of grid instability or
heightened probability of loss of offsite power.

In addition, licensees may designate certain SSCs in a so-called
Arun-to-failure@ category. These are typically SSCs that are simple, of
relatively low safety/risk significance, for which there is little or no
meaningful preventive maintenance established, for which conditions
indicative of degradation prior to failure are not readily detectable,
that have fairly predictable failure rates or expected limited service
life, and for which failure is self revealing so that the component can
be promptly replaced, i.e. no testing would be required to identify a
failed component that could impact any function important to safety were
it to remain undetected and uncorrected. Examples would be components
such as light bulbs, fuses with blown-fuse indicators, etc.

The licensee can and should promptly, commensurate with safety, repair
or replace failed equipment of this type, but adjustments to PM program
may not be necessary and monitoring under (a)(2) may be able to
continue, unless the affected component or batch of similar components
appear to suffer excessive or too frequent failures or significantly
shortened service life compared to vendor expectations and or indusrty
norms. These circumstances even with usual run-to-failure components
warrant investigation. However, if an SSCs has a function which caused
it to be within the scope of the MR, it has some safety significance;
therefore, licensee should provide a sound technical justification which
appropriately establishes a run-to-failure determination. For such SSCs,
the inspector may wish to review the categorization for appropriateness.

[Block 21]{.underline} - Performance Criteria/Goals Reasonable?

Determine whether the licensee=s goals and/or performance criteria are
reasonable and achievable, consistent with the PRA or commensurate with
safety, and appropriate. Consult the regional MR contact if you conclude
that the licensee=s performance criteria or goals are not reasonable and
also if you conclude that the actual number of failures or amount of
unavailability would have exceeded a more a reasonable goal or
performance criterion.

[Block 22]{.underline} - END - Develop Regulatory Position and
Documentation (See Appendix E for guidance)

03.02 [Identification and Resolution of Problems]{.underline}. PI&R are
integral and essential elements of maintenance effectiveness; therefore
the specific guidance in this inspection procedure covers review of
licensee PI&R in the maintenance effectiveness area. Guidance on the
conduct of PI&R inspections in general is contained in IP 711152.

71111.12-04 RESOURCE ESTIMATE

This inspection procedure is estimated to take 92 to 124 hours a year
for the routine maintenance effectiveness inspection.

71111.12-05 COMPLETION STATUS

Inspection of the minimum sample size will constitute completion of this
procedure in the Reactor Programs System (RPS). The minimum sample for
routine inspection will consist of eight maintenance effectiveness
issues (of high risk significance to the extent available) in a year.

71111.12-06 REFERENCES

Section 50.65, ARequirements for monitoring the effectiveness of
maintenance at nuclear power plants,@ of Title 10 of Part 50 of the
*Code of Federal Regulations* (10 CFR 50.65)

Statement of Considerations for the Maintenance Rule (three sections)

Inspection Procedure (IP) 62706, AMaintenance Rule@

NRC Regulatory Guide (RG) 1.160, AMonitoring the Effectiveness of
Maintenance at Nuclear Power Plants@

Nuclear Energy Institute (NEI) (formerly Nuclear Management and
Resources Council (NUMARC)), NUMARC 93-01, AIndustry Guideline for
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants@

NRC Inspection Manual, Chapter 0609, AReactor Safety Significance
Determination Process@

NRC Inspection Manual, Chapter 0612, AInspection Reports@

IP 97201, ALicensee disposition of NRC Generic Communications@

IP 71152, AIdentification and Resolution of Problems@

NRC Generic Letter 90-03, June 15, 1990, ARelaxation of Staff Position
on Generic Letter 83-28, Item 2.2, Part 2, Vendor Interface for
Safety-Related Components@

NRC Enforcement Manual, Section 8.1.11, AActions Involving the
Maintenance Rule@ (Go to
[http://www.nrc.gov/what‑we‑do/regulatory/enforcement/guidance.html#manual](http://www.nrc.gov/what we do/regulatory/enforcement/guidance.html#manual),
click on Chapters 1-8)

IP 88025, AMaintenance and Surveillance Testing@

NRC Inspection Manual, Part 9900, Technical Guidance, APreconditioning
of Structures, Systems, and Components (SSCs) Before Determining
Operability@

NUREG -1648, ALessons Learned from Maintenance Rule Implementation@

END

Attachments:

Appendix A, ARoutine Maintenance Effectiveness Inspection Flowchart@

Appendix B, ADeletedA

Appendix C, AMaintenance Rule Terminology@

Appendix D, ARegulatory Review@

Appendix E, ADocumenting Maintenance Effectiveness (ME) Findings@

APPENDIX A

Routine Maintenance Effectiveness Inspection Flowchart

![](media/image1.wmf)

APPENDIX B

DELETED

APPENDIX C

Maintenance Rule Terminology

**(a)(2) Performance Criteria**- A means, established by the
NRC-endorsed industry MR guidance, NUMARC 93-01, by which licensees
typically determine whether they are demonstrating effective control of
the performance of SSCs within the MR scope through appropriate
preventive maintenance. Note that (a)(2) performance criteria are not
required or even recognized per se by the MR. Meeting or not meeting
(a)(2) performance criteria is not, by itself, the sole test for a valid
(a)(2) demonstration for MR compliance with regard to those SSCs being
carried in (a)(2) status, i.e., not being monitored against goals in
(a)(1) status. Therefore, not placing an SSC into (a)(1) status for
failing to meet (a)(2) performance criteria alone may not be sufficient
grounds for an (a)(1)/(a)(2) violation; just as meeting (a)(2)
performance criteria alone may not be sufficient demonstration of
effective control of SSC performance in (a)(2).

If the inspector believes, on the basis of some objective standard
(e.g., the plant=s PRA, the EPRI PRA applications guide, or industry
operating experience) that unavailability and/or unreliability is
excessive, even if the existing performance criteria (which may no
longer be valid) are not exceeded, there may be justification to
conclude that the licensee is not effectively controlling the
performance of the affected SSC(s)/function(s) through appropriate
preventive maintenance. In such a case, the licensee should at least be
considering the affected SSC(s)/function(s) for monitoring under (a)(1).
However, not having recognized the unacceptable performance or
condition, the licensee will not have considered monitoring under
(a)(1). This may be grounds for identifying an (a)(2) violation, but
this kind of issue may be highly subjective and would require
considerable objective evidence to support a violation or a
risk-significant finding. In such cases, regulatory review must include
consultation with NRR.

