ML20235V901

Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Supports NUMARC Position.Proposed Rule Will Hinder Important Initiatives to Improve Maint

ML20235V901
Person / Time
Site:	Indian Point
Issue date:	02/24/1989
From:	Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00046, 53FR47822-46, NUDOCS 8903100391
Download: ML20235V901 (2)

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Consohdated Edison Company of New York, Inc. ,, ;I, y [ ; U Indian Point Station 'r Broadway & Bleakley Avenue B ana '

February 24, 1989 7 ,ns 737-8116 89 MAR -1 A9 :27 Re: Indian Point Station Docket No. 50-247 7 00L:. ,- r

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Mr. Samuel J. Chilk Secretary of the Commission US Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch

SUBJECT:

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:

Consolidated Edison Company of New York, Inc., (" Con Edison")

welcomes the opportunity to express its views to the Commission on the referenced proposed rule pertaining to nuclear power plant maintenance programs.

Con Edison is committed to continually improving the reliability and safety of Indian Point Unit No. 2. Improvements have occurred in several functional areas, one of the more significant being maintenance. In that regard, we conducted a maintenance self-assessment which resulted in a number of recommendations for improvement specific to our needs. We are in the process of implementing these recommendations stemming from this assessment, utillzing existing staffing and outside assistance. No matter how well intentioned the proposed rule is, we are concerned that the administrative requirements and unavoidable prescriptive elements of the rule would divert important and knowledgeable personnel from the preferred focus of our currently identified improvement efforts. Therefore, we believe that a rule is not in the best interest of Con Edison, and if implemented will detract from other activities to further enhance the reliability and safety of Indian Point Unit No. 2.

l As a member of the Nuclear Management and Resources Council, Inc.

("NUMARC"), we have participated in that organization's efforts in commenting on this proposed rule. We have reviewed and accepted the industry-wide position presented by NUMARC. The detailed comments on the proposed rule contained in the NUMARC submittal are fully endorsed by Con Edison and should be considered as an adjunct to this letter.

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1 At Indian Point Unit-No. 2, past efforts to improve maintenance have helped to result'in significant improvements in availability..

and capacity factor.and fewer trips and safety systems actuations.

Through our. ongoing efforts we expect to continue these trends.

We continue to strive for excellence in these areas and do not believe a rule is necessary to accomplish this objective. To the contrary, we are concerned that such a rule will hinder important initiatives.

Very truly yours, h /

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cc: Document Control Desk A US Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C. -20555 Mr. William Russell Regional Administrator - Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1498 Mr. Donald S. Brinkman, Project Manager Project Directorate I-1 Division of Reactor Projects I/II US Nuclear Regulatory Commission Mail Stop 14B-2 Washington, D.C. 20555 Mr. Larry Rossbach Senior Resident Inspector US Nuclear Regulatory Commission P.O. Box 38 Buchanan, N.Y 10511

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