Lessons Learned from Early Implementation of the Maintenance Rule at Nine Nuclear Power Plants

This report summarizes the lessons learned from the nine pilot site visits that were performed to review early implementation of the maintenance rule using the draft NRC Maintenance Inspection Procedure. Licensees followed NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." In general, the licensees were thorough in determining which structures, systems, and components (SSCs) were within the scope of the maintenance rule at each site. The use of an expert panel was an appropriate and practical method of determining which SSCs are risk significant. When setting goals, all licensees considered safety but many licensees did not consider operating experience throughout the industry. Although required to do so, licensees were not monitoring at the system or train level the performance or condition for some systems used in standby service but not significant to risk. Most licensees had not established adequate monitoring of structures under the rule. Licensees established reasonable plans for doing periodic evaluations, balancing unavailability and reliability, and assessing the effect of taking equipment out of service for maintenance. However, these plans were not evaluated because they had not been fully implemented at the time of the site visits.