**Availability** - Availability is often tracked by its numerical
complement, unavailability, and typically only for
high-safety-significance (HSS) SSCs as provided for in the endorsed
industry guidance. Unavailability is the time an SSC is unavailable
during periods when the SSC was required to be available. Unavailability
may also be expressed as a fraction of the total time the SCC was
required to be available. Under the MR, unavailability is customarily
charged from the time of a demand failure or discovery of a degraded or
failed condition until restoration. For the period prior to a demand
failure or discovery of a failed or degraded condition, additional
unavailability may be charged from when the condition first existed
(i.e., fault exposure time) if the fault exposure time can be
determined. However, for MR purposes, if the fault exposure time cannot
be determined, additional unavailability need not be charged.
Nevertheless, as an alternative to charging unavailability for fault
exposure time, the licensee may impute a demand failure and count it
against the unreliability performance criterion. Treatment of very long
fault exposure time resulting from long-standing latent deficiencies
(e.g., design deficiencies) depends on the circumstances. While the
condition should be promptly corrected (and *extent of condition*
addressed), it may legitimately be judged not to reflect adversely on
current maintenance effectiveness or on other aspects of the Ahealth@ of
the affected SSC(s); hence, not be charged as unavailability.
Consultation with cognizant NRC staff in such instances is encouraged.

An SSC may be considered unavailable, even if deemed operable under
technical specifications, when it cannot meet the appropriate success
criteria for one or more of its MR-scoped functions. On the other hand,
if the performance of the scoped function is tracked at the system
level, and not all trains of the system are unavailable (such that the
system can still meet scoped functional success criteria), then the
licensee may legitimately consider the system available. For MR
purposes, support system unavailability is not normally cascaded onto
supported system(s) because it is indicative only of the performance or
condition (Ahealth@) of the support system, not that of the supported
system.

NUMARC 93-01 contains guidance on the restrictions for crediting
operator recovery actions. Note that required availability may vary
widely under different plant conditions. It may depend upon the
licensee\'s relying on the SSC for alternate success paths to preserve
key safety functions.

With the assistance of regional and headquarters staff cognizant of the
MR, the inspector should be able to keep abreast of changes to industry
guidance related to maintenance effectiveness and the NRC positions with
respect to that guidance. For example, it is current industry practice
to track unavailability of HSS SSCs or functions for MR purposes under
all plant conditions in which they are required. However, this may not
always be the case during shutdown. Also, there may be changes in the
way fault exposure time and discovered conditions are treated for MR
purposes in the interest of improved consistency with unavailability
tracking for ROP performance indicators and other reporting programs.

**Common Cause Failures**- Failure of two or more SSCs due to single
specific event or cause. For example, a design deficiency, operation and
maintenance errors, a natural phenomenon, personnel-induced event, or an
unintended cascading effect from any other operation or failure within
the plant or a change in ambient conditions.

Common Mode Failure- Failure of two or more SSCs in the same manner or
mode due to a single event or cause (i.e., common mode failure is a type
of common cause failure in which the SSCs fails in the same way.)

**Corrective Actions**- Appropriate corrective actions must be taken
where established goals under (a)(1) are not met. AAppropriate@ means
that (a)(1) corrective actions should be broader than repair of the
failed SSC and address the cause of poor maintenance effectiveness.

**Extent of Condition**- The extent to which the problem(s) may affect
other trains, systems, units or plants, or similar components in other
applications.

**Maintenance Activities**- All activities associated with the planning,
scheduling, accomplishment, post-maintenance testing, and return to
service activities for surveillances and preventive and corrective
maintenance. These activities are considered maintenance regardless of
which organization performs the activity (e.g., maintenance, operations,
contractors). (Also, refer to discussion of maintenance support
activities in MR Reliability Performance Criteria in this Section.)

**Maintenance Preventable Functional Failure**- Failure of an SSC within
the scope of the MR to perform its intended function (i.e., the function
performed by the SSC that required its inclusion within the scope of the
Rule), where the cause of the failure of the SSC is attributable to a
maintenance-related activity. The maintenance-related activity is
intended in the broad sense of maintenance.

For example, in general, repetitive MPFFs (i.e., multiple failures of
the same SSC for the same maintenance-related reason) can demonstrate
that preventive maintenance is not effective and may be sufficient cause
for placing the affected SSC in (a)(1) even if the performance criterion
was not exceeded. By the same token, failures that are technically MPFFs
and that exceed the reliability performance criterion, but are not
related to the health of the SSC itself, may be reasonably judged by an
expert panel not to warrant the increased attention of (a)(1) status.
(Also, refer to MR Reliability Performance Criteria definition in this
Section.)

**Maintenance Rule Functional Failure**- Failure of an SSC within the
scope of the MR to perform its intended function (i.e., the function
performed by the SSC that required its inclusion within the scope of the
MR). Degraded performance may constitute a functional failure, even
without a complete loss of function. (Also, refer to MR Reliability
Performance Criteria definition in this Section.)

**MR Reliability Performance Criteria** (Block 12)- Reliability: may be
defined in various ways by the licensee, most of which are acceptable
under the endorsed guidance. However, the inspector should be aware of
limitations. For example, a licensee who defines reliability (or
unreliability) in terms of MRFFs, may only consider a total loss of
those functions to be an MRFF. The licensee=s program may not recognize
certain degraded performance as an MRFF (e.g., reduction in capacity
below the nominal value). Nevertheless, it may be reasonable to
consider, for example, that an affected SSC which still retained its
minimum design-basis capability did not suffer an MRFF, particularly if
there were no condition monitoring being done on the SSC in question.
Further, it may also be reasonable to consider some degraded performance
not to be a MRFF when the minimum capability assumed in the PRA (upon
which performance criteria are based in part) was maintained (i.e., PRA
functional success criteria met) even if design-basis capability was
not. However, such rationalization to avoid declaring MRFFs (or to avoid
charging unavailability) may be counterproductive to maintenance
effectiveness because the practice may mask declining performance trends
that otherwise might be more promptly addressed, preferably before
complete failures occur. In addition, the inspector should consider not
only the design basis and/or PRA success criteria for the function(s) in
question, but also the success criteria for all the functions for which
the SSC was scoped (e.g., use in the EOPs). If the affected SSC cannot
meet the appropriate functional success criteria for one or more of the
functions for which it was scoped, the reduced capability should ideally
be considered a MRFF. If it is not, then the inspector would be
justified in questioning the licensee=s basis for this determination,
whether or not counting the degraded performance as an MRFF would result
in the need to consider putting the affected SSC in (a)(1). [While this
situation may not result in an MR violation per se, there may be PI&R
and/or corrective action implications, not to mention some risk or
safety significance that could possibly be assessed through the
significance determination process (SDP).]{.underline}

