ML20235T231

Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Rulemaking Will Cause Delay in Further Maint Enhancement as Licensee Backtrack to Assure Prescriptive Compliance

ML20235T231
Person / Time
Site:	Turkey Point
Issue date:	02/22/1989
From:	Griffin B FLORIDA POWER & LIGHT CO.
To:	Zech L NRC COMMISSION (OCM)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00018, 53FR47822-18, NUDOCS 8903080201
Download: ML20235T231 (3)

Text

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20CKET NUMBER ~ , dT" j g-W.0 POSED RULE.pp._% .

Q fR Y9[k :q.m Florida *89 FEB'27 A10 :46

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J B. L. Griffin DOCr- ".-

Executive Vice President February 22, 1989 Mr. Lando W. Zech, Jr., Chairman U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Chairman Zeck:

I wanted to take this opportunity to provide my personal views concerning the Maintenance Rulemaking which I believe should not be finalized in its current form and schedule.

I had a. chance to briefly discuss this issue when you vis-

-ited Crystal River last May. I wanted.to reiterate my

. current views as the comment period draws to an end especially in light of information that leads me to believe it may be published in roughly its current form. Florida Powe_r Corpora-tion (FPC) is' participating in detailed comments, individually, -

through NUMARC and other forums.

'I believe you are aware that the industry almost universally.

opposes this rule. We are not opposed for basic philosophical' reasons because we wholeheartedly believe that maintenance is of paramount importance to the nuclear industry from a safety ,

and a reliability viewpoint. I further believe the balance of the industry holds a similar view.

FPC has a strong maintenance program and is actively working to enhance it by consolidating our maintenance related activ-ities into a comprehensive maintenance plan. We know that excellence in maintenance is an important path to safe and reliable operation. I believe the majority of other utili-ties see the same benefits and are working in the same 1

direction. If the Commission's concern is a minority of plants that do not adequately address maintenance, the NRC already has the clear capability to deal with them and has demonstrated that capability. Rulemaking will almost certain-ly cause delay in further maintenance enhancement as we e903080201 890222*

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[53N47822 3201 Thirty fourth Street South P.O. Box 14042 St Petersburg. Florida 33733 813 866 5151 A Florida Progress Company

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4 IMr.;Lando Wh Zech,LJr.,LChairman

' February:-22, 1989

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• 1 backtrack.to assure prescriptiveicompliance. .I know.this.is-not the-Commission's intent, but we must face'such'a' reality

. and factor it into our decisions'.'

I feel strongly that a" Maintenance' Rule will cause ' consider.- '

able disruption of.:our ongoing maintenance program and.will-result in future implications that will have significantly

' diverged from the intent of this rulemaking. Specifically,

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< the following items are of' concern' to 'me:

The rule will result in increased regulatory. inspection and dilution'of utility resources to respond to the

' inspections, -including- non-safety related' balance of -

. plant areas.

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.. The' rule will-result in increased documentation and required strict. compliance with the program for non-safety'related activities. This will signi.ficantly reduce our flexibility,' dilute resources from safety-related activities and' increase costs with~ minimal benefit.

The rule ~will decrease our flexibility to_ change and adjust our program as conditions change and technology

-advances. The maintenance program'will be a licensed program and, therefore, will require strict adminis-trative control to maintain compliance.

The. rule will require significant manpower diversion to change'our. existing and time-proven procedural,.

administrative.and technical bases in order to comply with new regulatory guidance. The training and re-

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training efforts alone will significar,tly impact our E manpower.

. Incentive for our maintenance staff and craft to im-prove and enhance our maintenance capability and performance will be. hampered by the necessity to concentrate on regulatory' interpretations, inspections 4' and potential ratcheting.

We welcome the challenge to keep maintenance a cornerstone to a safe and productive future for the nuclear industry. We must not sway from a commitment to move forward in this area.

However, if you choose to mandate where management should be exerting leadership you will, in my opinion, create a 8 -_= - . _ _ _ _- _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _

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' FGbruary 22, 1989~

Page 3' significant disincentive~to those who'have shown initiative-

, andf foresight'in this and other areas.

1(must oppose this rulemaking and urge'your personal recon ;

s'ideration as well.as that of yourifellow Commissioners.

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Veryft ruly yours, p '

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L 'BLG:sbl

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cc: Commissioner James.R.-Curtiss ..,

- Commissioner Thomas M. Roberts-

' Commissioner Kenneth M. Carr Commissioner Kenneth Rogers

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