ML20235R686

Comment on Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Rule Should Not Be Implemented Until Realistic Determination of Impact of Rule on Industry Has Been Made

ML20235R686
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/21/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00017, 53FR47822-17, NUDOCS 8903030390
Download: ML20235R686 (4)

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__ , f _ PbetanciGeneralElectricCoirytniy - --T:y-I David W. Cockfield Vice President, Nuclear '89 FEB 24 P1 :52 it.

February 21, 1985 Trojan Nuclear Plant Docket 50-344 I.icense NPF-1 Secretary of the commission Attn: Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington DC 20555

Dear Sir:

Comments on Proposed Maintenance Rule (53 FR 47822)

On November 28, 1988, the commission published for comment (53 FR 47822) its proposed rule [ Title 10, Code of Federal Regulations, Part 50.65 (10 CFR 50.65)) on maintenance programs for nuclese power plants. - Portland General Electric (PGE) is pleased to provide the following comments on the proposed rulemaking.

While we are in agreement that establishment of a comprehensive and effective maintenance program is important, we are concerned that a regulation is being proposed with:

1. No realistic statement of benefit,

2. Applicability to structures, systems, and components that are irrelevant to the protection of public health and safety,

3. A requirement to develop a maintenance standard which will be meaningful for all plants,

4. Possible use of a third party to certify the program,

5. Unjustifiable cost impact.

6. Possible certification requirements for maintenance personnel, and

7. Such vagueness that many interpretations are possible resulting in an inability to precisely determine the impact of the rule and as such, an inability to determine resource' commitments.

Details of these concerns are contained in the Attachment.

8903030390 890221 PDR PR 50 53FR47822 PDR 12: S W Saman freet Poniano. Oregon 37204 / -

W M BBCiriC CCeuptsif Secretary of the Commission February 21, 1989 Page 2 You acknowledge that the majority of plants have good maintenance prograns and that the concern focuses upon the lower 25 percent. You further acknowledge that improvements are continually being made by all plants through their own initiative and through industry group initiatives. Even the lower 25 percent are seeing improvement albeit at a much slower pace than desired. For those plants which are not making adequate progress, authority already exists to enforce compliance in the maintenance area without implementing a new regulation. This approach would seem the most efficient and direct.

Improvements that have taken place and are continuing to take place have occurred without a maintenance rule. The results of these improvements may not be seen immediately following a change to a maintenance program but may in some cases take years to see. This being the case, the Advisory Committee on Reactor Safeguards (ACRS) concern that the rule could have a negative impact may not be noticed until years later. We do not feel that a realistic determination of the impact of this rule upon the industry has been made; and until such time as it is, we feel the rule should not be implemented especially in light of the improvements that you recognize are continually taking place.

Sincerely,

/ 1

.i Attachment I c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant Mr. Roger Colburn State of Oregon l

Oregon Public Utility Commission l D

Trojan Nuclear Plant Secretary of the Commission Docket 50-344 February 21, 1989 License NPF-1 Attachment Page 1 of 2 CONMENTS ON PROPOSED MAINTENANCE RULE

+ While the proposed rule does not require that we report Maintenance Performance Indicators (MPIs), you have requested feedback as to whether the rule should be changed to require such reporting. Although some generic MPIs may be applicable to all plants, the usefulness of such indicators to determine effectiveness of maintenance programs may be misleading or meaningless due to differences in individual plants, policies, etc. A situation could develop where improvements to MPI reporting could be made at the expense of individual maintenance programs (i.e., the focus will be on keeping MPIs looking good so as to avoid being classified as a plant needing improvement).

+ The rule states that monitoring programs for determining maintenance effectiveness will be subject to Nuclear Regulatory Connission (NRC) review, but it does not state if NRC approval is needed prior to implementation or how modifications are to be reviewed. We are con-cerned that timely changes to our monitoring program will be impeded by NRC review of such programs.

+ We consider the scope of the rule for covering all systems to be too broad. For our situation at Trojan with its small maintenance and support group, the impact of this broad scope would be to dilute the efforts now being taken to improve maintenance on safety-related systems. Our current policy is to perform the same level of maintenance on quality or non-quality systems; however, the controls on these systems are significantly different (i.e. , detail of work instruction, verification, quality control support, documentation, etc.). We feel the resources necessary to upgrade the controls on the non-quality systems could be more effectively utilized.

• A standard to implement this rule, that is yet to be developed, will supposedly allow for flexibility for adoption of new innovative technology as they are validated. It is unclear as to who would perform the validation and the timeliness of such a process.

+ While Draft NUREG-1333, " Maintenance Approaches and Practices in Selected Foreign Nuclear Power Programs and Other U. S. Industries: ,

Review and Lessons Learned", lists practices of foreign countries and {

others Which were found to contribute to effective maintenance, the adaptation of some of the practices may be difficult to achieve. For example, our plans for using an integrated information system for collecting data and monitoring the effectiveness of a maintenance program may not be implemented for some time. Also, a certification program for maintenance workers inplies that licenses may be required j for those workers similar to that now required for reactor operators.

! The administrative costs associated with such certification will be j significant due in part to the large turnover in the workforce and the use of contractor and temporary personnel.

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Trojan Nuclear Plant Secretary of the commission Docket 50-344 February 21, 1989 License NPF-1 Attachment Page 2 of 2

• ' We take exception to the Commission's view that the rulemaking is desirable to foster common maintenance practices. What may be good for some utilities, may not be so for others. Also, the resources of utilities differ making what may be a simple practice for one plant an overwhelming one for another.

• Your encouragen,ent to use the Nuclear Plant Reliability Data-System (NPRDS) as a moans to evaluate the effectiveness of our maintenance, program should be tempered. The NPRDS will give a gross indication of a problem and should be used, but the usefulness of such information is limited since inaintenance practices, component application, etc., will vary from plant to plant.

+ A two-year tine frame to develop a standard appears reasonable, but to l implement it within that time period does not. The shear magnitude of l implementing additional monitoring and control systems, performing failure trent.ing and analysis, and increasing preventative maintenance on all systems will take much time and resources.

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• We do not feel it appropriate for a designated third party-to certify that our pinnt maintenance program complies with a standard. The management of our maintenance program should rest solely with us and not be diluted by additional reviews and certifications by outside parties.

. While'we agree that individual worker accountability plays an important role in an effective maintenance program, it does not appear to us that this consideration can be effectively legislated.

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- We ' agree with Commissioner Robert's comments that the proposed rule fails te provide a basis for determining when a maintenance program is effective or when improvements are " appropriate". Without this basis, we canr.ot estimate the amount of resources necessary to comply with such a nebulous target. We further question the assertion that the economic impact on us will be nil. Besides the futility of estimating costs associated with a vague and general rule, we feel there is insufficient data and explanation to support the claim that gains in plant availability and reduced reactive maintenance costs will offset the costs associated with implementing the rule.

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