ML20235V930
| ML20235V930 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/27/1989 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR47822, RULE-PR-50 53FR47822-00055, 53FR47822-55, ULNRC-1922, NUDOCS 8903100409 | |
| Download: ML20235V930 (3) | |
Text
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N Mr. Samuel J. Chilk N
Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 ATTENTION: Docketing and Services Branch Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT COMMENTS ON PROPOSED MAINTENANCE RULE These comments are submitted in response to the request of the Nuclear Regulatory Commission (NRC) for comments on the NRC proposed rule related-to effectiveness of maintenance programs for nuclear power plants (53 FR 47822).
Union Electric has been involved in the preparation and review of the extensive comments provided by the Nuclear Management and Resources Council Inc. (NUMARC) on February 27, 1989. We fully endorse the NUMARC comments.
In addition we would like to highlight the following issues associated with the proposed rule:
i A major concern is the lack of a demonstrated need for the rule since most utilities already have effective maintenance programs as indicated by NRC's SALP process. In the specific case of plants such as Callaway, where effective maintenance programs exist, implementation of a rule will result in redirection of resources in order to achieve compliance with specific requirements of the rule, instead of continuing with program enhancements.
8903100409 890227[
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'4-Mr. Samuel Jo Chilk Page 2 February 27, 1989 j
The proposed-rule should be promulgated only if it will result in
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a substantial increase in the overall protection of the public 1
health and safety. This would require a backfit analyses conducted
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under the provisions of 10 CFR 50.109. There is no basis for a presumption that U.S. nuclear plants are currently operating at a level below the " adequate protection" baseline.
The Regulatory Analysis in the proposed rule is inappropriate'in that industry costs are greatly underestimated and cost. savings associated with the rule are greatly exaggerated.
The proposed rule establishes requirements for specific program elements which are not defined in the rule or its accompanying discussions.
This will result in eventual interpretations of I
regulatory requirements and potentially even inadvertent regulatory non-compliance.
The proposed rule would have a negative impact on the' l
effectiveness of the Institute of Nuclear Power Operations (INPO) in assisting industry in striving for excellence in all aspects P
of plant operation, including maintenance. Use of the comprehensive Maintenance Guidelines, developed by INPO and the nuclear industry, as a regulatory standard is not appropriate.
The purpose of the Guidelines is to-set the direction for the I
industry to strive for excellence in maintenance.
The industry has been working to establish programs and practices that improve' maintenance. Although real. improvements take time, we believe that the industry has demonstrated that we are making substantive progress through ongoing industry initiatives. We strongly stand behind the position that a rule on maintenance is not practical nor will it be beneficial.
We appreciate the opportunity to comment on the proposed rule and are available to discuss our comments at your convenience.
Very truly yours, I
l Donald F. Schnell
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DS:jlh cc: Nuclear Management and Resources Council 1776 Eye Street, NW-Suite 300 Washington, D.C.
20006-2496
1 cc:
Gerald Charnoff, Esq.
Shaw, Pittman, Potts'& Trowbridge 2300 N.
Street,'N.W.
t Washington, D.C.
20037 Dr.,J. O. Cermak CFA, Inc.
4 Professional Drive (Suite 110)
Gaithersburg, MD 20879 R. C. Knop Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S.
Nuclear Regulatory Commission RRil Steedman, Missouri 65077 Tom Alexion (2)'
Office'of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 i
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