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NRC INSPECTION MANUAL IIPB

INSPECTION PROCEDURE 62706

MAINTENANCE RULE

PROGRAM APPLICABILITY: 2515

62706-01 INSPECTION OBJECTIVE

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

62706-02 INSPECTION REQUIREMENTS

Verify Implementation of the Maintenance Rule. Perform the following reviews to verify the ˇ

licensee's implementation of the maintenance rule (i.e., the rule), following the guidance of ˇ

Nuclear Management and Resources Council (NUMARC) 93-01, “Industry Guideline for Monitoring ˇ

the Effectiveness of Maintenance at Nuclear Power Plants,” (Ref. 2).

02.01 Goal Setting and Monitoring, 50.65(a)(1). Verify that the licensee has implemented goal

setting and monitoring as required by paragraph (a)(1) of the rule. The licensee is required by the

rule to perform the following:

a. Monitor the performance or condition of structures, systems, and components (SSCs)

against licensee-established goals, in a manner sufficient to provide reasonable assurance

that such SSCs, as defined in 10 CFR 50.65(b), are capable of fulfilling their intended

functions.

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

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

meet established goals.

02.02 Preventive Maintenance, 50.65(a)(2). For those SSCs that are within the scope of the rule

but are not monitored under paragraph (a)(1) of the rule, verify that the licensee has demonstrated

the following:

a. Performance or condition of a SSC is being effectively controlled through the performance

of appropriate preventive maintenance such that the SSC remains capable of performing

its intended function; or,

b. The SSC is inherently reliable and has low safety significance; therefore, preventive

maintenance may not be required (i.e., perform corrective maintenance only).

c. The SSCs that provide little or no contribution to system safety function could be allowed

to run to failure (i.e., perform corrective maintenance rather than preventive maintenance).
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02.03 Periodic Evaluation, 50.65(a)(3). Verify that the licensee is performing the periodic

evaluations and safety assessments required by paragraph (a)(3) of the maintenance rule.

a. The licensee shall evaluate performance and condition monitoring activities, associated

goals, and preventive maintenance activities at least every refueling cycle, provided that

the interval between evaluations does not exceed 24 months. The evaluations shall

consider industry-wide operating experience, where practical.

b. The licensee shall make adjustments where necessary to ensure that the objective of

preventing failures of SSCs through maintenance is appropriately balanced against the

objective of minimizing unavailability of SSCs due to monitoring or preventative

maintenance activities.

ˇ

ˇ See Inspection Procedure 71111.12, “Maintenance Rule Implementation.”

ˇ 02.04 Safety Assessments Before Performing Maintenance, 50.65(a)(4). Verify that the licensee

ˇ assesses and manages increases in risk before performing maintenance activities required by

ˇ paragraph (a)(4) of the maintenance rule.

ˇ

ˇ See Inspection Procedure 71111.13, “Maintenance Risk Assessments and Emergent Work

ˇ Control.”

ˇ

ˇ 02.05 Scope of the Rule, 50.65(b). Verify that the licensee has identified those SSCs that are

ˇ required to be within the scope of the maintenance rule, as defined in paragraph 50.65(b) of the

ˇ rule.

ˇ

62706-03 INSPECTION GUIDANCE

General Guidance

Inspection Requirements. All inspection requirements listed in Section 02 do not have to be

performed during each inspection. NRC management may decide that specific inspection

requirements be reviewed for implementation of the maintenance rule based on plant performance

indicating a potential weakness in a particular inspection requirement. In addition, NRC

management may decide to select specific inspection requirements to be performed based on the

allocation of resources available. The items selected for review will depend on the intended scope

of the inspection and the resources allotted for the inspection. In addition, inspectors should also

note that despite the fact that items selected for review are listed under inspection requirements,

they may not be explicitly stated in the maintenance rule. Rather, these items may be derived from

Regulatory Guide 1.160, “Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,”

(Ref 3) or NUMARC 93-01, which are optional guidance documents and, therefore, would not

apply to those licensees who implement the rule using other methods.

Implementation Guidance. Except when the licensee proposes an alternate method for complying

with specified portions of the maintenance rule, the methods described in Regulatory Guide 1.160

will be used to evaluate the effectiveness of maintenance activities of licensees who are required

ˇ to comply with the maintenance rule. Regulatory Guide 1.160 endorses NUMARC 93-01 and

provides methods acceptable to the NRC for complying with the maintenance rule. The inspector

should also be aware that licensees may use methods other than those described in Regulatory

Guide 1.160 and NUMARC 93-01 to satisfy the requirements of the maintenance rule. Where

other methods are used, the licensee must demonstrate that those methods satisfy the

requirements of the rule.

Requirements vs. Acceptable Methods. The information provided in the specific guidance section

of this procedure was derived from information contained in the maintenance rule, the statements
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of consideration (SOC) for the rule (Ref. 4), Regulatory Guide 1.160, and the industry guideline,

NUMARC 93-01. Reference was made to the source document, where possible, in order to help

the inspector differentiate between the regulatory requirements and recommendations. In general,

anything that is stated in the rule itself is a requirement. The SOC does not contain requirements

but does contain information that could be used to clarify the intent of the requirements.

