ML19332F202

Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. More Flexibility Should Be Provided in Guidelines for Organizations

ML19332F202
Person / Time
Site:	Cook
Issue date:	12/01/1989
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-54FR33983, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-DG1001, TASK-RE 54FR33983-00020, 54FR33983-20, AEP:NRC:0508I, AEP:NRC:508I, NUDOCS 8912140031
Download: ML19332F202 (2)

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AEP:NRC:0508I Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 I License Nos. DPR-58 and DPR-74 ,

COMMENTS ON DRAFT REGULATORY GUIDE " MAINTENANCE PROGRAMS ..

I FOR NUCLEAR POWER PLANTS" Regulatory Publications Branch e of Administration M I U.S. Nuclear Regulatory Commission Washington, D.C.'20555 Oh 1

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December 1,~1989 l

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Dear Sir or Madam:

The NRG issued draft Regulatory Guide DG-1001, " Maintenance Programs '

for Nuclear Power Plants," for comment via a letter dated August 1, 1989. We are pleased to provide comments on the draft Regulatory Guide as follows:

l l: o More flexibility should be provided in guidelines for organizations, aside from plant-site organizations, to control and oversee the various aspects of a maintenance program, ranging from communications to control of vendors.

Present wording of the Regulatory Guide would only permit plant staff to serve the controlling function.

o It is not clear what role Individual Plant Examination (IPE), required under Generic Letter 88-20, will have in defining the scope or performance objectives of maintenance programs under the guidance provided in this Regulatory Guide. If the NRC desires a workable interface between these programs, pertinent guidance should be provided within this Regulatory Guide, o It is recommended that the Institute of Nuclear Power Operations (INPO) Guideline 85-038, " Guidelines for the Conduct of Maintenance at Nuclear Power Stations,"

definitions for types of maintenance be used in the Regulatory Guide section on " Types of Maintenance" (Section 4.6). All nuclear plants in the United States were required to complete a maintenance self-assessment based on this guideline. Using INPO definitions would provide consistency in this area.

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AEP:NRC:0508I Page 2-It-should be noted that, in addition to our own comments shown above, we adopt and support' comments provided to the NRC by the Nuclear

. Management and Resources Council (NUMARC). However, we would like to proceed one step further and indicate those NUMARC comments of particular importance to us as follows:

o Training and personnel-qualification guidelines should not be applied unilaterally to contractor personnel. Their training and qualification criteria should instead be based on the work they are to perform, and not necessarily meet all the criteria for unsupervised station personnel, o Something less subjective than the " level of performance consistent with that achieved by the top-performing U.S.

plants of similar design" should be used as a performance goal for the maintenance program. Instead, goals should be

-established based on excellence in achieving safe and reliable plant operations rather than on another plant's performance, o Throughout the Regulatory Guide subjective words and terms l are used that are open to varying interpretations. For l example, " Proper control of tools...," "... sound human l factors principles," and "... effective planning...." We recommend these words be omitted or clarified to avoid problems of interpretation, o Radiological exposure control and practices followed during l maintenance and other activities.are defined in the appropriate plant ALARA program. There is no need to define specific radiological controls in a maintenance Regulatory Guide.

Sincerely, ,

t M. . Alexidh Vice President idp

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