Some licensees define their reliability performance criteria in terms of
maintenance-preventable functional failures (MPFFs) in a given number of
valid demands or within some time period, as opposed to merely MRFFs.
This further distinction can become very subjective. In evaluating the
licensee\'s characterization of MRFFs as MPFFs (or not), where
circumstances warrant, the inspector should consider maintenance-related
contributing factors in a broad sense, not limited to work practices or
other activities of maintenance staff alone. For example, deficiencies
in certain direct maintenance support activities may cause or
substantially contribute to failures, allow failures to occur or fail to
prevent them, or allow unsatisfactory conditions to persist. These
activities can include (but are not limited to) procurement; acceptance
(including receiving and commercial-grade dedication); material control
and issue; engineering (including design control, specifications,
procedures and drawings, and poorly designed post-maintenance tests),
work controls (including clearances, equipment lineups, etc.); operators
(reconfiguring systems and equipment in support of maintenance); and use
of vendor information and industry operating experience to keep
instructions and procedures up to date.

Even certain common cause problems related to design and/or
manufacturing deficiencies in replacement parts, component, or materials
(e.g., sealants, adhesives, lubricants, etc.) may be legitimately
considered to render an MRFF maintenance-preventable (i.e., the MRFF
would become an MPFF) if the deficiency(ies) could or should reasonably
have been detected and screened out (or contained) by the licensee
applying generally acceptable industry standard practices in
procurement, acceptance, and comprehensive corrective action. These
maintenance support activities can be viewed as part of a more
comprehensive concept of maintenance, and preventive maintenance in
particular.

However, the inspector should also recognize that while such factors may
indicate the need for improvements in maintenance and/or its support
activities (e.g., re-training, improved work practices, etc.), they may
not necessarily reflect degraded health of the affected SSC that would
warrant monitoring. Such contributing factors as certain operator
errors, for example, committed in direct support of maintenance (e.g.,
clearances, valve or equipment lineups, etc.), may require a failure to
be deemed an MPFF by the licensee=s program. However, absent any
indications of actual degraded performance or condition of the SSC(s)
involved, the licensee (typically an expert panel) may be justified in
not placing or retaining the affected SSC(s) in (a)(1), even if that
operator error-related MPFF caused the applicable performance criterion
to be exceeded. It would be reasonable in such a situation for the
licensee to prescribe corrective action more appropriate to the
circumstances, such as remedial operator training or requalification.
The licensee should be expected to be able to defend such decisions.
Although not required by the MR to be documented, this sort of rationale
may often be found recorded in expert panel meeting minutes or similar
documents.

**Periodic Evaluation**- Licensee performance of an evaluation of
maintenance activities at least once a refueling cycle, not to exceed 24
months between evaluations. The evaluation shall take into account
relevant industry experience.

**Reliability**- A measure of the expectation (assuming that the SSC is
available) that the SSC will perform its function upon demand at any
future instant in time. Reliability is typically measured in terms of
the number of failures in some pre-established number of valid demands
over a pre-established tracking or monitoring period. Along with
availability, reliability is a performance measure.

**Run-to-Failure**- Applies to SSCs that are typically simple, of
relatively low safety/risk significance, for which there is little or no
meaningful preventive maintenance established, for which conditions
indicative of degradation prior to failure are not readily detectable,
that have fairly predictable failure rates or expected limited service
life, and for which failure is self revealing so that the component can
be promptly replaced, i.e. no testing would be required to identify a
failed component that could impact any function important to safety were
it to remain undetected and uncorrected. Examples would be components
such as light bulbs, fuses with blown-fuse indicators (particularly in
standby SSCs), etc. For such SSCs, the inspector may wish to review the
categorization for appropriateness.

The licensee can and should promptly, commensurate with safety, repair
or replace failed equipment of this type, but adjustments to PM program
may not be necessary and monitoring under (a)(2) may be able to
continue, unless the affected component or batch of similar components
appear to suffer excessive or too frequent failures or significantly
shortened service life compared to vendor expectations and or indusrty
norms. These circumstances even with usual run-to-failure components
warrant investigation. However, if an SSCs has a function which caused
it to be within the scope of the MR, it has some safety significance;
therefore, licensee should provide a sound technical justification which
appropriately establishes a run-to-failure determination. For such SSCs,
the inspector may wish to review the categorization for appropriateness.

**Scope of the Maintenance Rule** (Block 11)- SSCs/functions that have
one or more of the following attributes must be scoped into the
maintenance rule program:

-   Safety-related SSCs/functions \[50.65(b)(1)\]

-   Non-safety-related SSCs that perform an accident or transient
    mitigation function \[50.65(b)(2)(i)\] (as defined in the Final
    Safety Analysis Report)\*

-   Non-safety-related SSCs that are used in the emergency operating
    procedures (EOPs) \[50.65(b)(2)(i)\]\*

-   Non-safety-related SSCs that could prevent the fulfillment of a
    safety-related function \[50.65(b)(2)(ii)\]

-   Non-safety-related SSCs that could cause an unwanted reactor trip or
    engineered safety feature (ESF) activation \[50.65(b)(2)(iii)\]

NUMARC 93-01 (Rev. 3) states that an SSC needs to be in scope under
(b)(2)(i) only if it Aprovides a significant fraction of the mitigating
function@; whereas, paragraph 1.1.2 of RG 1.160 (Rev. 2) states that
SSCs that are Adirectly used to address the accident or transient or
explicitly used in the EOPs are within the scope of the rule, as are
SSCs whose use is implied and that provide a significant fraction of the
mitigating function.@ NRR (MR group) should be consulted for scoping
issues of this type.

**Technically Justifiable**- means justifiable in terms of logic for
both qualitative and quantitative considerations. For example, the
reliability performance criterion for emergency diesel generators (EDGs)
is typically expressed in terms of the number of failures to properly
start and/or run on demand for some given number of attempts or demands
within the monitoring (or (a)(2) \"tracking\") period.

Technically justifiable criteria in terms of deterministic
considerations would include, for example, allowable demand failures
that are consistent with industry operating experience that are
reasonably sensitive to declining performance (i.e., degraded
performance would be recognized before complete failure), but not be so
restrictive as to become unbalanced with availability. For example, the
risk-informed EDG reliability performance criteria discussed above might
also be judged against operating experience, among other deterministic
considerations, by the expert panel to ensure they made sense for the
plant in terms of tracking SSC health and monitoring the effectiveness
of maintenance.

