Issue Date: 08/13/13 1 62712

NRC INSPECTION MANUAL SPRA

INSPECTION PROCEDURE 62712

PART 52, MAINTENANCE RULE 

PROGRAM APPLICABILITY: 2504

62712-01 INSPECTION OBJECTIVE

01.01 To determine whether there is reasonable assurance that the licensee’s Maintenance 

Rule (MR) program will meet the requirements set forth by 10 CFR 50.65, Requirements for 

monitoring the effectiveness of maintenance at nuclear power plants and the maintenance rule 

program as specified in the FSAR, once it is fully implemented after the Commission’s 10 CFR 

52.103(g) finding. 

62712-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 General Guidance

Combined license (COL) holders are required to have a fully functional MR program after the 

Commission’s 10 CFR 52.103(g) finding. Certain elements of the licensee’s MR program 

cannot be implemented prior to startup; in these cases, the inspector should verify that there is 

reasonable assurance of future compliance. This should be done by reviewing licensee 

procedures, training and qualification, and any other tools that the licensee will use to implement 

the MR program.

Inspectors should review procedures to verify that they are of sufficient detail and scope to 

provide reasonable assurance that they can be implemented properly. For general guidance on 

determining the adequacy of a procedure, see IP 42401, Plant Procedures.

If the licensee has existing units on the same site, they may credit parts of their existing MR 

program. If this is the case, inspectors should ensure that plant-specific differences are 

accounted for and that any credited aspects of the MR program are applicable to new reactors. 

For example, a new passive plant (AP1000 or ESBWR) may be built next to an active 

PWR/BWR. 

The detailed description of the licensee’s MR program should be consistent with the high level 

programmatic requirements described by the COL Final Safety Analysis Report (FSAR). In 

general, it is expected that most licensees will adopt a program that adheres to the guidance 

contained in NEI 07-02A with supplementary information contained in the FSAR. Licensees 

may supplement their MR program to include a condition monitoring program for underground 

or inaccessible cables which is described in NRC Generic Letter 2007-01. The inspector should 

become familiar with the specifics of the licensee’s program by reviewing the FSAR Section 

17.6 and any other applicable documentation.
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Where the licensee's MR program deviates from what is described in the FSAR, the licensee 

must be able to demonstrate that such deviations or alternate methods meet the requirements 

of the MR. Where deviations or alternate methods are judged to be in compliance with the MR, 

but are not consistent with the licensee's MR program as described in approved licensing basis 

documents, the licensee will be expected to resolve the discrepancies by either modifying the 

program or its implementation to conform to approved licensing basis documents or obtain 

approval for amendments to its licensing basis documents as necessary.

Due to the performance-based nature of the maintenance rule, all potential violations should be 

carefully evaluated to ensure that they are dispositioned correctly. Specific guidance about 

actions involving the maintenance rule is available in Section 7.11 of the U.S. NRC Enforcement 

Manual and Inspection Manual Chapters (IMC) 0613, Power Reactor Construction Inspection 

Reports.

Once a plant is operational, the implementation of the MR will be inspected using inspection 

procedures IP 62706, IP 71111.12, and IP 71111.13.

02.02 Review the licensee’s MR scoping procedure and independently verify that the

structures, systems, and components (SSCs) within the scope of the MR program include 

safety-related SSCs and certain nonsafety-related SSCs. 

Note: This inspection requirement is on a sampling basis. The sample size is to be determined 

based on the number of inspectors and duration of the inspection. 

a. Confirm that the scoping procedure addresses:

 Safety-related SSCs.

 Nonsafety-related SSCs that mitigate accidents or transients.

 Nonsafety-related SSCs that are used in Emergency Operating Procedures (EOPs), 

where ‘used’ means directly used to mitigate the accident or transient via explicit 

reference in the EOP or used in steps of procedures referenced by the EOP. 

Additionally, SSCs explicitly referenced in back-up or lower-tier methods in the EOPs 

and provide reasonable assurance of mitigation success, or whose use is implied in 

an EOP and essential to the completion of an EOP step, are considered within scope 

of the MR.

 Nonsafety-related SSCs whose failure would prevent safety-related SSCs from 

fulfilling their safety-related functions.

 Nonsafety-related SSCs whose failure would cause a scram or actuate safety 

systems.

b. Independently verify that the SSCs within the scope of the MR program are evaluated 

against performance criteria to determine which SSCs will have goals established and 

monitoring activities performed in accordance with 10 CFR 50.65(a)(1).

c. Confirm that safety significance classifications and bases of in-scope SSCs, e.g., high 

safety significance (HSS) or low safety significance (LSS) are determined using 

processes consistent with Section 9.3.1 of NUMARC 93-01 or another NRC-approved 
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methodology. This should include determination of risk significance criteria and 

appropriate consideration of operating experience, generic failure data, component 

reliability information, probabilistic risk assessment (PRA) results and insights that cover 

the initiating events and modes of operation of the PRA required under 10 CFR 50.71(h), 

and the recommendations of an expert panel.

d. Independently verify that all SSCs within the scope of the Reliability Assurance Program 

(RAP) are included within the initial MR scope and are scoped in as HSS SSCs.

e. Independently verify that an expert panel was established prior to fuel load and in 

accordance with NUMARC 93-01 that utilizes operating, maintenance and systems 

expertise, PRA insights, and other applicable information to update and maintain the MR 

scope and SSC classifications.

