ML20235N728

Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Util Shares Commissioner Robert Concerns on Existence of Rule

ML20235N728
Person / Time
Site:	Cook
Issue date:	02/17/1989
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00013, 53FR47822-13, AEP:NRC:0508F, AEP:NRC:508F, NUDOCS 8903010375
Download: ML20235N728 (3)

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                                                             -Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 Comments on Proposed Rule 10 CFR 50.65
                                                               " Ensuring the Effectiveness of Maintenance Programs For Nuclear Power Plants" U.S. Nuclear Regulatory Comm'.ssion                                             

Secretary of the Commission I ATTN: Docketing and Service Branch Washington, D.C. 20555 Attn: Samuel J. Chilk i February 17, 1989 i

Dear Mr. Chilk:

The NRC published its proposed maintenance rule 10 CFR 50.65 in the Federal Register Monday, November 28, 1988, page 47822. We are pleased to provide the following comments on the proposed rule. Indiana Michigan Power Company, the owner and operator of the Cook Nuclear Plant, recognizes that maintenance has a primary role in ensuring the safe, reliable, and economic operation of its nuclear plant. As such, we are committed to an aggressive maintenance program that maintains the plant in a safe and reliable condition. In addition, recent industry initiatives as well as economic considerations have combined to prompt us and other citilities to direct our efforts to improve our maintenance practices. For example, our Senior Executive Vice President Engineering and Construction has issued a Maintenance Policy statement which reaffirms our commitment to a strong and proactive maintenance program. We have also conducted a maintenance self assessment at the Cook Nuclear Plant per DIPO 85-038. "Cuidelines for the Cenduct of Maintenance at Nuclear Power Stations." This erd etter initiatives will identify further enhancements to our maintenance program. We are committed to refine our existing maintenance program which we believe will set a new standard of excellence for the l 8903010375 890217 PDR PR [-{/p v 50 53FR47822 PDR

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( Nr. S. J. Chilk AEP:NRC:0508F~ industry in the area of nuclear plant maintenance. It would be difficult and possibly counter productive to p;oceed on this course and then have to change to meet unknown maintenance standards that the NRC could incorporate in a final rule. We believe that the NRC already has the' authority to implement all the criteria of the proposed rule relative to safety related equipment. In general, we share Commissioner Robert's concera "... that the existence of this rule could make things worse and diminish rather than enhance the protection of the public." We cannot support the NRC's proposed rule on maintenance. i In the event the decision is made to proceed with the proposed rule, we offer the folicwing commenta. o It is nut clear that a maintenance standard in required at all. If it is derarmined that a maintenance standard is necessary, we would prefer to have a standard develop:ed by the industry rather than a standard set forth by the NRC. However, due to the very diverse nature of maintenance in i general, we do not believe it possible to develop a ' maintenance standard and establish and implement an effective and documented program based on this reandard wichin two years. The time frame for compliance cannot be determined without knowing the content of any specifte standard. However, based on past experience with implementation and compliance with standards, a minknum of i five years is not unreasonable, o The proposed rule should not be extended to all systoms, including balanc( of plant (BOP) systems. Although BOP is and will always be part of our maintenance program, we do not believe the KRC's authority should be broadened in this proposed rule to include BOP. The rule is written such that it could be interpreted that all plant equipment i should be treated equally as to its importance. Apply ing j all of the requirements of the rule to all systems and  ! components is noe practical and may draw off resources i that could be better used on equipment more important to the safe operation of the plant. The rula should be limited to those systems that are clearly safety related or important to safety, o Third party certification of the maintenance program should not be required. The level of protection of the , l public health and safety already provided by the operating license including technical specifications and enforcement 1 L--.____-_ . _ _ _

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fi: ; 4 i actions'resulting from NRC inspecti.ons should be adequate ,O"' .to insure ccmpliance, a l ., ' o Staffing, shift' coverage, training, and resource h)b)[J'! allocation, among other' items, are proposed elements of j We believe these-functions'are management-the rule

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o We believe a backfit analysic for this rule is necessary because the NRU has not shown that. the present maintenance i (

                                          . programs at' nuclear utilitics'are_ inadequate to protect                               , .- l
               ,'                            the public' health and safety. . In addition, we do not                              1
                                          .believe the backfit' analysis'shown isJadequate. The NRC 0
            ,.                               assumes the backfit analysis benefits the entire nuclear.                           - !'         i industry when in fact, the. rule will only benefit some; plants that the NRC has indicated have poor maint.enance programs., To be adequate, the backfit analycis must                             i identify the. benefit to the entire industry i.

4, In addition to. our own comments, we adopt and support comments provided.to the NRC by the Nuclear. Management and Resources Council'(NUMARC).

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Sincerbly, e M. P. Alexich Vice President MPt/MWE/mac . cc: D. H. Williams , Jr. W. G. Smith, Jr. - Bridgnan A. B. Davis - Region IIi NRC Resident Inspection - Bridgman i}}