Performance criteria may need to be adjusted logically as well. For
example, if the industry average demand failures in a refueling cycle
for some piece of equipment was two, then a reliability performance
criterion of two demand failures allowed might be reasonable, except for
a plant at which the equipment was never challenged more than twice
during the monitoring period. In that case, it could fail two times and
never exceed the performance criterion such that it would be considered
for transition to (a)(1) status. If the equipment in question were
non-safety-related, there would be no regulatory requirement to take
corrective action.

In such a case, the prudent licensee would consider the operating
history of the equipment at its plant. If the equipment was more
reliable historically than the industry average, then it might be more
prudent to set the reliability performance criterion at zero or one in
order to promptly flag degraded performance or establish condition
monitoring to detect declining trends.

If the inspector questions the performance criteria or a change in
performance criteria (or a shift from HSS to LSS status), the licensee
should be asked to explain the basis for the criteria and/or change. If
the inspector does not believe (1) the criteria or changes are
reasonable, (2) the justification is inadequate, or (3) is simply
unsure, the inspector should commence a regulatory review, including
consulting with the regional SRA and MR contact and NRR MR staff
(Quality and Maintenance Section of the Plant Support Branch, Division
of Inspection Program Management).

Note that having (a)(2) performance criteria that are not technically
justifiable or that are not commensurate with safety (unlike (a)(1)
monitoring goals that must be) is not necessarily a violation of the
rule. However, it could be a contributing cause of the licensee\'s
failure to demonstrate effective control of performance or condition if
there are an excessive number of functional failures or excessive
unavailability. However, determining what\'s excessive may be difficult.
As stated elsewhere in this procedure, the region and NRR must be
consulted in such cases to assist in evaluating the situation and making
the case for a violation if warranted while helping to ensure
consistency in enforcement. (Also, refer to trigger values definition in
this Section).

**Trigger Values**- A generic EDG reliability analysis was done that
resulted in what were known as \"trigger values.\" The trigger values
allowed (1) 3 failures to start or run in 20 attempts, (2) 4 in 50
attempts, and (3) 5 in 100. However, it was later determined that the
values were not technically justifiable from a risk standpoint (i.e.,
not commensurate with safety), because they allowed an unacceptably high
risk level to be reached before the EDG would be considered for shifting
into (a)(1) status. Instead, the more conservative demand failure
figures given in the EPRI PRA Applications Guide of (1) 2 in 20, (2) 3
in 50, and (3) 4 in 100, based on generic bounding PRA analyses would
keep the risk within acceptable limits. During the NRC MR baseline
inspections, these were deemed to be technically justifiable in terms of
risk and hence, commensurate with safety. (Also, refer to technically
justifiable definition in this Section).

**Unavailable Hours**- The numerical complement of availability. The
hours within a period during which an SSC is required to be available
when the SSC cannot perform its function. An SSC that is required to be
available for automatic operation must be available and respond without
human interaction. (See Availability in this Section).

**Work Practices**- The term Awork practices@ refers to the broad range
of activities performed to maintain SSCs, including (but not limited to)
preventive maintenance program requirements, maintenance procedures,
field activities, system isolation and restoration procedures and
practices, and post-maintenance testing.

APPENDIX D

Regulatory Review

In general, Regulatory Review (RR) is entered whenever the inspector has
occasion to question licensee actions or inaction and has not received a
satisfactory response or justification from the licensee, or whenever
the inspector desires further evaluation of the validity of a licensee
response. Based on the results of the inspector=s reviews and
discussions with the licensee, the inspector should consult other
knowledgeable sources, such as: other inspectors on site and the senior
resident inspector, regional supervision, regional Division of Reactor
Safety (DRS) maintenance rule contact(s), and regional enforcement
specialist(s). After consultation with appropriate regional staff, and
at least preliminary significance determination and documentation as
described below, consult with the headquarter maintenance rule staff in
the Division of Risk Assessment (DRA) and Office of Enforcement (OE)
staff as necessary.

The following guidance is intended to supplement the general guidance of
IMCs 0612, 0609, and 0305 by providing specific guidance on the
disposition of maintenance effectiveness (ME) issues. That is, where
there are choices or interpretations indicated in the applicable manual
chapters, this procedure is intended to provide the inspector with the
staff-pre-selected choices and preferred interpretations unique to ME
issues and applicable under the vast majority of foreseeable
circumstances.

First, the licensee performance deficiency(ies) involved in or
associated with the ME issue(s) should be clearly identified. They
should be able to be characterized by a simple written statement as a
preliminary determination. An ME performance issue can involve various
types of licensee performance problems, including, but not limited to:
deficient procedures, instruments/measuring and test equipment, tools or
other equipment, deficient work practices, deficient maintenance support
activities (e.g., replacement parts procurement and dedication, storage
and material issue), inadequate recognition and handling of common cause
problems, or inadequate root-cause analysis and/or corrective actions
for degraded performance or condition of SSC(s)/function(s).

In addition, one or more of the identified performance deficiencies may
constitute a violation of one or more NRC regulations. Though not
limited to violations of 10 CFR 50.65, the Maintenance Rule (MR), this
section will focus on the disposition of ME issues involving MR
violations because treatment of violations of other regulations that may
be involved as well are covered adequately elsewhere. For ME issues
involving potential MR violations, refer to Enforcement Manual Section
8.1.11. Note that the provisions of NUMARC 93-01 and RG 1.160 are not
regulatory requirements, but may provide insights for characterization
of failures to meet one or more explicit requirements of the MR or
expectations of the Commission with regard to MR implementation as
described in the statements of considerations.

Next, the identified performance deficiency(ies) is/are screened against
the criteria in Appendix B to IMC 0612 to determine whether they are
minor or more than minor. Those issues that are determined to be minor,
although not normally to be documented in the inspection report, should
be brought to the licensee=s attention at a level and in a forum deemed
appropriate by the inspector and must be corrected. Effective corrective
action normally requires entry into the licensee=s corrective action
program. Appendix B to IMC 0612 will refer to the examples of minor
issues in Appendix E to IMC 0612. Note that specific examples of MR
violations are included in Appendix E to IMC 0612. These examples also
explain the conditions that make the violations more than minor. In
general, ME performance deficiencies will be more than minor when there
is or has been identifiable degraded performance or condition of
associated SSCs/functions, sometimes regardless of the extent to which
such degraded performance or condition has been recognized and/or
appropriately categorized or characterized by the licensee.