As part of the inspection, if possible, witness the expert panel engaged in their various 

responsibilities in the MR program. If the expert panel is not engaged in MR activities at 

the time of this inspection, review meeting minutes from several expert panel meetings. 

02.03 Evaluate Licensee’s Plan for Monitoring and Corrective Action per 10 CFR 50.65(a)(1)

Note: SSCs within the scope of the MR may be initially classified as (a)(2) except where 

it is determined that an SSC should be initially classified as (a)(1), e.g., an SSC that fails 

during start-up testing, if determined to be maintenance related. Although it is expected 

that all in-scope SSCs will be classified as (a)(2) during this inspection, confirm that the 

licensee has controls in place that provide guidance about when to place an SSC into 

(a)(1) and clearly define appropriate corrective actions.

a. Independently verify that procedures are in place that call for MR expert panel reviews to 

determine whether SSCs are to be classified as (a)(1).

b. Independently verify that the monitoring goals established for SSCs classified as (a)(1) 

are commensurate with safety significance and consider industry operating experience

with the objective of providing reasonable assurance that the SSC is proceeding to 

acceptable performance levels and that the corrective actions taken were effective.

02.04 Evaluate Licensee’s Plan for Preventive Maintenance per 10 CFR 50.65(a)(2)

a. Independently verify that the licensee’s MR program includes procedures for managing 

SSC performance in accordance with 10 CFR 50.65(a)(2) requirements during plant 

operation consistent with NUMARC 93-01.

b. Independently verify that the effectiveness of maintenance performed on the various 

SSCs, performance criteria are established at the plant, system, train, or component 

level commensurate with safety, risk significance and SSC function. SSC performance 

criteria (e.g., failure rate, unavailability or condition-based) are chosen that are 

reasonable, measurable, and technically appropriate for the purpose of timely 

identification of degraded SSC performance or condition. 
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c. For licensee’s that use PRA to develop their risk significant criteria, independently verify 

that for RAP SSCs within the scope of the maintenance rule, performance criteria are 

consistent with the reliability and availability assumptions used in the PRA.

d. Confirm that when a MR Program performance criterion is not met, the SSC is evaluated 

for (a)(1) classification in accordance with MR program procedures, including review by 

the expert panel. Should the expert panel conclude that the SSC should not be 

classified as (a)(1), or that no (a)(1) monitoring goals need be established, verify that a 

technical justification establishing the appropriateness of continued management of SSC 

performance under (a)(2) is documented and maintained.

e. Confirm the SSCs that provide little or no contribution to system safety function or can 

be allowed to run to failure due to an acceptable risk are categorized in a “run-to-failure” 

status (i.e., perform corrective maintenance rather than preventive maintenance) are 

consistent with NUMARC 93-01. 

02.05 Review Licensee’s Plan for Periodic Evaluation of Monitoring and Preventive 

Maintenance per 10 CFR 50.65(a)(3)

a. Independently verify that the MR program includes procedures for the periodic 

evaluation of the performance and condition monitoring activities and associated goals 

and preventive maintenance activities in accordance with 50.65(a)(3). The licensee’s 

controlling documents should have clear guidance on:

 How procedures govern the scheduling and timely performance of (a)(3) evaluations.

 Documenting, reviewing and approving evaluations, providing and implementing 

results.

 Review of 50.65(a)(1) goals and 50.65(a)(2) performance criteria, condition

monitoring criteria, SSC performance and condition history and effectiveness of 

corrective action.

 Making adjustments to achieve or restore balance between reliability and availability.

 How to use industry operating experience.

02.06 Evaluate Licensee’s Plan for Risk Assessment and Risk Management per 10 CFR 

50.65(a)(4)

a. Independently verify that the MR program includes procedures for maintenance risk 

assessment and management in accordance with 10 CFR 50.65(a)(4), employing the 

methods described in NUMARC 93-01, Section 11 or an alternate methodology 

described by the FSAR. For licensees using PRA to perform risk assessment, the 

methodology employed to meet 10 CFR 50.65(a)(4) should cover the initiating events 

and modes of operation of the PRA required under 10 CFR 50.71(h). Additional 

guidance on evaluating the technical adequacy of the licensee’s PRA used to perform 

risk assessments will be issued in a separate inspection procedure after the NRC 

reaches resolution on this issue.
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b. Verify that controls are in place so that the risk from maintenance activities is both 

assessed (i.e., using a risk-informed process to evaluate the overall contribution to risk 

of the planned maintenance activities) and managed (i.e., providing plant personnel with 

proper awareness of the risk, and taking actions as appropriate to control the risk). This 

may include the review of the stations “protective equipment” program (i.e., for example, 

the placement of signage in the area of one train of an operable safety-related pump 

while performing maintenance on the opposite train, safety-related pump). 

c. Confirm that the MR program and procedures reflect, as appropriate, consideration of 

issues associated with grid/offsite power reliability as identified in NRC Generic Letter

2006-02, items 5 and 6 and IP 71111.01.

