ML20235V826

Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Util Continues to Implement New Programs & Practices That Enhance & Improve Maint

ML20235V826
Person / Time
Site:	Cooper
Issue date:	02/27/1989
From:	Kuncl L NEBRASKA PUBLIC POWER DISTRICT
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00043, 53FR47822-43, NLS890090, NUDOCS 8903100352
Download: ML20235V826 (3)

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41 February 27, 1989 '((. .. $j , , , , , ,. m Ob ER E Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch

Subject:

Comments on Proposed Maintenance Rule Cooper Nuclear Station Docket No. 50-298, DPR 46

Reference:

1) Proposed Rule 10 CFR Part-50 Ensuring the Effectiveness of Maintenance Programs for Nuclear Power Plants 53 FR 47822 (November 28, 1988) REQUEST FOR COMMENTS

2) Letter from NUMARC to Mr. Samuel J.

Chilk, dated February 27, 1989, Same Subject.

Dear Mr. Chilk:

These comments are submitted by the Nebraska Public Power District (NPPD or District) in response to the request of the U.S. Nuclear Regulatory Commission ("NRC") for comments on the referenced NRC proposed rule relative to effectiveness of maintenance programs for nuclear power plants (53 FR 47822).

The District is deeply concerned that the NRC is proceeding with expedited rulemaking on an issue as complex as maintenance without a thorough evaluation and understanding of the impact of this rule on utility maintenance efforts or a demonstration that implementation of the rule will achieve improvements in safety or reliability. The District opposes the rule because we are concerned that the rule will undermine our efforts to effect maintenance properly and will redirect our attention and resources away from the real improvements we are achieving today.

The industry expressed its concern over the determination of the Commission to proceed with a rulemaking in an October 28, 1988 letter from Robert Campbell, Chairman, p) 8903100352 890227[ d /

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Mr. Chilk February 27, 1989 Page 2 NUMARC Board of Directors, to Chairman Zech.

Importantly, the industry stressed to the NRC its commitment of achieving improved reliability and safety through better maintenance. All sixty members of the NUMARC Board of Directors including NPPD, endorsed those positions. The industry also agreed that there is additional work that needs to be done and it committed to continuing the present efforts and to implementing new activities including verification of their benefits. The District is firmly committed to the achievement of excellence in the overall operations of its nuclear facility to further ensure the viability of our nuclear option through safe and economic power generation. Wo believe that the NRC can establish the proper environment for excellence by issuing rules only when there is reasonable assurance that the required actions will actually reduce the risk from the operation of nuclear i facilities.

We strongly encourage the Commission not to proceed with promulgation of the final rule until there is a clear understanding of where the current industry maintenance practices do not meet the NRC's regulatory requirements and until a thorough evaluation of the impact of the regulatory requirements to correct any inadequacies has been completed. This is extremely important on such a diverse and complex issue as maintenance. The District agrees with NUMARC's position (Reference 2) that a delay in the promulgation of a final rule until such matters are properly addressed will not be adverse to public health and safety.

The District has continued to implement new programs and practices that enhance and improve maintenance and has established many positive initiatives in maintenance activities to address those areas needing improvement.

Although real improvements take time, we believe that the industry has demonstrated that it is making substantive progress in strengthening our weaknesses as evidenced by these ongoing industry initiatives. For example, the District initiated a Maintenance Self-Assessment utilizing INPO Criteria and has implemented a program to address its findings. In addition, a comprehensive Reliability Performance Monitoring Program has been developed with full implementation of the program expected by 1991. Re-evaluation of the System

e i 4 Mr. Chilk February 27, 1989 Page 3

- Engineering Program .at Cooper Nuclear Station was

- recently completed and a training program to enhance this concept is in progress. Training programs are also being pursued- in regard to Preventative, Predictive, and Reliability Centered Maintenance for engineering and-maintenance ' personnel. Although . the District already has a comprehensive Preventive Maintenance Program in place and has updated its essential vendor manuals, we

- are evaluating the necessity of upgrading our program to include Predictive and Reliability Centered Maintenance.

The District appreciates the opportunity to. comment on the proposed rule and would welcome the opportunity to discuss our comments, as well as alternative approaches, with appropriate NRC personnel.

Sinc ely, 8

L. G. Kun 1 Nuclear Power Group Manager LGK: caa24-3 (NED) cc: NRC Regional Administrator Arlington, TX Senior. Resident Inspector Cooper Nuclear Station Byran Lee NUMARC

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