In processing more-than-minor ME performance deficiencies (i.e.,
findings), consider that MR violations do not always cause degraded
SSC/function performance or condition, but rather are often a separate
consequence of them. In some instances, equipment failures are found not
to be attributable to any licensee performance deficiencies and are
therefore not findings. Yet, in many instances, licensee ME performance
deficiencies contribute to the equipment problems, or allow them to
occur, persist, or get worse. In order to disposition ME issues
involving performance deficiency(ies) systematically and consistently,
all such issues will be categorized as follows:

Category I - ME issues involving performance deficiencies (including any
MR or other violations) that are minor, determined as described above.

Category II - ME issues involving more-than-minor performance
deficiencies (which are thus considered findings) where any identified
MR violation has occurred as a separate consequence of degraded
performance or condition of associated SSCs/functions within the scope
of the MR, but where the degraded SSC/function performance or condition
is not attributable to the MR violation.

In this category, the degraded SSC/function performance or condition
will have its own proximate, ultimate and/or contributing causes that
involve licensee ME performance deficiencies (findings) other than MR
violations. Those causal findings will be processed in accordance with
Appendix B to IMC 0612 and their significance will be determined,
independent of any associated MR violations, using the reactor safety
significance determination process (SDP) commensurate with the severity
and risk/safety significance of the degraded performance or condition of
the affected SSCs/function(s). Alternatively, the impact of the
equipment problems may be otherwise captured under the Reactor Oversight
Process (ROP) by the performance indicators.

However, also in this category, the MR violation(s) itself/themselves
is/are also considered to be more than minor because actual problems
with the associated equipment have occurred. However, since the
equipment problems are not attributable to the MR violation, rather, the
MR violation has occurred as a consequence of those problems, they
cannot be processed through the SDP. Therefore, in accordance with
Appendix B to IMC 0612, such MR violations are considered to be GREEN by
definition.

Category III - ME issues involving more-than-minor performance
deficiencies where the identified MR violation(s) is/are among the
contributing causes of degraded SSC/function performance or condition.
Such instances will typically involve circumstances in which, in
addition to non-MR proximate causes, the lack of adequate preventive
maintenance or proper attention to degraded performance or condition of
affected SSCs/functions, which has allowed such degraded performance to
continue or the condition to deteriorate, can be shown to be the result
of one or more MR performance deficiencies, including MR violations. MR
findings in this category are bundled together with the other,
contributory, non-MR findings, and treated collectively as one finding,
involving multiple violations and/or other performance deficiencies,
which is then processed through the SDP. Note that only Category III MR
findings can be greater than green.

Note also that in all three categories, cross-cutting issues may be
involved. However, where identified in conjunction with Category II or
III ME findings as described above, cross-cutting issue aspects should
be documented within the finding and dispositioned in accordance with
IMCs 0612 and 0305.

Example of a MR Finding: Consider the very common case in which a
high-safety-significant (HSS) SSC in (a)(2) status has suffered one or
more *MR functional failures* (MRFFs), i.e., failures of one or more of
the functions for which it was included in the scope of the licensee=s
MR program. Typically one or more of the following circumstances exist:
(1) The inspector has determined that the MRFFs were maintenance
preventable (i.e., were MPFFs), but the licensee has not recognized
this. If counted appropriately as an MPFF, the latest MRFF would exceed
the licensee-established (a)(2) unreliability performance criterion
(PC); and/or (2) the latest MPFF constituted a repetitive MPFF (i.e.,
same type of failure and same cause or type of cause); and/or (3)
regardless of the PC, the number of failures (and/or associated
unavailability) is excessive by one or more objective standards, e.g.,
the EPRI PRA Applications Guide, NRC, vendor or industry guidance
(including NEI, INPO, EPRI, and users or owners groups) or prevailing
industry practice or operating experience. In any of these three cases,
the circumstances may support an inspector determination that the
licensee has failed to demonstrate for the affected (a)(2) SSC that its
performance or condition has or is being effectively controlled through
appropriate preventive maintenance; although in the third case,
consultation with NRR and OE staff is required. This demonstration must
be made in order for the affected SSC/function to remain in (a)(2)
status under the MR. But having failed to make this demonstration, the
licensee must set goals and monitor the performance or condition of the
affected SSC under (a)(1) to be in compliance with the MR.

In practice, when licensees consider putting the affected SSC/function
in (a)(1), but can justify not doing so by reason, for example, of the
root cause being either corrected or unrelated to the equipment itself
(e.g., personnel issues only), then they may be deemed to be in
compliance with the MR while allowing the affected SSC/function to
remain in (a)(2) status. However, if the circumstances warrant
monitoring the affected SSC/function under (a)(1), and the licensee
commences monitoring under (a)(1) within a reasonable amount of time,
and takes prompt and adequate corrective action in case goals are not
met, there has, thus far, been no violation of the MR in this scenario.
Therefore, when the inspector reviews the circumstances described above,
and determines that the licensee has not yet complied with the MR, the
inspector must then determine whether the time that has passed since the
licensee=s first opportunity to comply is excessive, in which case, a
violation may be identified. In making this determination consider the
following:

When the inspector=s concerns are brought to the attention of the
licensee, the licensee may immediately recognize the situation, convene
its expert panel and at least consider putting the affected SSC into
(a)(1). In this case, the licensee may have avoided an MR violation
unless an excessive amount of time has already passed and/or the
licensee has missed one or more reasonable opportunities to comply.
However, the inspector should also expect the licensee to take prompt
corrective action for the degraded performance or condition of the SSC
regardless of the MR disposition. There may still be grounds for a
violation of Criterion XVI of 10 CFR Part 50, Appendix B, for inadequate
corrective action for previous failures, assuming the affected SSC is
safety-related.

The second common situation is that the series of MPFFs that invalidated
the (a)(2) demonstration occurred some time ago, for example, before the
licensee=s last (a)(3) periodic evaluation, one or more expert panels
have been convened without addressing the issue, or more than one
rolling MR monitoring period has gone by, and the licensee has never
recognized that the SSC in question should have been in (a)(1). In this
case, there has clearly been a violation of (a)(2) and/or (a)(1) in that
effective preventive maintenance was not demonstrated under (a)(2), yet
the SSC was never put in (a)(1) despite several opportunities for the
licensee to comply with the MR. In either of the foregoing situations,
to determine the appropriate MR finding category, the history of the
performance or condition of the affected SSC(s)/function(s) must be
considered.

