ML20235T444

Comment on Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants.Potentially Adverse Aspects of Proposed Rule Include Poor Definitions of Maint & balance-of-plant,maint Surveillance & QA

ML20235T444
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/24/1989
From:	Brey H PUBLIC SERVICE CO. OF COLORADO
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00024, 53FR47822-24, P-89066, NUDOCS 8903080285
Download: ML20235T444 (3)

Text

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PP0FOSED RULE (51 Rf V') Sal) ~~"a O Public Service' :Ch P.o. Box 840 89 FEB 27 P2 :03 o.nm co so2oi. o84o

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L February 24, 1989 Fort St. Vrain Unit No. I sF & i . , ,

00Cm P-89066 , , w, ,

Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-Docket No. 50-267

SUBJECT:

Comments on Proposed Rule Making for Maintenance Programs

REFERENCE:

Notice of Proposed Rule Making: Ensuring the Effectiveness of Maintenance Programs for Nuclear Power Plants, (53 FR 47822),

Published for Comment on November 28, 1988.

Dear Sirs:

Enclosed please find comments on the proposed rule making en maintenance programs' for nuclear power plants.

Public Service Company of Colorado is concerned that this rule, while well-intentioned, may have unanticipated effects that hinder maintenance improvement efforts, or actually detract from good maintenance performance.

Should you have any questions concerning this matter please contact Mr. M. H. Holmes (303) 480-6960 for information.

8903080285 090224 Very truly yours, PDR

$R53:R47822 9-], / On y h d'79%MA H. L. Brey, Manager Nuclear Licensing and Resource Management HLB /JXE:tmk Enclosure  !

4 ~ Attachment 1 P-89066 .

Page'1 Ll j

Comments i

1. As written, the rule itself appears benign but it has several potentially adverse aspects which include:

o Poor definitions of maintenance and Balance-of-Plant (B0P).

o Unclear _ extension of Appendix B quality -assurance programs to Balance-of-Plant (80P) maintenance programs and activities.

o Requirement to classify and separate "other" equipment from BOP equipment, as safety-related equipment is now classified and separated from non-sa fety-related equipment.

o Inadequate definition of terms, including:

Maintenance Surveillance

-Quality Assurance (as applied to Maintenance)

Quality Control (as applied to Maintenance) o Lack of criteria describing " adequate" programs.

o Severe penalty for reliability-centered maintenance (RCM) approches.

2. Based on industry maintenance initiatives and maintenance program performance improvements observed, this rule is unnecessary.

Commissioner Roberts' comments and the NRC's own admission substantiate this position.

3. . Existing NRC rules applicable to maintenance, and their very specific requirements are already in force. Greater emphasis on

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performance-based application of existing rules would yield the same result, unambiguously. The duplication of regulatory maintenance requirements should be explicitly avoided.

4. This rule will serve to introduce more ambiguity into the existing rules, with new tems introduced without definition, apparently conflicting with older accepted definitions.

5. This rule places the burden on the industry to make sense out of the whole subject area defined by the NRC. While it is desirable for the industry to set its own standards, the schedule for establishing those standards is very short. Implementing potentially poor standards in order to accommodate an accelerated schedule is not prudent.

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Attachment 1 P-89066;

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6. A considerable backfit potential is present if plants must initiate major labelling revisions, drawing revisions, and other l' programs to cover maintenance of BOP equipment. In addition, many computerized maintenance systems may require upgrades as a result of this rule .(work orders,. parts control schedulin'g, etc.). If !poorly implemented, this program could adversely affect existing safety-related maintenance programs.

7. It is not clear what new roles for quality assurance (QA) and F quality control.(QC) will result from this rule. Potentially,.

they could be very different from previous roles. Based on our experience, any rule that removes ownership . for maintenance .

performance from the maintenance organization is probably detrimental.

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