ML20036A641
| ML20036A641 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee, Yankee Rowe, Maine Yankee |
| Issue date: | 05/05/1993 |
| From: | Denise Edwards YANKEE ATOMIC ELECTRIC CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR15303, FRN-58FR33993, RULE-PR-50 58FR15303-00009, 58FR15303-9, AE55-2-017, AE55-2-17, FYC-93-010, FYC-93-10, SPS-93-040, SPS-93-40, NUDOCS 9305130005 | |
| Download: ML20036A641 (3) | |
Text
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FYC 93-010 SPS93-040 Mr. Samuel J.
Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Docketing and Service Branch
Subject:
Proposed Rule:
" Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (58FR15303) 1
Dear Mr. Chilk:
Yankee Atomic Electric Company (YAEC) appreciates the opportunity to comment on the subject proposed rule.
YAEC is, the owner of the Yankee Nuclear Power Station in Rowe, Massachusetts and provides engineering and licensing services to nuclear power plants in New England.
These comments are filed on behalf of Maine Yankee Atomic Power Company and Vermont Yankee Nuclear _ _ Power Corporation as well.
Northeast Utilities has expressed concurence -
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with the points presented in this letter and will be filing similar comments on behalf of their plants.
- l The proposal in this notice is.to change the required frequency at which nuclear power plant licensees must evaluate _
performance and condition monitoring activities and associated.
?
goals and preventive udintenance from' annually to once per
?
refueling cutage.
We agree with and support this change for the
. i reasons provided in the notice.
Evaluation of data collected over the period of a
refueling cycle
- will, indeed, provide
-a-substantially better assessment of maintenance activities.
The Nuclear Management and Resources Council (NUMARC) has commented to this effect in their filing, and we support their comment.
l There is, however, another aspect of the subject rule which should be addressed at this time which has to do with. the boundaries of the rule's scope.
NUMARC's document No.
93-01
" Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" has been _ adopted by. the NRC as the applicable substantive regulatory guidance for the rule.
As a result' of the recently completed Verification and Validation program conducted to test 93-01, it has been determined that plants i
will identify several systems that are 'neither risk-significant'nor j
able to be monitored for performance using any currently known i'
plant level performance criteria.
In other words, a few systems 1
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9305130005 930505L
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4 Pr. Samuel J.
Chilk 5
May 5, 1993 Page-2 (nominally between 1 and 8 systems, depending entirely on how a' plant defines " systems") identified by the current interpretation of the emergency operating procedure (EOP) criterion (criterion (b) (2) (i) will be screened as in-scope but are:
- 1) not significant in terms of risk, 2) non-safety in terms of classification, and 3) not able to affect plant performance in any way.
The impe.ct of the above is that, under the rule, system-specific performance measures must be devised for each of these systems and performance data must be collected to monitor. the defined measures.
It would seem that systems of no public health or safety significance should be excluded from the scope of a rule intended to " monitor the effectiveness of maintenance activities for safety significant plant equipment..." (Final Rule 56FR31306).
For example, specific, formal performance monitoring of the public address
- system, the auxiliary house
- boiler, or the freeze i
protection system seems unnecessary.
The Federal Register notice which published the maintenance rule noted.that
...given the period allowed for implementation, there can be adjustments made to the rule before it becomes effective...".
Since one of the clear lessons learned from the recently completed V & V program is that the major expense of the rule's implementation will be the detailed documentation (for NRC-
-)
audit purposes) of performance monitorina as well as failure cause i
determinations and corrective actions, modification of this aspect of the rule appears to be one of these necessary " adjustments".
)
Given the current impetus toward cost-effective regulation by the i
NRC Regulatory-Review Group (58FR13808), this would seem to be the appropriate time for such an adjustment.
Such a change could be made by a minor addition to the current sub paragraph (b) (2) (i) of 10 CFR 50.65 as follows*
(i)
That are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures (EOPs) and are deemed to be either risk sianificant or monitored by plant level nerformance criteria; or The underlined language could elimine i the few systems discussed above from the regulatory data collection imposed by_ the maintenance rule.
Their deletion from scope would in no way alter the maintenance practices which apply to them already.
These practices were included in the programs which the NRC Maintenance Team Inspections had found entirely acceptable in -their comprehensive reviews (5BFR31312).
l
i Mr. Samuel J.
Chilk May 5, 1993 Page 3 s
.i The added advantage of this simple delineation is the' introduction of the word " risk" in the rule language.
Thus, one of the fundamental features of the implementation document, NUMARC 93-'
01, would have an anchor in the language of the rule itself.
i Further, the compatibility in scope between the Maintenance Rule and the License Renewal Rule would be enhanced.
The major i
difference in their respective scope definition has been identified (see SECY 93-049) as the EOP criteria.
i i
The Maintenance Rule offers a real opportunity to move towards j
a performance-based regulatory system which will place emphasis, correctly, on the most safety significant equipment.
Both the change proposed in the subject notice and the one suggested in this letter will help shape the rule to a more cost effective and i
optimally focused requirement.
Sincerely yours,
(
D. W.
Edwards Director, Industry Affairs 1
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