ML20235N834

Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants

ML20235N834
Person / Time
Site:	Point Beach
Issue date:	02/17/1989
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-89-019, CON-NRC-89-19, FRN-53FR47822, RULE-PR-50 53FR47822-00014, 53FR47822-14, VPNPD-89-086, VPNPD-89-86, NUDOCS 8903010429
Download: ML20235N834 (3)

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3 February 17, 1989 l

Secretary U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555 Attention: Docketing and Service Branch Gentlemen:

P_ROPOSED RULE: ENSURING THE EFFECTIVENESS OF MAINTENANCE PROGRAMS FOR NUCLEAR POWER PLANTS This letter is in response to the November 28, 1988 Federal Register Notice at 53FR47822 requesting comments.on the above subject. We have reviewed a draft of the NUMARC comments and wish to endorse them; we also desire to provide a further response specific to our situation and the effect the proposed rule would have on the operation of Point Beach Nuclear Plant.

Wisconsin Electric Power Company has operated the two-unit Point Beach Nuclear Plant since 1970. During the nineteen years of operation, Point Beach has supplied over 113 million megawatt-hours of reliable, low-cost energy to our customers.

Many routine, and some not so routine, items of power plant maintenance were performed during the period. The latter included replacement of Unit 1 steam generators, added spent fuel storage capacity, sleeving of steam generators, several modifications to reactor core internals, and replacement or ,

retubing of essentially all heat exchangers in the feedwater circuit, including retubing of main condensers. Modifications were carried out to respond to TMI backfit, Appendix R requirements, and other regulations.

In spite of all this activity and twenty-eight refueling outages, the plant reliability has been high as indicated by cumulative annual availab.ility statistics of 80.9% and 86.4%,

with forced outage rates of 1.9% and 1.25% for Units 1 and 2 respectively. The plant performance continues to be impressive 1

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f Secretary - NRC February 17, 1989 Page 2 with the 1988 statistics being significantly better than the f cumulative numbers cited. NRC Chairman Lando Zech emphasized I last November, in his presentation to the INPO 1988 CEO )

Conference, that a plant that is safe and well maintained will experience fewer scrams and, in the long run, prove to be more economical. Wisconsin Electric agrees and also believes that the converse is true; a reliable plant is a safe plant.

It is with this background that Wisconsin Electric wishes to suggest that the proposed maintenance rule is likely to be counterproductive. The thrust of the proposed rule is that each licensee have a " documented and effective maintenance program", which would include seventeen activities. This type of requirement, whether as an NRC rule or an industry commitment, is likely to impose a new administrative burden on the very craftsmen and their supervisors who are relied upon to "do the job right the first time", especially when the adequacy of each licensee's response may be subject to a wide variation of interpretation by a variety of NRC or industry auditors.

This is not to argue whether or not the seventeen activities are appropriate but, rather, to point out that the effort to meet ill-defined, unknown criteria will distract from the very area where improvement is sought.

It also needs to be pointed out that effcetive maintenance is very much in each utility's best interest. With the very large investment in most nuclear plants, low availability and high forced outage rates already impose a significant financial penalty on the owner (s). While the "backfit analysis" presumes over-all cost savings to the industry, even if such were the case, these savings would not accrue to the plants presently operating at a high level of reliability. For at least some U. S. plants, the cost-benefit analysis does not justify the proposed action.

Our own successful record.makes us extremely cautious whenever internal changes to procedures or organizations are considered, lest we adversely impact some aspect of our business that has contributed to our success. While the rather wide range of nuclear plant performance is recognized in the associated documentation, we are surprised that no provisions exist in the proposed rule that would relate in any way to performance. To impose sweeping revisions on all licensees in the absence of specific performance goals may result in some improvements for the poorer performers, but will also risk a decrease for the best performers. j i

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Secretary - NRC' February 17, 1989 Page-3 In summary, Wisconsin Electric recommends against the adoption of a new maintenance rule at this time for the above reasons, as well as those already expressed to the NRC by the nuclear industry, the ACRS, and Commissioner-Roberts. If, notwithstanding the extensive negative reactions, NRC determines to proceed with a new maintenance rule, the rule should include performance goals, with structured requirements tailored to the level of historical performance.

Very truly yours, 9;r, C. W. Fay Vice President Nuclear Power

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