Category II Scenario: If during the period following the MPFF that first
invalidated the (a)(2) demonstration, there were no further MPFFs, no
additional related unavailability, or no further degradation of the
condition of the affected SSC(s)/function(s), then the equipment
problems are not considered attributable to the associated (a)(2)
violation. Therefore this situation would be consistent with Category
II. Accordingly, the non-MR performance deficiencies/findings
contributing to the equipment problems would be dispositioned as
otherwise provided for under the ROP. However, the associated,
more-than-minor, but non-contributory MR violation, identified as a
separate consequence of the equipment problems, would be colored green
by default and documented separately, but as an additional finding
related to the other non-MR ME findings.

Category III Scenario: However, if when the MR finding is identified by
the inspector, the historical review reveals a continued declining trend
in performance, i.e., more MPFFs and/or more unavailable hours after the
MPFF or amount of unavailability that first invalidated the (a)(2)
demonstration, such that failure to place the affected SSC/function in
(a)(1) has resulted in continued inadequate attention or corrective
action, then this is a Category III MR finding in that the MR (a)(2)
violation has contributed to the continued degraded performance of the
affected equipment. In this case, the MR violation and all other
contributing causes would be considered together. To determine the
significance of the composite finding, the resultant equipment problems
would not be aggregated, but the safety/risk significance of the most
severe of them would be processed through the SDP to color the finding.
Note that this single colored finding could comprise multiple
contributory performance deficiencies and violations, including MR
violations.

Other types of Category III MR findings would include, for example, an
(a)(3) violation in which there are MPFFs as a direct consequence of
failing to take industry operating experience into account, or a scoping
violation of (b)(1) or (b)(2) in which failure to include an SSC or
function in the scope of the MR program when required resulted in the
failure to recognize that no preventive maintenance or inadequate
preventive maintenance was being performed; which then resulted in
excessive MPFFs, excessive unavailability, or degraded condition of the
affected SSC, or failure even to recognize that the performance or
condition of the affected SSC/function was excessively degraded.

Finally, for regulatory assessment under the ROP, it is appropriate to
view the licensee=s MR program as one part of their overall problem
identification and resolution program. When an ME finding has problem
identification and resolution or human performance aspects, these
cross-cutting issues should be identified within the finding. The
cross-cutting aspects should be documented as a contributing cause of
the finding. Guidance related to evaluating and documenting issues in
cross-cutting area is provided in IMC 0305 and IMC 0612.

APPENDIX E

Documenting Maintenance Effectiveness (ME) Findings

ME findings should be documented according to the format prescribed by
IMC 0612 for the findings section of an item under AReport Details,@
i.e., an introduction section, description of the findings, an analysis
section, and an enforcement section. In order to supplement that
guidance, in view of varying inspector experience and the need for
standardization, the following specific guidelines for documenting ME
findings (particularly those involving MR violations) in inspection
reports are provided. Although it is recognized that many instances are
complex and do not fit preconceived patterns, use of the standard
language and structure suggested herein to the extent practicable is
expected to greatly facilitate expeditious processing of findings.

[In the introduction section]{.underline}, briefly state the finding
(Abottom-line result@), the safety/risk characterization and/or any
enforcement or severity level. Use a short phrase to describe the
regulatory requirement violated and how it was violated, as applicable.
Note that the standard language for this section (within quotation marks
in the examples) was crafted in view of its frequent publication in
plant issues matrices (PIMs) which need to be understandable by the
public. Examples:

\[(a)(1) violation\]:

> A(Green) The licensee failed to take timely and adequate corrective
> action for the failures of the AA@ service water pump to run for its
> required mission time due to high bearing temperatures. These failures
> caused the pump not to meet its monitoring goals established pursuant
> to Paragraph (a)(1) of 10 CFR 50.65, the Maintenance Rule. The
> regulation requires corrective action for components being monitored
> under Paragraph (a)(1) that do not meet their monitoring goals. A
> non-cited violation of 10 CFR 50.65(a)(1) was identified.@

This scenario may represent a Category II finding (automatic green) if
identified when the SSC first fails to meet its goals. However, it is
consistent with a Category III finding when unsatisfactory equipment
performance or condition is aggravated or persists as a result of the
(a)(1) violation, i.e., in this case, inadequate corrective action.
Absent actual SSC degraded performance or condition, most other types of
(a)(1) violations will be Category I (minor). The category of the
finding need not be documented in the report but is used only to
determine the appropriate disposition of the finding in regulatory
review.

\[(a)(2) violation\]:

> A(Green) The licensee failed to set goals and monitor the performance
> \[and/or condition\] of the 22 CVC pump as required by
> 10CFR50.65(a)(1), and had no justification for not doing so, after it
> had failed to demonstrate effective control of the performance or
> condition of the pump through appropriate preventive maintenance. Per
> 10 CFR 50.65(a)(2), effective control of SSC performance or condition
> through appropriate preventive maintenance must be demonstrated in
> order for the monitoring under Paragraph (a)(1) not to be required.
> Therefore, a non-cited violation of 10 CFR 50.65(a)(2) was
> identified.@

This scenario would be a Category II finding if no further degradation
of performance or condition has occurred after that which first
invalidated the (a)(2) demonstration and after the licensee had a
reasonable amount of time and/or number of opportunities to comply. It
would be Category III if lack of adequate attention due to remaining in
(a)(2) contributed to further or prolonged degraded performance or
condition.

\[(a)(3) violation\]:

> A(\[Greater than Green\]) During its most recent periodic evaluation
> of its maintenance rule program performed pursuant to 10 CFR
> 50.65(a)(3), the licensee failed to take industry operating experience
> into account (when practicable) as required by Paragraph (a)(3).
> Specifically, the licensee failed to incorporate recommended
> maintenance actions specified in a vendor technical service bulletin
> on the emergency diesel generator (EDG) in its preventive maintenance.
> This resulted in a subsequent failure of the diesel engine while the
> other EDG was unavailable. A violation of 10 CFR 50.65(a)(3) was
> cited.@

This kind of finding would be characterized per the SDP. This example is
greater than green because of its safety significance. It must also be
Category III for that reason, but more fundamentally because the (a)(3)
violation directly contributed to the EDG failure. However, absent
actual consequences in terms of degraded performance or condition of
SSCs, most (a)(3) violations will be minor.

\[(b)(1) violation\]:

> A(Green) The licensee failed to include the vital station battery
> circuit breakers within the scope of its maintenance rule program as
> required by 10 CFR 50.65(b)(1) and therefore did not recognize that
> appropriate preventive maintenance was not being performed. Failure to
> perform preventive maintenance on the breakers resulted in a failure
> of the AB@ breaker during a test which indicated that the breaker
> would have failed upon demand in service. A non-cited violation of 10
> CFR 50.65(b)(1) was identified.@

This is another Category III MR finding because the functional failure
(in this case, failure of the breaker=s overload/fault trip function)
was a consequence of the MR violation. The safety significance of this
Category III finding would be determined using the SDP.

