ML20235V854

Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Util Committed to Goal of Achieving Improved Reliability & Safety Through Better Maint

ML20235V854
Person / Time
Site:	Hatch, Vogtle, 05000000
Issue date:	02/27/1989
From:	Hairston W GEORGIA POWER CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00041, 53FR47822-41, HL-338, NUDOCS 8903100366
Download: ML20235V854 (4)

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sucw roper.iene HL-338 ELV-00277-February 27, 1969 X7GJ17-H220-Docket Nos. 50-321 50-424 50-366 50-425 Mr. Samuel J. Chilk Secretary of the Commission <

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION: Docketing and Service Branch Georgia Power Company Comments on NRC Proposed Rule Proposed Maintenance Rulemaking  !

(53 Federal Reaister 47.822-of November 2B.1988) {

Dear Mr. Chilk:

The Nuclear Regulatory Comission (NRC) published the proposed l maintenance rulemaking in the Federal Register on Novent>er 28, 1988, and invited. comments by January 27, 1989. The comment period was later extended ,

to February 27, 1989.- Georgia Power Company (GPC) has monitored the efforts )

of NUMARC with regard to this proposed rulemaking. In accordance with the i request for comments, GPC hereby endorses the NUMARC comments to be provided ,

to the NRC on February 27, 1989. GPC also submits the enclosed comments addressing some of the issues that are of particular significance to GPC.

GPC arareciates the opportunity to comment on the proposed rule. If you have any < .stions, please contact our office.

Sincerely, j M-W. G. Hairston, III i WGH,III:CRP/db Enclosure 8903100366 890227?

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i GeorgiaPower d Page 2 c: Georata Power comoany Mr. J. T. Beckham, Vice President - Nuclear, Plant Hatch Mr. C. K. McCoy, Vice President - Nuclear Plant Vogtle Mr. P. D. Rice, Vice President and Vogtle Project Director Mr. G. Bockhold, Jr., General Manager - Plant Vogtle U. S. Nuclear Reculatory Commis11on. Washinoton. D.C. '

Mr. L. P. Crocker, licensing Project Manager - Hatch Mr. J. B. Hopkins, ticensing Project Manager - Vogtle l

1!. S. Nuclear Reaulatory Commission. Reaion II Mr. S. D. Ebneter, Regional Administrator Mr. J. E. Menning, Senior Resident Inspector - Hatch Mr. J. F. Rogge, Senior Resident Inspector, Operations - Vogtle is/46 l

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ENC 1.05URE GPC COMMENTS ON NRC PROPOSED MAINTENANCE RULEMAKING

-Georgia Power Company (GPC) is committed to the goal of achieving improved reliability and safety through better maintenance. This is 4 evident at Plant Hatch where there are several years of operation available-for review. The results of this commitment have been demonstrated at Plant Hatch in the past few years by its dramatically improved -record of reliability

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and availability. These improvements were achieved partially through an upgraded maintenance program. Significant upgrades have been mado in the area inventory of maintenance training and procedures, control, preventive and predictive maintenance programs, and ou work order processing, tage planning.

This is also evidenced through Plant Hatch's improved SALP ratings in the maintenance area in the past few years. Recognizing that effective maintenance programs result in improved plant performance, Plant Vogtle has done extensive work to assure adequate maintenance procedures are developed and adequate corrective, predictive and preventive maintenance and maintenance surveillance programs are in place. This has resulted in a comprehensive maintenance program at Plant Vogtle. GPC is committed to continuing the present efforts at both Plants Hatch and Vogtle and to implementing new efforts that prove to be beneficial.

Poor, ineffective maintenance programs should be of concern. However, as discussed below and in the NUMARC Letter to the NRC of February 27, 1989, which GPC has endorsed, GPC does not believe that the proposed rule will serve to increase the Commission's ability to ensure that all nuclear power plants are reliably maintained. In fact, due to the diversion of resources, the proposed rule may have just an opposite effect and decrease overall plant safety. The NRC's own Advisory Comnittee on Reactor Safeguards (ACRS), its staff, its consultants, and all the nuclear utilities have advised against such a rule on the same basis. It is difficult to conceive that the Commission would disregard the advice of these groups, since that is where the bulk of the maintenance expertise resides.

The Commission has based the bulk of their conclusions on the data in NUREG-1212. This data was collected in the 1984-1985 time frame. Based on their analyses, the NRC concluded that possibly 25 plants had inadequate maintenance programs. Assuming this data represented the U. 5. industry maintenance programs in 1985, it is now obsolete and is therefore inappropriate to base conclusions en the need for a new rulemaking for principally two reasons. First, significant strides is nuclear utility maintenance programs have been made since the 1985 time frames. Second, it is unreasonable to promulgate a rulemaking which the NRC has not shown to be required for any plants in the 1989 time frame but which im>oses a significant financial burden on the nuclear industry. The NRC already its resources at its disposal to take enforcement action should they believe that any utility's maintenance program is ineffective to the point where plant safety is impacted. New analyses provided by NUMARC in their February 27 letter to the El-1

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NRC indicate that there has been significant improvement in maintenance programs since 1985. Also, these analyses indicate that utilities will incur substantial implementation costs with a possible net decrease in plant performance and safety if this proposed rulemaking in the current form were to be adopted.

The Commission has applied 10 CFR 50.109(a)(4), more commonly known as the " adequate protection clause" of the backfit rule, as the primary justification for the proposed maintenance rulemaking. The application of

" adequate protection" in this case is unjustified since this requires the Commission to find that, in Commissioner Roberts words, "t;he current operating

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plants now pose an undue risk to the public which we are presently tolerating...This is clearly not the case." Nowhere in the proposed rulemaking, nor in the regulatory tnalysis, does the NRC state or imply that there is not an adequate level of safety for any licensee, groups of licensees, or the entire industry. The Commission should operate within the intent of the backfit rule and demonstrate clear evidence t1at the current level of safety in the nuclear industry is unacceptable before applying this section.

The pro)osed rulemaking is very broadly based and defines a number of activities tiat the NRC believes comprises an " adequate" maintenance program.

However, nowhere in the proposed rulemaking is the scope of the activities defined, nor the methodology for measuring the effectiveness of those activities. Without an understanding of the scope of these activities, a regulatory analysis cannot be adequately performed. In fact, this rulemaking is :o broadly defined that such activities as operator training and configuration design control could be interpreted to fall within its scope.

This will lead to varying interpretations of the rulemaking through the years with different utilities and NRC personnel. Furthermore, if the NRC continues with the issue of certifying nuclear plant maintenance programs, the question of recourse for uncertified plants would need to be addressed (e.g., would uncertified plants do no maintenance?). These same conditions leo to confusion in past rulemakings and resulted in both the nuclear industry and the NRC expending significant rmurces uneconomically. In addition, the NRC has proposed that BOP equipmen: tu included as a scope of this rulemaking.

The inclusion of BOP equipment in this rulemaking certainly cannot meet the

" adequate protection" criteria of the Backfit Rule. Maintenance performed on non-safety related equipment is already dictated by performance, operability requirements, end the overall contribution to risk. Inclusion of this non-safety related equipment into the regulatory area will dilute the attention of the NRC and plant personnel from tFeir primary concern with the nuclear safety portions of the plant. These conditions are clearly unacceptable.

It is GPC's conclusion that there is adequate evidence to demonstrate the potentially adverse effects of the currently proposed inaintenance rulemaking.

With such evidence, the Commission should proceed carefully so as not to undo the tremendous strides made in the U. S. Nuclear Program within the past few years.

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