ML19318G580
| ML19318G580 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1988 |
| From: | Kerr W Advisory Committee on Reactor Safeguards |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| FRN-53FR25169, FRN-53FR47822, FRN-53FR9430 ACRS-R-1319, AD-1-14, AD00-1-14, NUDOCS 8809220142 | |
| Download: ML19318G580 (2) | |
Text
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UNITED sTATES Cys: Stello o
y NUCLEAR REGULATORY COMMISSION Taylor n
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Thompson, NMSS Jordan, AE0D September 13, 1988 Murray, OGC
@s-The Honorable Lando W. Zech, Jr.
Chairman U.S. Nuclear Regulatory Comission Washington, D.C. 20555
Dear Chairman Zech:
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SUBJECT:
PROPOSED RULEMAKING RELATED TO MAINTENANCE OF NUCLEAR POWER PLAWTS I
During the 341st meeting of the Advisory Comittee on Reactor Safe-guards, September 8-10, 1988, we discussed the proposed amendment to 10 CFR Part 50 related to maintenance of nuclear power plants. We had previcusly discussed this topic with the NRC staff during our 340th meeting, August 11-13, 1988, and during meetings of our Maintenance Practices and Procedures Subcomittee on June 15 and September 7, j
1988.
During these meetings, we had the benefit of coments by a representative of the Nuclear Management and Resources Council (NUMARC). We also had the benefit of the document referenced.
We cannot endorse the proposal to establish a maintenance rule.
The propcsal appears to be based upon the following hypotheses:
1.
Maintenance of nuclear power plants, as now performed, poses a significant risk to public health and safety.
2.
The existence of a maintenance rule would reduce this risk.
There is some evidence to support the first of these hypotheses, although there is no direct ciuantitative indicator.
There is anec-dotal evidence that poor maintenance has contributed to plant un-availability and has even led to the existence of plant states that are interpreted es accident precursors.
Comon sense suggests that a well-maintair.ed plant poses less risk than one poorly maintained.
Some operating plants have better maintenance programs than others, and some have programs that should be improved.
We have seen no evidence to support the second hypothesis.
The regulatory analysis provided by the staff makes the arbitrary assump-tion that a reduction in risk will occur as a result of the rule, and bases its cost-benefit conclusions on a guess about the amount of risk reduction expected. Nor have we seen evidence that the existence of a rule would not make things worse.
Indeed there are characteristics of Q
regulations, and especially the way in which they.are typically enforced, that lead us to believe that, under a rule, a move toward
\\/)l uniformity would occur, and this is likely to decrease the effective-ness of some of the better existing programs.
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The Honorable Lando W. Zech, Jr. September 13, 1988 l
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Finally, it appears to us that maintenance practices in the industry j
are improving and that a rule may be disruptive to the substantial 4
industry initiatives that have been 'developed to accomplish this improvement, i
Ad;itional comments by. ACRS member Harold W.
Lewis are presented
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below.
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Sincerely,
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W. Kerr i
Chairman l
Additional comments by ACRS mecber Harold W. Lewis i
I want to take thu opportunity to observe that it is not necessarily true that trcre maintenance is better maintenance -- a substantial i
number of events are initiated by testing and maintenance operations.
There exists a well-developed theory of.reliability which deals with such matters as the optimum level of maintenance -- there are books on j
the subject -- and it would be useful to bring some expertise into the l
analysis of this question.
Reference:
Letter cated August 29, 1988 from Bill M. Morris, Director, Division j
of Pegulatory Applications Office of Nuclear Regulatory Research, to j
Raymond F. Fraley, Executive Director, Advisory Committee on Reactor Safeguards, enclosing Draft Commission Paper for Notice of Proposed i
Rulemaking for Maintenance of Nuclear Power Plants l
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