[Description of findings section]{.underline}: The description of
findings should summarize the facts and circumstances surrounding the
issue in the form of a brief chronology of events. The MR-related
performance deficiency should be clearly described, citing applicable
requirements. Category II findings should be described as separate
consequences of the equipment performance deficiencies. Category III
findings, as in the (a)(1) violation example below, are described as
being a contributing cause of the equipment performance deficiencies.
Cite, if relevant, any missed opportunities for licensee compliance with
the MR such as expert panel meetings, (a)(3) periodic evaluations, or
even the passing of multiple monitoring periods or cycles after action
should have been taken. Example \[(a)(1) violation\]:

> A[Discussion]{.underline}: The AA@ service water pump was included
> within the scope of the MR under 10 CFR 50.65(b)(2)(i). It is
> non-safety-related, but is relied upon in mitigating accidents and
> transients. The pump had been placed in (a)(1) status under the MR in
> December 2001 after having suffered its second maintenance-preventable
> functional failure (MPFF) within one year. The failures had been
> increasingly high bearing temperatures, eventually rising above alarm
> setpoints requiring immediate pump shutdown on the occasions when it
> was run. The (a)(1) reliability goal (and condition for returning the
> pump to (a)(2) status) that the licensee had established for the pump
> was zero Maintenance Rule functional failures (MRFFs) for the next
> 6-month period in which the pump would see at least two valid demands.
> However, the licensee had only performed routine preventive
> maintenance and had made the AA@ pump the one normally in standby. On
> January 12, 2002, after being placed on service after preventive
> maintenance (shaft packing renewal), the AA@ pump failed to run longer
> than 15 minutes before another high bearing temperature alarm was
> received. At that moment, a nearby auxiliary mechanical operator
> observed smoke coming from the area of the pump shaft packing gland.
> The AA@ pump was immediately stopped from the control room and the now
> standby AB@ pump picked up and ran normally. Upon a cursory
> examination of the pump, technicians found that the shaft packing
> gland was too tight. The gland was loosened to obtain proper leak off
> and the AA@ pump was released to Operations for unlimited service. It
> was declared available and operable, but placed back in standby.
> However, the inspector learned later that the licensee had made no
> attempt to determine the cause of the high bearing temperature alarm.
> Approximately one month later, on February 10, 2002, the inspector
> inquired about the status of the pump. The licensee stated that the
> pump was still in (a)(1) status, awaiting completion of the so-called
> Aget-well@ period so that it could be returned to (a)(2). The
> inspector asked about the failure on January 12 because as of that
> incident, the (a)(1) reliability monitoring goal for the pump had not
> been met. The licensee stated that the problem that caused the January
> failure had been corrected and the expert panel had determined that
> the pump needed only to operate successfully two times to be placed
> back in (a)(2). One week later on February 18, the AA@ service water
> pump was placed in service in order to perform preventive maintenance
> on the AB@ pump. After having started the AA@ pump once more,
> operators noticed bearing temperature rising rapidly and shut the pump
> down just as the high temperature alarm was received. In looking into
> this failure, the inspector learned that a high bearing temperature
> alarm had been received in January as well, but that its cause had not
> been found and corrected. The pump had failed to meet this goal with
> its failure to be able to run for its required mission time on January
> 12, but the licensee had not taken adequate corrective action in that
> it failed to find and correct the cause(s) of the bearing overheating.
> By now, the licensee had over a month since the January failure when
> the pump had failed to meet its (a)(1) reliability monitoring goal to
> find the cause of the overheating problem and correct it, but despite
> this time and several opportunities to recognize the problem, the
> licensee had failed to do so. At this point, the inspector determined
> that the licensee had violated (a)(1) by failing to take adequate
> corrective action when an SSC in (a)(1) failed to meet its goal.
> Subsequently, the licensee determined that the cause of the bearing
> overheating had not been related to the over-tightened packing gland
> as had apparently been erroneously assumed, but without any
> confirmation. Instead, after extensive and more rigorous
> troubleshooting the licensee found that the separately mounted pump
> and motor had excessive runout (i.e., they had come severely out of
> alignment). The licensee corrected the misalignment, but its cause had
> not been determined as of the time of the inspection.@

For issues involving MR scoping violations, explain why the affected
SSCs/functions should be within the scope of the MR, citing the scoping
criterion(a) under which the SSCs/functions in question should have been
included. Then discuss any consequences of the scoping deficiencies with
some risk significance (e.g., attributable degraded performance or
condition of the associated SSCs/functions).

For issues/findings involving in-scope SSCs/functions, discuss the
following: performance or condition problems that should have prompted
licensee actions and any continued degradation or further unsatisfactory
performance after action should have been taken as applicable; licensee
recognition and characterization of those problems and your assessment
of the appropriateness of that characterization; MR status of the
affected SSC(s)/function(s) and its appropriateness, any changes in MR
status, licensee rational for making MR status changes (or not) and its
validity; whether the problems caused (a)(2) performance criteria or
(a)(1) goals not to be met; and licensee handling of the issue and its
appropriateness with regard to the MR.

For issues involving SSCs/functions in (a)(2), make it clear that
deficiencies related to (a)(2) performance criteria and tracking
availability and reliability against those criteria are being described
only as supporting information for the determination of whether the
licensee has demonstrated effective control of the performance or
condition of the affected SSCs/functions through appropriate preventive
maintenance; this being the relevant regulatory consideration. Cite
basis(es) (e.g., repetitive MPFFs, industry standards, etc.) for any
determinations that unreliability and/or unavailability are excessive
such that it invalidates the demonstration of effective preventive
maintenance under (a)(2) regardless of the performance criteria, if
applicable (Note that this determination requires NRR/OE consultation).
Also, discuss corrective actions for the equipment problems themselves,
stating if and how the corrective action addressed the problem. In
addition, discuss any ME issues of broader significance than MR
compliance, such as work practices, maintenance support problems,
common-cause problems and cross-cutting issue aspects.