Information derived from Regulatory Guide 1.160 and its endorsed industry guideline, NUMARC

93-01, provide acceptable methods for complying with the rule, but they are not regulatory

requirements. If the licensee chooses not to implement the maintenance rule in accordance with

the regulatory guide and the industry guideline, then the licensee must demonstrate that the

alternate methods satisfy the requirements of the rule.

Most licensees have implemented the maintenance rule using the guidance contained in NUMARC

93-01. However, licensees have also used other methods that the NRC staff has found acceptable

for implementing the rule. Inspectors should determine whether the licensee has taken ˇ

exceptions to NUMARC 93-01 and has documented justifications for these exceptions. Exceptions ˇ

to NUMARC 93-01 shall meet the requirements of the rule.

Decommissioned Plants. Manual Chapter 2561, “Decommissioning Power Reactor Inspection

Program,” provides guidance and requirements for the inspection of maintenance and surveillance

activities at power reactors that have submitted 10 CFR 50.82(a)(1) certifications. Inspectors

should use Inspection Procedure 62801, “Maintenance and Surveillance at Permanently Shutdown

Reactors,” when inspecting maintenance rule requirements at power reactors with 50.82(a)(1)

certifications.

ˇ

Maintenance Rule Guideline Book. The Quality Assurance and Maintenance Branch (IQMB)

compiled a Maintenance Rule Guideline Book which contains NRC and industry guidance on

acceptable methods to implement the individual requirements of the maintenance rule. The

inspection requirements for the maintenance rule are listed in Sections 2.01 through 2.05 of this

procedure. The inspector should refer to the Maintenance Rule Guideline Book for additional

inspection guidance. The Maintenance Rule Guideline Book includes information such as:

ˇ 10 CFR 50.65, “Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants”

ˇ Statements of Consideration for 10 CFR 50.65, Federal Register, Vol. 56, No. 132, July 10,

1991, pages 31306—31323 (56 FR. 31306)

ˇ 10 CFR 50.65(a)(1), “Rule Change, Monitoring the Effectiveness of Maintenance at Plants in a

Decommissioning Status” Federal Register, Vol. 61, No 146, July 29,1996, pages 39278, 39288

& 39301 (61 FR 39278)

ˇ Statements of Consideration for 10 CFR 50.65(a)(4), Federal Register, Vol 64, No. 137, dated

July 19, 1999, pages 38551-38557 (64 FR 38551)

ˇ Regulatory Guide 1.160, “Monitoring the Effectiveness of Maintenance at Nuclear Power Plants”

ˇ Regulatory Guide 1.182, “Assessing and Managing Risk Before Maintenance Activities at

Nuclear Power Plants, dated May, 2000

ˇ NUMARC 93-01, “Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear

Power Plants”

ˇ Inspection Procedure (IP) 62706, “Maintenance Rule.”

ˇ Inspection Procedure (IP) 62707, “Maintenance Observations,” April 22, 1996

ˇ IP 71111, Attachment 12, “Maintenance Rule Implementation.”
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ˇ IP 71111, Attachment 13, “Maintenance Risk Assessments and Emergent Work Control.”

ˇ Maintenance Rule Enforcement Guidance

ˇ Simplified Maintenance Rule Flow Chart

Historical Information. In addition to the Maintenance Rule Guideline Book, historical information

is contained in NUREG-1526, “Lessons Learned From Early Implementation of the Maintenance

Rule at Nine Nuclear Power Plants,” dated June 1995 (Ref. 6). Temporary Instruction 2515/126,

"Evaluation of On-Line Maintenance," was used by inspectors to verify the level of utility control

for on-line maintenance activities while at power.

ˇ

ˇ Lessons Learned from Maintenance Rule Baseline Inspections. Licensees are expected to have

ˇ reviewed information contained in NUREG-1648, “Lessons Learned from Maintenance Rule

ˇ Baseline Inspections,” dated October 1999 (Ref 7). This document contains information on unique

ˇ and diverse methods licensees used to implement the maintenance rule that went beyond the

ˇ guidance contained in the documents noted above. Licensees can use this information to improve

ˇ site-specific maintenance rule programs.

ˇ

ˇ Specific Guidance

03.01 Goal Setting and Monitoring, 10 CFR 50.65(a)(1). The licensee is required to set goals

and monitor the performance or condition of those SSCs handled under paragraph (a)(1) of the

rule.

The licensee should consider monitoring SSCs under the requirements of paragraph (a)(1) of the

maintenance rule when failures occur, performance criteria are not being met under paragraph

(a)(2), adequate preventive maintenance has not been established, or cause determinations and

corrective actions are needed to improve SSC performance. If any of the above conditions exist,

the licensee should consider establishing goals commensurate with safety and, where practical,

ˇ take into account industry wide-operating experience.

