ML20235V664

Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Proposed Rule May Be Detrimental to Safety by Discouraging Potentially Superior Maint Practices

ML20235V664
Person / Time
Site:	Ginna
Issue date:	03/01/1989
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00067, 53FR47822-67, NUDOCS 8903100274
Download: ML20235V664 (2)

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BPANG Mr. Samuel J. Chilk, Secretary United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch

Subject:

Request For Comments Proposed Rule 10 CFR Part 50 Ensuring The Effectiveness of Maintenance Programs For Nuclear Power Plants 53 FR 47822 [ November 28, 1988]

Dear Mr. Chilk:

Rochester Gas And Electric Corporation would like to take this opportunity to provide its comments on the above referenced proposed rule.

As licensee for the R.E. Ginna Nuclear Power Plant, RG&E is committed to the goal of achieving excellence in safety and operational reliability through constant review and improvement of all its nuclear-related programs. As part of our efforts to achieve this goal, we are working with INPO and other industry groups to continuously assess _, develop, and improve our maintenance programs.

RG&E believes that current and planned industry programs adequately address improvements in plant maintenance, and that the proposed rule is inconsistent and potentially detrimental to some of these industry-initiated efforts. In this regard, we endorse the position of Commissioner Roberts that, "the trends staff has provided show continued improvement in the maintenance area." We also agree with the ACRS's concern that, "there are characteristics of regulations, and especially the way in which they are typically enforced, that lead us to believe that, under a rule, a move toward uniformity would occur, and this is likely to decrease the effectiveness of some of the better existing programs."

Furthermore, maintenance has been intensely scrutinized during the NRC's SALP reviews, and thus the programs are adequately reviewed by NRC personnel on a periodic basis. Publication of a Rule would not significantly enhance NRC review programs.

8903100274 090301 PDR 53 47822

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RG&E agrees with Commissioner Roberts that the NRC should be required to show that the proposed maintenance rule complies with the provisions of the backfit rule. We would request the opportunity to examine and comment on any detailed staff calculations purporting to show the cost effectiveness of this proposed rule.

In summary, RG&E does not believe that the proposed rule is necessary to provide adequate protection to the public; we believe, to the contrary, that it might prove detrimental to safety by discouraging potentially superior maintenance practices that fall outside the strict provisions of any rule. We therefore urge the Commissioners to reject the proposed rule.

Very truly yours, Robert C. Mec dy General Manager Nuclear Production TAD \023 xc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Carl Stahle - Mail Stop 14D1 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Ginna Senior Resident Inspector

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