Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure.| ML17311A246 |
| Person / Time |
|---|
| Site: |
Palo Verde  |
|---|
| Issue date: |
08/25/1994 |
|---|
| From: |
Krainik A
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
|---|
| To: |
NRC |
|---|
| References |
|---|
| FRN-59FR33026, RTR-REGGD-01.160, RTR-REGGD-1.160 59FR33026-00006, 59FR33026-6, NUDOCS 9409120067 |
| Download: ML17311A246 (8) |
|
|
|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217E1551999-09-28028 September 1999
Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code
ML17313B0651999-07-30030 July 1999
Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps.
ML17313B0161999-07-0101 July 1999
Comment on Draft Rg DG-1074, SG Tube Integrity.
ML20196K5631999-06-29029 June 1999
Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program
ML20207D1591999-05-20020 May 1999
Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors
ML17313A9791999-05-20020 May 1999
Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel
ML20205A4271999-03-18018 March 1999
Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation
ML17313A8521999-03-0505 March 1999
Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided
ML17313A8191999-02-24024 February 1999
Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process
ML20198J4031998-12-11011 December 1998
Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs
ML20217B9761998-04-0909 April 1998
Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys
ML20216A9091998-04-0303 April 1998
Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds
ML17313A3361998-03-27027 March 1998
Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors
ML20217E8781998-03-27027 March 1998
Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal
ML17313A2511998-03-0303 March 1998
Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps.
ML20203L5521998-02-25025 February 1998
Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events
ML20202E4251998-01-30030 January 1998
Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652
ML20199E0871998-01-17017 January 1998
Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public
ML20202G4461997-12-0101 December 1997
Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule
ML20212D1391997-10-17017 October 1997
Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors
ML17312B4241997-04-23023 April 1997
Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps)
ML20134J9671997-02-0606 February 1997
Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry
ML20134N2521996-11-14014 November 1996
Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp
ML20117E3871996-08-0707 August 1996
Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements
ML20113C6981996-06-24024 June 1996
Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning
ML20117P1261996-06-24024 June 1996
Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution
ML20095A8461995-11-28028 November 1995
Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI
ML17311B2931995-11-27027 November 1995
Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters.
ML17311B1601995-08-31031 August 1995
Comment Opposing Review of Revised NRC SALP
ML20087H7241995-08-16016 August 1995
Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy
ML20087H7501995-08-0404 August 1995
Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design
ML20087H7331995-08-0404 August 1995
Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations
ML17311B0071995-06-27027 June 1995
Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number
ML20083N5031995-05-0505 May 1995
Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation
ML20082P7461995-04-19019 April 1995
Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr
ML20082H0971995-04-10010 April 1995
Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation
ML20081B5721995-03-0808 March 1995
Motion of Plains Electric Generation & Transmission Cooperative,Inc to Withdraw,W/Prejudice,Petition for Leave to Intervene,Request for Finding of Significant Change & for Antitrust Hearing & Comments.* W/Certificate of Svc
ML17311A6691995-02-0202 February 1995
Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure)
ML20078H0671995-01-20020 January 1995
Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures
ML20077M5471995-01-0404 January 1995
Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule
ML17311A2461994-08-25025 August 1994
Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure.
ML17310B1911994-04-12012 April 1994
Petition to Intervene of Public Utility Commission of Texas. W/Certificate of Svc
ML17310B2041994-04-12012 April 1994
Petition to Intervene of Public Utility Commission of Tx
ML20062M4141993-12-27027 December 1993
Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items
ML20056G3351993-08-27027 August 1993
Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process
ML17306B2461993-01-15015 January 1993
Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps.
ML17306A9571992-09-0808 September 1992
Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev
ML20099E0621992-07-29029 July 1992
Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power
ML20090F9661992-03-0909 March 1992
Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel
ML17306A4501992-02-0404 February 1992
Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data
1999-09-28
[Table view]
Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20217E1551999-09-28028 September 1999
Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code
ML17313B0651999-07-30030 July 1999
Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps.
ML17313B0161999-07-0101 July 1999
Comment on Draft Rg DG-1074, SG Tube Integrity.
ML20196K5631999-06-29029 June 1999
Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program
ML17313A9791999-05-20020 May 1999
Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel
ML20207D1591999-05-20020 May 1999
Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors
ML20205A4271999-03-18018 March 1999
Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation
ML17313A8521999-03-0505 March 1999
Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided
ML17313A8191999-02-24024 February 1999
Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process
ML20198J4031998-12-11011 December 1998
Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs
ML20217B9761998-04-0909 April 1998
Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys
ML20216A9091998-04-0303 April 1998
Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds
ML20217E8781998-03-27027 March 1998
Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal
ML17313A3361998-03-27027 March 1998
Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors
ML17313A2511998-03-0303 March 1998
Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps.
ML20203L5521998-02-25025 February 1998
Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events
ML20202E4251998-01-30030 January 1998
Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652
ML20199E0871998-01-17017 January 1998
Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public
ML20202G4461997-12-0101 December 1997
Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule
ML20212D1391997-10-17017 October 1997
Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors
ML17312B4241997-04-23023 April 1997
Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps)
ML20134J9671997-02-0606 February 1997
Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry
ML20134N2521996-11-14014 November 1996
Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp
ML20117E3871996-08-0707 August 1996
Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements
ML20113C6981996-06-24024 June 1996
Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning
ML20117P1261996-06-24024 June 1996
Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution
ML20095A8461995-11-28028 November 1995
Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI
ML17311B2931995-11-27027 November 1995
Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters.