03.02 Preventive Maintenance, 50.65(a)(2). The maintenance rule states that monitoring of an

SSC as specified in paragraph (a)(1) is not required if it has been demonstrated that the

performance or condition of the SSC is being effectively controlled through the performance of

appropriate preventive maintenance so that the SSC remains capable of performing its intended

function. The SOC clarify that licensees are not required to monitor under paragraph (a)(1) of the

rule if they have demonstrated that preventive maintenance has been effective or if an SSC has

inherent high reliability and availability.

The licensees must be able to demonstrate that an effective preventive maintenance program

exists in controlling the performance or condition of an SSC so that the SSC remains capable of

performing its intended function. Although no monitoring process is required by paragraph (a)(2),

in order to assure itself, the licensee needs to establish some evaluation or monitoring process

under paragraph (a)(2) of the maintenance rule to verify that preventive maintenance is effective.

ˇ 03.03 Periodic Evaluations Under 50.65 (a)(3). The licensee is required by paragraph (a)(3) of

the maintenance rule to perform the following periodic evaluations:

The licensee must perform the periodic evaluations at least once per refueling cycle, not to exceed

an interval of 24 months. Adjustments shall be made to goals, performance criteria, or preventive

maintenance when equipment performance has not met established goals or performance criteria.

The licensee should consider industry operating experience, where practical, when establishing

goals. Adjustments shall be made where necessary to ensure that the objective of preventing

failures of SSCs through maintenance is appropriately balanced against the objective of minimizing

unavailability of SSCs due to monitoring or preventive maintenance activities.

ˇ
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03.04 Assessing and Managing Increases in Risk Before Performing Maintenance, 50.65(a)(4).

The licensee is required by paragraph (a)(4) to assess and manage the increase in risk that may

result from the proposed maintenance activities before these maintenance activities are performed.

These maintenance activities include but are not limited to surveillances, post-maintenance testing,

and corrective and preventive maintenance activities. The licensee may limit the scope of the

assessment to SSCs that a risk-informed evaluation process has shown to be significant to public

health and safety.

The licensee should implement the requirements of this section using the guidance contained in

NUMARC 93-01, Section 11, “Assessment of Risk Resulting from the Performance of Maintenance

Activities,” dated February 22, 2000, as endorsed of RG 1.182, dated May 2000.

03.05 Scope of the Rule, 50.65(b). Under paragraph (b) of the maintenance rule, the licensee

must identify safety-related SSCs that are relied upon to remain functional during and following

design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability

to shut down the reactor and maintain it in a safe shutdown condition, or the capability to prevent

or mitigate the consequences of accidents that could result in potential offsite exposures

comparable to 10 CFR Part 100 guidelines. In addition, the licensee must identify non-safetyrelated SSCs that: (1) are relied upon to mitigate accidents or transients or are used in the plant

emergency operating procedures, or (2) whose failure could prevent safety-related systems from

performing their intended safety-related function, or (3) whose failure could cause a reactor scram

or actuation of a safety-related system.

The licensee must document all SSCs that have been identified as being under the scope of the

maintenance rule. The licensee should use the guidance contained in RG 1.160 and NUMARC 93-

01 to implement their program for identifying safety-related and non-safety-related SSCs under the

scope of the maintenance rule but may consider other methods.

ˇ

62706-04 RESOURCE ESTIMATE

A maintenance rule baseline inspection team utilizes five to six inspectors to complete the

inspection. The team consists of one team leader, three to four inspectors performing maintenance

rule program reviews and sample reviews of SSCs under the scope of the maintenance rule to

verify that all maintenance rule requirements have been implemented for each SSC. In addition,

one specialist inspector, utilizing probabilistic risk assessment (PRA) expertise, determines if the

licensee is appropriately using PRA to implement maintenance rule requirements for high safety

(risk) significant (HSS) and low safety (risk) significant (LSS) SSCs under the scope of the

maintenance rule.

Completion of this inspection procedure is expected to take a minimum of 600 inspection hours:

five inspectors for 3 weeks performing 1 week of inspection preparation, 1 week on-site, and 1

week of inspection documentation.

62706-05 REFERENCES

U.S. Nuclear Regulatory Commission, 10 CFR 50.65, "Requirements for Monitoring the

Effectiveness of Maintenance at Nuclear Power Plants" (the maintenance rule)

Nuclear Management and Resources Council, NUMARC 93-01, "Industry Guideline for Monitoring

the Effectiveness of Maintenance at Nuclear Power Plants."

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.160, "Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants"
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U.S. Nuclear Regulatory Commission, Statements of Consideration, "Monitoring the Effectiveness

of Maintenance at Nuclear Power Plants," Federal Register, Vol. 56, No. 132, Wednesday July 10,

1991, pages 31306 to 31323

Maintenance Rule Guideline Handbook

U.S. Nuclear Regulatory Commission, NUREG 1526, "Lessons Learned From Early

Implementation of the Maintenance Rule at Nine Nuclear Power Plants," June 1995

U.S. Nuclear Regulatory Commission, NUREG-1648, “Lessons Learned from Maintenance Rule

Baseline Inspections,” dated October, 1998

END