ML20244B324

Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants

ML20244B324
Person / Time
Site:	Saint Lucie, Turkey Point, 05000000
Issue date:	04/10/1989
From:	Hudiburg J FLORIDA POWER & LIGHT CO.
To:	Zech L NRC COMMISSION (OCM)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00082, 53FR47822-82, NUDOCS 8904190131
Download: ML20244B324 (3)

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00CXL M a~ a dri idaNt 6 Chairman Lando W. Zech, Jr.

Office of the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: NRC Maintenance Rule

Dear Chairman Zech:

It is widely recognized that maintenance at commercial nuclear generating stations is one of the major issues facing the nuclear power industry. The emphasis by the NRC, INPO, and NUMARC on maintenance in conjunction with the efforts of the individual utilities, is resulting in significant improvements in this vital area. The industry in general and Florida Power and Light (FP&L) specifically realize that an effective maintenance program is necessary for the continuance of nuclear power as a safe, viable energy source. Safety is a prime concern of the industry and already a high management priority in maintenance.

Excellent support has been provided to the industry through the development of the INPO 85-038 Guidelines for Maintenance, NUMARC Working Group 4 activities and issuance of the NRC Policy Statement on Maintenance of Nuclear Power Plants. FP&L understands the importance of effective maintenance as a means of enhancing the safe, reliable operation of our nuclear stations and is fully committed to its continued improvement. We are committed to these industry and regulatory initiatives.

The proposed NRC Maintenance Rule has been initiated to strengthen maintenance activities at commercial nuclear facilities. FP&L does not oppose the formulation of regulation when clearly justified, but in this complex area, we feel strongly that the proposed rule would be counter-productive and divert attention and resources from the many on-going industry initiated improvements, as well as from maintenance activities currently taking place at each plant on a ,

daily basis. Regulation will result in a shift from performance- I based to compliance-based maintenance evaluation. Resources will be diverted from the performance of maintenance activities to the development of documentation needed to satisfy the requirements of a compliance-based program. The elements of maintenance which will be regulated by the rule are management issues which cannot be codified and mandated. , ,

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l Chairman Zech Page 2 i

FP&L is committed to aggressively pursue improvements in maintenance at our sites as well as supporting industry-wide l initiatives. Turkey Point and St. Lucie Plants- dedicated  !

considerable manpower and resources to participation in the 1986 '

Pilot Maintenance Self-Assessment Project because of our belief in its value.

The following are examples of our progress:

St. Lucie 2 Unit led the world in capacity factor in 1988 supported by a strong maintenance program. '

Upgrades have not been limited to safety systems, but have included balance of plant systems and components as seen in the extensive valve packing program implemented at St. Lucie and Turkey Point sites to improve reliability of secondary systems.

The introduction of Total Quality Control concepts into the FP&L maintenance arena has contributed to a marked reduction in unplanned shutdowns. Our Turkey Point units had 29 unplanned shutdowns in 1984 as compared to 9 in 1988, a 69%

positive change.

Unplanned automatic scrams while critical for FP&L units have been reduced from an average of 8.0 in 1980 to 1.0 in 1988, an 87% improvement.

The_ Planned Maintenance Group at Turkey Point has been allocated $6.8 million since 1986 to continue an on-going effort to upgrade the preventive maintenance process, as well as continuing a system by system application of Analytical Based Preventive Maintenance.

Mean Time Between Failures for Turkey Point Units 3 and 4 has improved 53% from 22.7 days in 1980 to 48 days in 1988.

i Through application of the INPO 85-038 Guidelines and management involvement in the improvement process, we have realized upgraded material condition, better backlog control and improved work quality.

We are currently developing a multi-faceted computer based information system which will improve our ability to store and retrieve maintenance history, facilitate failure analyses, upgrade PM scheduling and integrate the various systems needed to execute an effective maintenance program. ,

I i

e Chairman.Zech Page 3 We have taken the initiative to improve maintenance effectiveness and will continue to do so. We clearly recognize goed maintenance as a prime contributor to the production of economical power generation with no compromise of public safety. We should :not disturb this self-initiated process with a regulatory approach which will shift our focus and resources from performance to compliance.

We appreciate your consideration of our views regarding this-important issue.

Sincerely, J. J. Hudiburg Chairman of the Bo rd &

Chief Executive Officer JJH/GLB/cib xc: Commissioner Thomas M. Roberts Commissioner Kenneth M. Carr Commissioner Kenneth Rogers Commissioner James R. Curtiss EDO Victor Stello, Jr.

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