ML20235V400

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Comment on Proposed Rule 10CFR50 Re Maint Program at Nuclear Plants.Proposed Maint Rule Has Potential to Significantly Undermine Util Initiatives & Direct Limited Resources Away from Real Improvements in Maint
ML20235V400
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 03/02/1989
From: Keiser H
PENNSYLVANIA POWER & LIGHT CO.
To: Zech L
NRC COMMISSION (OCM)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00063, 53FR47822-63, NUDOCS 8903100167
Download: ML20235V400 (2)


Text

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DOCKET MOPOSED RULE NUMBER g [< "N - Q Q Pennhlva i ow & Light Company ,.g M '-

Two North Ninth Street e Allentown. PA 18101-1179 e 215/770-5151 March 2, 1989 '89 MAR -7 PS :31-Harold W. Keiser Senior Vice President Nuclear ,yta:

215/770-4194 00 Chi.I a i , ! . ', kJ '

BReNL" The Honorable Lando W. Zech, Jr.

Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Chairman Zech:

When you ' visited PP&L's Susquehanna Steam Electric Station, you saw a well managed and well maintained plant. This was largely due to an excellent maintenance program initiated very early in plant life.

We are, however,- continuing to enhance this program. We are upgrading our Preventative Maintenance Program through the application of new techniques and technologies such as reliability centered maintenance and thermography. We also are investigating the use of new computer applications such as expert systems.

We are strengthening our root cause investigations by involving the mechanics and workers in the process. Our significant events and analysis program relies heavily on root cause techniques. In addition, we have initiated a very aggressive water chemistry program to lengthen the lives of plant components and to reduce the need for corrective maintenance. PP&L, like other nuclear plant owners, is expending significant resources to upgrade plant maintenance.

Given this background, I am concerned that the proposed maintenance rule has the potential to significantly undermine our initiatives and direct our limited resources away from real improvements in maintenance. The NRC appears to be taking this action despite strong evidence that our maintenance initiatives, and those of the industry, are working. The AE0D report on safety performance and operational reliability indicates real progress is being achieved in maintenance.

I would appreciate the opportunity to discuss these concerns with you, either in person or by phone. I look forward to hearing from you on this issue.

Sincerely, 8903100167 890302 R4 22 PDR ,

H. W. Keiser

...I 4-0229105061 03/02/89 ICS IPMMTZZ CSP WHSB 215770u194 MGMB TDMT ALLENTOWN PA 272 03-02 0305P {$T MTR -6 R2:10

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1 PROPOSED RULE. !n WCd ...

HONORAdLE LANDO W ZECH JR CHAIRMAN US NUCLEAR REGULATORY COMMISSION k(

WASnINGTON DC 20555 DEAR CHAIRMAN ZECH '

WHEN YOU VISITED P P AND L SUSQUEHANNA STEAM ELECTRIC STATION, YOU SAa A aELL MANAGED AND DELL MAINTAINED PLANT. THIS WAS LARGELY DUC TO AN EXCELLENT ' MAINTENANCE PROGRAM INITIATED VERY EARLY IN THE PLANT LIFE WE ARE HOWEVER CONTINUING TO ENHANCE THIS PROGRAM. WE ARE UPGRADING OUR PREVENTATIVE MAINTENANCE PROGRAM THROUGH THE APPLICATION OF NEW TECHNIQUES AND TECHNOLOGIES SUCH AS RELIABILITY CENTERED MAINTENANCE AND THERM 0 GRAPHY. WE ALSO ARE INVESTIGATING THE USE OF NEW COMPUTER APPLICATIONS SUCH AS EXPERT SYSTEMS.

WE ARE STRENGTHENING OUR ROOT CAUSE INVESTIGATIONS BY INVOLVING THE MECHANICS AND WORKERS IN THE PROCESS. OUR SIGNIFICANT EVENTS AND ANALYSIS PROGRAM RELIES HEAVILY ON ROOT CAUSE TECHNIQUES. IN ADDITION WE HAVE INITIATED'A VERY AGGRESSIVE WATER CHEMISTRY PROGRAM TO LENGTkEN THE LIVES OF PLANT COMPONENTS AND TO REDUCE THE NEED FOR CORRECTIVE MAINTENANCE P P AND L LIKE OTHER NUCLEAR PLANT OWNERS IS EXPENDING SIGNIFICANT RESOURCES TO UPGRADE PLANT MAINTENANCE.

GIVEN THE BACK GROUND I AM CONCERNED THAT THE PROPOSED MA!HTENANCE -l RULE WAS THE POTENTIAL TO SIGNIFICANTLY UNDERMINE OUR INITIATIVE AND DIRECT UUR LIMITED RESOURCES AWAY FROM REAL IMPROVEMENTS IN MAINTENANCE. THE NRC APPEARS TO BE TAKING THIS ACTION DESPITE STRONG EVIDENCE THAT QUR MAINTENANCE INITIATIVES AND THOSE OF THE INDUSTRY ARE WORKING. THE AEOD REPORT ON SAFETY PERFORMANCE AND OPERATIONAL RELIABILITY INDICATES REAL PROGRESS IS BEING ACHIEVED IN MAINTENANCE I WouLD APPRECIATE THE OPPORTUNITY TO DISCUSS THESE CONCERNS WITH YOU EITHER IN PERSON OR BY PHONE I LOOK FORWARD TO HEARING FROM YOU ON THIS ISSUE SINCERELY H W KEISER SENIUR VICE PRESIDENT = NUCLEAR 15:08 EST S MGMCOM8 k

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