ML20005F652

Comment on Proposed Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Concurs w/industry-wide Position Presented by NUMARC & Offers Addl Comments

ML20005F652
Person / Time
Site:	Indian Point
Issue date:	12/13/1989
From:	Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-54FR33988, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-DG1001, TASK-RE 54FR33988-00036, 54FR33988-36, NUDOCS 9001170101
Download: ML20005F652 (2)

Text

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96ephen B. Brom ,

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$ (n 009 - t I Consohdated Edison Company of New York, Inc.

Indian Point Station Broadway & B6eakley Avenue Buchanan, NY 10511 Telephone (914) 737 8116 g'

Ret Indian Point Unit No. 2 2 Docket No. 50-247 -

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SUBJECT:

Draft Regulatory Guide DG-1001, ' Maintenance Programs for Nuclear l Power Plants' Consolidated Ediron Company of New York, Inc., (" Con Edison") velcomes the opportunity to' ei. press its views to the Commission on the subject draf t Regulatory Guide pertaining to nuclear power plant maintenance programs.

'As a member of the Nuclear Management and Resources C oune.il, .T.n c .

("NUMARC"),- we have participated in that organization's efforts in commenting on this draft Regulatory- Guide. We have reviewed and accepted the industry-wide position presented by NUMARC. The detailed comments on the draft Regulatory Guide contained in the NUMARC submittal are fully i endorsed by Con Edison and should be considered as an adjunct to this '

letter. Additionally,'ve offer the following comments.

In discussing the application of a maintenance program, the regulatory guide makes numerous references to plant security in conjunction with plant L safety. The first-paragraph of the " Introduction" refers to B0P equipment whose. failure vould "significantly impact.... security." In the second-paragraph of the " Discussion," maintenance applies to "all parts....that could significantly impact safe operation and security, including the BOP."

l AltM uch the context of these uses of " security" is slightly different, we l- are unaccustomed to seeing it defined in this manner. We do not understand l

what is meant by singling out security (over, for example, reactor protection, feedvater, etc.) and we question whether there is an intent to change the significance of security maintenance. Does the use of " security" throughout the regulatory guide lead to an implied, special significance

'related to security maintenance that heretofore hasn't existed?

. In the first paragraph of S(etion C.2, "Overall Maintenance Policy", the use l:

i-of the term " conduct of maintenance" in two separate ine,tances seems to be different. In either case, the context is unclear.

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a The " work control process" as described in Section C.4.7 is essentially ,

7 " planning and scheduling"_as described in Section C.4.5. However, these are two different but related elements in the conduct of maintenanc. We suggest- that section C.4.7 be rewritten to define that distinction.- Vork '

controls are used to nsure compliance with plans and schedules, to control changes to plans, t .1 assure protection of the r.djacent equipment and to

provide for safe return to service.

At Indian Point Unit No. 2, past efforts to. improve maintenance have cortributed .to significant improvements in availability and capacity factor

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and_ fewer trips and safety systems actuations. Through our ongoing efforts we expect to' continue these trends, and we continue to strive for excellence in these areas.

Should you or your staff have any questions regarding this matter, please contact Mr. Charles W. Jackson, Manager, Nuclear Safety and Licensing.

Very truly yours, P-L

• cc: Documint Control Desk US Nuclear Regulatory Commission Mail Station'P1-137-Washington, DC 20555 Mr.-William Russell-

~ Regional Administrator - Region I US Nuclear Regulatory Commission-475 Allendale Road

-King-of Prussia, PA 19406 Mr. Donald'S. Brinkman, Senior Project Manager Project Directorate I-1 Division of Reactor Projects I/II US Nuclear Regulatory Commission Mail'Stop 14B-2

. Washington, DC 20555 Senior Resident Inspector l' US Nuclear Regulatory Commission PO Box 38 Buchanan, NY - 10511 ll l

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