ML19353B201

Comment on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Fundamental Tenant of Maint,Ensuring Programmatic Review of Balance Between Corrective,Preventive & Predictive Maint Disregarded

ML19353B201
Person / Time
Site:	Calvert Cliffs
Issue date:	12/01/1989
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-54FR33983, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-DG1001, TASK-RE 54FR33983-00025, 54FR33983-25, NUDOCS 8912130201
Download: ML19353B201 (2)

Text

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BALTIM O RE J GAS AND ELECTRIC A w .i CH ARLES CENTER

• P. O. BOX 1475. BALTIMORE, MARYLAND 21203 GEORGE C. CREEL vics ParslOENT NucLeam ENCROY (300 260-4456 December 1,1989 -

Division of Freedom of Information and Publications Services Office of Administration

$b Q'jif3 U. S. Nuclear Regulatory Commission Washington, DC 20555 g ATTENTION: Regulatory Publications Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos,1 & 2; Docket Nos. 50-317 & 50-318 )

Comments on the Draft Regulatory Guide DG-1001, " Maintenance Programs j for Nuclear Power Plants" {

Gentlemen:

The following comments are submitted by the Baltimore Gas and Electric Company in response to the Federal Register Notice of August 17, 1989, concerning the draft guide DG- 1001.

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We agree that establishing a regulatory standard for a maintenance program will provide stability to the regulatory process and better ensure that nuclear power plant structures, systems, and components are maintained at a level commensurate with their safety significance. We also ngree the key to providing regulatory stability is to allow considerable flexibility for each licensed plant to develop a maintenance program consistent with the plant's design and the licensee's organizational structure. In Section B, the draft guide sti.tes that considerable flexibility will be allowed; however, in its effort to maintain flexibility, the draft guide too often uses ambiguous terms. Unless a. definition section for at least the following words and phrases is included, we anticipate regulatory stability in the maintenance arena will not be achieved:

Rework Management Oversight Corrective Maintenance Preventive Maintenance Predictive Maintenance Promptly Restore Timely Manner 8912130201 891201 PDR REGQD 01.XXX C PDR

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Regulatory Publications Branch j t- December 1,1989

~Page 2 We- are particularly ' concerned that the draft regulatory guide states that

" Fundamentally, the maintenance program should minimize corrective maintenance to the extent practical, and it should rely on sound preventive - and predictive maintenance "

We agree this . is a laudable goal, llowever, we feel it disregards a fundamental tenant of maintenance, which is, a good maintenance program ensures programmatic review of the balance between corrective, preventive and predictive maintenance. The balance should be adjusted as determined by utility management assessment.

In addition to the above comments, we fully endorse those comments submitted by NUMARC in their letter dated December I, 1989.

Should you have any further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, j

GCC/JMO/dtm cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC J. E. Beall, NRC T. Magette, DNR W. Smith, NUM ARC

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