ML20006D382

Comment on Proposed Rule 10CFR2 Re Policy & Procedures for Enforcement Actions;Policy Statement.Util Uncertain as to Whether Changes Necessary

ML20006D382
Person / Time
Site:	05000000, Peach Bottom, Limerick
Issue date:	02/06/1990
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-54FR50610, RULE-PR-2 54FR50610-00011, 54FR50610-11, NUDOCS 9002130133
Download: ML20006D382 (2)

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February 6, 1990

j Mr. Samual J.-Chilk c

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Secretary of the Commission U.S. Nuclear Regulatory Commission LAttn:L Docketing and Service 8 ranch Washington DC 20555 SU8 JECT:

Comments Concerning the Nuclear. Regulatory Commission's Policy' Statement Modification to 10 CFR 2. " Policy and Procedures for Enforcement Actioas; Policy Statement" (54FR50610) i

Dear Mr. Chilk,

This letter is being submitted in response.to the Nuclear Regulatory Commission's (NRC's) request for comments.regarding the Policy Statement Modification 10 CFR 2, " Policy and Procedures for Enforcement. Actions;-Policy Statement," published in the Federal Register (54 FR 50610, dated December 8,

.1989).

.The Philadalphia Electric Company (PECo appreciates the opportunity s

'to comment on this policy statement modification. )The modification to the NRC's Enforcement Policy described in 54 FR 50610 is to add 'an additional civil penalty adjustment factor for violations involving maintenance deficiencies.

We

.are uncertain as to whether'these changes to 10 CFR 2, Appendix C, " General Statement of Policy and Procedure for NRC Enforcement Actions," are necessary.

We consider._the existing Enforcement Policy an effective deterrent to. continued poor performance:in operations, including maintenance.

In addition, we support the Nuclear'and Management Resources Council's (NUMARC's) position and comments regarding this policy statement moutfication.

PECo is currently developing a Nuclear Maintenance Program Manual which is consistent with the scope and activities defined in the NRC Revised Policy Statement 10 CFR 50, " Maintenance of Nuclear Power Plants, Revised Policy Statement " published in the Federal Register (54 FR150611, dated December 8

'.1989). Our Maintenance Program Manual-incorporates guidance published in the Institute of Nuclear' Power Operations' (INP0's) document No.85-038, Guidelines for--the Conduct of Maintenance at Nuclear Power Stations," Revision 1.

In

addition, our Program will be patterned after.similar maintenance programs developed by other nuclear utilities which are already in place. One of these programs'has been viewed by the NRC as an effective maintenance program that 9002130133 900206

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meets the intent of the 10 CFR 50 Proposed Rule, " Ensuring the Effectiveness of 1

. Maintenance Programs for Nuclear Power Plants " published in-the Federal Register.(53FR-47822,datedNovember28,1988).

'If you have any questions, please do not hesitate to contact us.

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7erytrulyyours, j

444 G. A. Hunger, Jr.

Director t

Licensing.Section Nuclear Services Department

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