ML20235V557

Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Util Supports NUMARC Position on Proposed Rule

ML20235V557
Person / Time
Site:	Davis Besse
Issue date:	02/27/1989
From:	Shelton D TOLEDO EDISON CO.
To:	Chilk S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 1641, 53FR47822-00065, 53FR47822-65, NUDOCS 8903100229
Download: ML20235V557 (2)

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Docket Number 50-346 License Number NPF-3 Serial Number 1641 February 27, 1989 Mr. Samuel J. Chilk, Secretary United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Subj ect : Comments on Proposed Maintenance Rule

Dear Mr. Chilk:

Toledo Edison is pleased to provide comments on the proposed rule as requested by the NRC in the November 28, 1988 Federal Register (53FR47822).

Toledo Edison strongly supports the NUMARC position on the proposed rule and would like to place particular emphasis on the following points which have been communicated to the Nuclear Regulatory Commission (NRC) during earlier meetings and dialogue on the Maintenance Rule.

1) The rule is unnecessary. Commissioner Roberts speaks most eloquently to this point, "Most importantly... there has been no demonstration that this rule vould improve implementation of existing programs. Neither have I been provided with compelling documentation on what the problem is and how, specifically, this rule vill fix it." Industry initiatives coordinated by NUMARC and INP0 have already shown progress in increasing the effectiveness of maintenance programs within the industry.

Further, the Commission already has several rules and programs in place that can effectively correct poor maintenance practices at individual utilities without burdening the entire industry.

2) The rule vould probably do more harm than good. Applying this resource-intensive initiative to all plant equipment appears to be in direct opposition to the recent Individual Plant Examination (IPE) generic letter (88-20), which proposed to focus limited utility resources on those plant features most significant to safety. The IPE program, the 8903100229 090227 53 47822 ,PDR (/

THE TOLEOO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 c____-___---

.,q Docket Number 50-346 License Number NPF-3 Serial Number 1641 Page 2 cornerstone of severe accident resolution, has also been proposed as the vehicle for resolving other issues such as systems interaction.

3) This rule should be required to meet the standards of the Backfit Rule (10CFR50.109), since the rule proposes to modify and/or add procedures required to operate the plant. To argue that the proposed rule can be implemented under the " adequate protection" stendard implies that nuclear plants do not presently assure it.

The industry's safety record and continuing work at improvement refute that implication.

If you have any questions concerning this matter, please contact Mr. R. V.

Schrauder, Nuclear Licensing Manager, at (419) 249-2366.

Very truly yours,

[ . . . . .

GAB /dlm cc P. M. Byron, DB-1 NRC Resident Inspector A. B. Davis, Regional Administrator, NRC Region III T. V. Vambach, DB-1 NRC Senior Project Manager

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