02.07 Evaluate the Licensee’s MR Training and Qualification Program

a. Independently verify that the MR program is supported by appropriate training and 

qualification for designated personnel. Training should be commensurate with MR 

responsibilities, including MR program administration, the expert panel process, 

operations, engineering, maintenance, licensing, and plant management, as appropriate. 

Note: MR program administration may include on-site staff and off-site staff located at 

corporate offices or corporate headquarters. 

b. Independently verify that MR Program training and qualification materials are based on 

regulatory requirements and guidance, and training records are maintained in 

accordance with plant procedures.

02.08 Evaluate the Licensee’s Program for Incorporating Operating Experience

a. Confirm that the licensee has a program in place to review industry operating experience 

(IOE) for plant-specific applicability and, where appropriate, is applied in various 

elements of the MR program and procedures. This includes:

1. Scoping

2. Performance/condition criteria

3. Monitoring

4. Goal-setting

5. Corrective action

6. Training

7. Program assessment

8. Maintenance & procurement activities

Note: Sources of IOE may include information programs organized by the reactor 

vendor, safety-related equipment suppliers, the NRC, the Institute of Nuclear Power 

Operations (INPO) and the Electric Power Research Institute (EPRI).
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62712-03 RESOURCE ESTIMATE

A maintenance rule inspection team consisting of one team leader and three to four inspectors 

is required to complete the inspection. In addition, one specialist inspector, utilizing PRA 

expertise, determines whether the licensee is adequately using its PRA in the maintenance rule 

program. The time needed to complete the onsite MR inspection is estimated to be between 

one to two weeks. The resource estimate for this inspection procedure is approximately 200 to 

460 hours of direct inspection effort.

62712-04 REFERENCES

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

Power Plants”

IMC 0613, ”Power Reactor Construction Inspection Reports”

Inspection Procedure (IP) 42401, “Part 52, Plant Procedures”

IP 62706, “Maintenance Rule”

IP 62709, “Configuration Risk Assessment and Risk Management Process”

IP 71111.01, “Adverse Weather Protection”

IP 71111.12, “Maintenance Effectiveness”

IP 71111.13, “Maintenance Risk Assessments and Emergent Work Control”

NRC Generic Letter 2006-02, “Grid Reliability and the Impact on Plant Risk and the Operability 

of Offsite Power” 

NRC Generic Letter 2007-01, “Inaccessible or Underground Power Cable Failures the Disable 

Accident Mitigation Systems or Cause Plant Transients”

Regulatory Guide 1.160, Rev. 3, May 2012, “Monitoring the Effectiveness of Maintenance at 

Nuclear Power Plants”

Regulatory Guide 1.206, June 2007, “Combined License Applications for Nuclear Power Plants 

(LWR Edition)”

NEI-07-02A, Revision 0–November 2010, “Generic FSAR Template Guidance for Maintenance 

Rule Program Description for Plants Licensed Under 10 CFR Part 52”

Nuclear Management and Resources Council, Inc., "Industry Guideline for Monitoring the 

Effectiveness of Maintenance at Nuclear Power Plants," NUMARC 93-01, Rev. 4A, April 2011
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62712-05 PROCEDURE COMPLETION

This procedure is complete upon satisfactory inspection results verifying that an MR program 

exists that adequately implements the program required by regulation and described in the 

COL. 

The target of the inspections conducted in Section 02.02 is to verify that at least one entire 

system identified for each category in Section 02.02a is reviewed and that all of the SSCs within 

the scope of the RAP in Section 02.02d are verified to be included within the initial MR scope 

and are scoped in as HSS SSCs. The goal of the inspections conducted in Sections 02.03, 

02.04, 02.05, 02.06, 02.07, and 02.08 is to verify that the specified plans, training and 

qualification programs exist and meet the particular requirements of each section. 

END

Attachment: 

Revision History for IP 62712
Issue Date: 08/13/13 Att1-1 62712

ATTACHMENT 1 

Revision History for IP 62712

Commitment 

Tracking 

Number

Accession Number 

Issue Date

Change Notice

Description of Change Description of 

Training Required 

and Completion Date

Comment and 

Feedback Resolution 

Accession Number

N/A ML13098A126

08/13/13

CN 13-017

Initial issue to support inspections of 

construction programs described in IMC 

2504, Construction Inspection Program: 

Inspection of Construction and 

Operational Programs.

N/A ML13098A127