[In the analysis section]{.underline}, per IMC 0612, describe the logic
for entering the SDP, how it was used, and the assumptions, using the
guidance and example for determining MR violation significance with the
SDP that is prescribed above in the Regulatory Review section of this
procedure. If appropriate (RR Category II), characterize the ME
finding/MR violation as being an additional, but separate consequence of
the degraded performance or condition of the associated SSCs/functions;
or, if appropriate (RR Category III), characterize the ME finding/MR
violation as a contributing cause of the degraded performance or
condition of the associated SSCs/functions. Describe any cross-cutting
issue aspects of the finding. In answering Question (1) in Appendix B to
IMC 0612, analysis section, use the considerations in the MR section
(8.1.11) of the Enforcement Manual and the MR examples in Appendix E to
IMC 0612 to establish how/why the issues are more than minor. Example:
\[(a)(1) violation\]

> A[Analysis]{.underline}: The inspector determined that the licensee=s
> performance deficiency was failing to address all the failure modes of
> a risk-significant component. This deficiency posed an actual safety
> concern and had resulted in additional component failures. Further,
> the inadequately addressed degraded condition of the component in
> question, if left uncorrected could have more serious safety/risk
> consequences. Therefore, the performance deficiency was more than
> minor and was a finding. In determining the significance of this
> finding using the reactor safety SDP, the inspector noted that
> although the AA@ service water pump had suffered several failures
> before the licensee had recognized the problem, determined its cause,
> and corrected it, the AB@ pump had remained available. Therefore, the
> pump failures were of very low safety significance (Green). This
> finding also has cross-cutting issue implications, i.e., weakness in
> problem identification and resolution.@

Follow the guidance in IMC 0612 for the enforcement section. For the
(a)(1) example violation above, the enforcement section would read as
follows:

> A[Enforcement]{.underline}: Paragraph (a)(1) of 10 CFR 50.65 requires
> that corrective action be taken for structures, systems or components
> being monitored under (a)(1) that do not meet their
> licensee-established monitoring goals. Contrary to the above, the
> licensee failed to take adequate and timely corrective action for the
> overheated bearing problem and the resultant failures that caused the
> pump not to meet its (a)(1) reliability monitoring goal, despite a
> reasonable length of time and several opportunities to find and
> correct the problem. Because this violation was determined to be of
> very low safety significance (Green) and because the licensee entered
> the finding into its corrective action program, the violation was
> treated as a non-cited violation.@

[10 CFR APPENDIX B CORRECTIVE ACTION]{.underline}. For safety-related MR
SSCs (MR paragraph (b)(1)), the determination of adequacy of corrective
actions may also be evaluated against the requirements of 10 CFR Part
50, Appendix B, Criterion XVI.

ATTACHMENT

Revision History - IP 71111.12

+--------+--------+------------------------------+-----+-------+-------+
| Comm   | Issue  | Description of Change        | Tr  | Tra   | Co    |
| itment | Date   |                              | ain | ining | mment |
| Tr     |        |                              | ing | Compl | Resol |
| acking |        |                              | Nee | etion | ution |
| Number |        |                              | ded | Date  | Acce  |
|        |        |                              |     |       | ssion |
|        |        |                              |     |       | N     |
|        |        |                              |     |       | umber |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 03     | Completed Four-year          | NO  | N/A   | N/A   |
|        | /13/06 | historical review            |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 07/0   | Revised to clarify           | NO  | N/A   | N/A   |
|        | 1/2002 | inspection objectives and to |     |       |       |
|        |        | improve effectiveness of     |     |       |       |
|        | CN     | this procedure based on      |     |       |       |
|        | 02-025 | feedback and lessons learned |     |       |       |
|        |        | from implementation. This    |     |       |       |
|        |        | revision provides greater    |     |       |       |
|        |        | focus on reviewing           |     |       |       |
|        |        | licensee\'s effectiveness at |     |       |       |
|        |        | performing routine           |     |       |       |
|        |        | maintenance. The revised     |     |       |       |
|        |        | procedure also focuses on    |     |       |       |
|        |        | review of equipment          |     |       |       |
|        |        | performance issues           |     |       |       |
|        |        | associated with availability |     |       |       |
|        |        | and reliability, preferably  |     |       |       |
|        |        | on high‑risk significant     |     |       |       |
|        |        | systems, maintenance work    |     |       |       |
|        |        | practices, and common cause  |     |       |       |
|        |        | issues. Sample size and      |     |       |       |
|        |        | inspection resource          |     |       |       |
|        |        | requirements were revised    |     |       |       |
|        |        | based on experience gained   |     |       |       |
|        |        | from four verification and   |     |       |       |
|        |        | validation visits at one     |     |       |       |
|        |        | site in each region.         |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 01/0   | Inspection frequency was     | NO  | N/A   | N/A   |
|        | 5/2006 | changed from a biennial to a |     |       |       |
|        | CN     | triennial frequency based on |     |       |       |
|        | 06-001 | a mature industry            |     |       |       |
|        |        | maintenance program.         |     |       |       |
|        |        | Additionally, estimated      |     |       |       |
|        |        | inspection hours were        |     |       |       |
|        |        | changed to 36 hours every 3  |     |       |       |
|        |        | years or annualized estimate |     |       |       |
|        |        | of 12 hours based on the     |     |       |       |
|        |        | actual inspection resources  |     |       |       |
|        |        | expended to complete this    |     |       |       |
|        |        | inspection procedure during  |     |       |       |
|        |        | last several ROP cycles.     |     |       |       |
|        |        | Completed historical CN      |     |       |       |
|        |        | search.                      |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| NA     | 03     | IP71111-12 has been revised  | NO  | N/A   | N/A   |
|        | /13/06 | to clarify inspection        |     |       |       |
|        |        | objectives and to improve    |     |       |       |
|        | CN     | effectiveness of this        |     |       |       |
|        | 06-006 | procedure based on feedback  |     |       |       |
|        |        | and lessons learned from     |     |       |       |
|        |        | implementation.              |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 10     | IP71111.12 has been revised  | NO  | N/A   | N/A   |
|        | /31/07 | to reflect the ROP FY-2007   |     |       |       |
|        |        | realignment. The triennial   |     |       |       |
|        |        | inspection was eliminated    |     |       |       |
|        |        | because it was determined    |     |       |       |
|        |        | adequate oversight of        |     |       |       |
|        |        | licensee performance in the  |     |       |       |
|        |        | area of maintenance can be   |     |       |       |
|        |        | maintained through the       |     |       |       |
|        |        | quarterly portion of IP      |     |       |       |
|        |        | 71111.12 and other           |     |       |       |
|        |        | inspection activities..      |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 01     | IP 71111.12 has been revised | NO  | N/A   | N/A   |
|        | /31/08 | to clarify the level of      |     |       |       |
|        |        | effort section in which the  |     |       |       |
|        | CN     | inspection procedure clearly |     |       |       |
|        | 08-005 | states that the samples are  |     |       |       |
|        |        | not required on a quarterly  |     |       |       |
|        |        | basis.                       |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+