ML17311B1601995-08-31031 August 1995
Comment Opposing Review of Revised NRC SALP
ML20087H7241995-08-16016 August 1995
Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy
ML20087H7331995-08-0404 August 1995
Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations
ML20087H7501995-08-0404 August 1995
Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design
ML17311B0071995-06-27027 June 1995
Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number
ML20083N5031995-05-0505 May 1995
Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation
ML20082P7461995-04-19019 April 1995
Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr
ML20082H0971995-04-10010 April 1995
Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation
ML17311A6691995-02-0202 February 1995
Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure)
ML20078H0671995-01-20020 January 1995
Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures
ML20077M5471995-01-0404 January 1995
Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule
ML17311A2461994-08-25025 August 1994
Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure.
ML20062M4141993-12-27027 December 1993
Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items
ML20056G3351993-08-27027 August 1993
Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process
ML17306B2461993-01-15015 January 1993
Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps.
ML17306A9571992-09-0808 September 1992
Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev
ML20099E0621992-07-29029 July 1992
Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power
ML20090F9661992-03-0909 March 1992
Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel
ML17306A4501992-02-0404 February 1992
Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data
ML20055F4531990-06-29029 June 1990
Comment on Proposed Rule 10CFR55 Re Operators Licenses Modified for fitness-for-duty.Rule Unnecessary & May Adversely Affect Morale of Licensed Operators
ML19327B1631989-09-0707 September 1989
Comment on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. Recommends That NRC Should Not Attempt to Dictate Standardized Form of Decommissioning Trust Agreement
ML20235V7101989-02-27027 February 1989
Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Rule Will Not Improve Maint,Reliability or Safety of Arizona Nuclear Power Project Plants
1999-09-28
[Table view] |
Text
PRIDRIT'Y (NUDOCS OFFSITE FACILITY)
Z REGULA Y INFORMATION DISTRIBUTIO YSTEM (RIDS)
ACCESSION NBR:9409120067 DOC.DATE: 94/08/25 NOTARIZED: NO DOCKET N FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 050'00528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION KRAINIK,A.K. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION P NRC No Detailed Affiliation Given
SUBJECT:
Comment on draft reg guide (DG-1031), "Monitoring Effectiveness of Maint at NPPs." Term "maint preventable failure" needs to be defined a compared to term "maint I preventable functional failure."
SIZE:
0 DISTRIBUTION CODE: DS09D COPIES RECEIVED:LTR ENCL TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G R
NOTES:STANDARDIZED PLANT 05000528 Standardized plant. 05000529 I Standardized plant. 05000530 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL Y INTERNAL: OGC/DR 15-B-18 1 1 REG FILE 01 1 1 RES DIR 1 1 RES/DER 1 1 RES/PMPDAS 1 1 EXTERNAL: NRC PDR 02 1 1 C
U NOTE TO ALL'Rl DS" RECIPIENTS:
PLEASE HELP US TO REDUCE O'ASTE! CONTACTTHE DOCUMENTCONTROL DESK, ROOM P!-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 6 ENCL 6
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'Ke Ar1zona Public Se~ice Comp PALQ YERDE NUCLEAR GENERATINQQT+IoPI r.
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102-03096"-AK@AP7PRL nvVI Z ON-~
August 25, 1994
'I Rules Review and Directive Branch Sge<iz.
Division of Freedom of Information and Publication Services Office of Administration zW P<9MEQ U.S. Nuclear Regulatory Commission 4/av(qy Washington, D.C. 20555 I ~
CA
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Ch Docket Nos. 50-528/529/530 Comments on NRC Draft Regulatory'Guide DG-1031, "Monitoring~<
the Effectiveness of Maintenance at Nuclear Power Plants.""
File: 94-010-026 o Arizona Public Service Company (APS) is responding to the Federal Register Notice, Vol. 59, No. 122, Monday, June 27, 1994, page 33206, soliciting comments on NRC's Draft Regulatory Guide DG-1031 (proposed Revision 1 to Regulatory Guide 1.16 ),
"Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
are provided in the enclosure to this letter.
APS'omments Should you have any questions, please contact me at (602) 393-5421.
Sincerely, 9409120067 940825 PDR 0l. f60 REQQD A.. Krainik, Department Leader C,. PDR Nuclear Regulatory Affairs AKK/SAB/DRL/rv Enclosure cc: L. J. Callan K. E. Perkins K. E. Johnston B. E. Holian
- I ENCLOSURE
'COMMENTS ON DRAFT REGULATORY GUIDE DG-1031
~ ~
I
Page 2, lines 2 & 26 and Page 4, line 31 Page 2, line 2 and Page 4, line 31 appear to endorse a concept of minimizing failures, which is contrary to the objective of balancing reliability and availability. Page 2, line 26 does embrace the concept of balancing reliability and availability. Page 2, line 2 and Page 4, line 31 need to incorporate similar wording.
Page 6, lines 3 through 13 This paragraph is unclear. The term "maintenance preventable failure" needs to be defined and compared to the term "maintenance preventable functional failure," which is defined in NUMARC 93-01. Additionally, this paragraph implies that any second failure (regardless of time interval between failures, cause of the failure, or the impact of the failure) is an indicator of poor performance. This would require utilities to strive for perfect reliability of all EDG components (including components that do not affect the function of the EDG) without regard to the unavailability required to meet this performance. This level of attention is no longer required for the EDGs in light of the improvement in EDG reliability and additional actions that have been taken to comply with 10CFR50.63, "Loss of All Alternating Current Power."
4 0 'C a j f