ML20245J019

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

ML20245J019
Person / Time
Site:	Dresden, Byron, LaSalle, 05000000
Issue date:	04/14/1989
From:	Reed C COMMONWEALTH EDISON CO.
To:	Zech L NRC COMMISSION (OCM)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00084, 53FR47822-84, NUDOCS 8905030613
Download: ML20245J019 (3)

Text

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/- , Commonacith Edison-

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3 Address Reply to: Post Omco Box 767 6 -

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DOCKET NUMBER'an - April H, IM9 PROPOSED RULE rn

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y Honorable Lando W. Zech, Jr.

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United States Nuclear Regulatory Commission '[68/

Washington, DC' 20555 Vff

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SUBJECT:

Maintenance Initiatives at Commonwealth Edison I

l Dear Chairman Zecht I would like to convey to you my personal assurances that maintenance l

is of the utmost importance at Commonwealth Edison. We are committed to the l goal of achieving improved reliability and safety and we firmly believe that maintenance has an important role to play in meeting chis goal. Since 1983, Commonwealth Edison has undertaken a number of initiatives to improve the manner in which maintenance is performed. I would like to.take this opportunity to share our progress.

Prior to 1983, we did not have a formal documented company-wide program. Each station was held responsible for its own maintenance and was judged by the results of its effectiveness. . Problems that occurred were dealt with on an exception basis and significant. lessons were shared between stations. In 1983, a formal Conduct of Maintenance Directive was issued to provide consistency and identifv programmatic requirements. This directive was based on guidelines provide by INPO that ultimately resulted in the issuance of INPO 85-038, " Guidelines for the Conduct of Maintenance at Nuclear Power Plants".

In late 1986, we experienced equipment failures that seemed to be related to improperly performed maintenance. We-began to assess existing -

practices at our stations; our task force included several consultants with broad exposure to industry maintenance programs to provide an external perspective. We determined that improvements were needed in the areas of procedures, work pachage guidelines, and planning & scheduling.- In addition, it appeared that the station maintenance organizations were inconsistently developed and staffed.

8905030613 890414 PDR PR 7 50 53FR47822 PDR _

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L. Zech Apr12 14, 1989 l 4

In early 1987, we started conducting self assessments at each of our six nuclear stations in accordance with the INPO sponsored industry-wide self assessment initiatives. A multi-disciplined team approach was utilized i including representatives from the corporate maintenance staff and training department, as well as peer evaluators within the company. Although they noted progress on many of the concerns determined by the earlier task forca, their conclusion was that additional actions were necessary to bring both station 85-038. and corporate programs up to the level of excellence typified by INPO i The self assessments were completed in November 1987, and a new l

corporate Conduct of Maintenance Directive was developed and issued on March 31, 1988.

Both Commonwealth Edison and the industry have made significant strides in maintenance over the last several years as demonstrated by statistics on the automatic scrams, unplanned safety system actuations, licensee event reports, and significant events. Equivalent availability,  ;

capacity trends. factor, and forced outage rates all show equally matching improvement These gains are the result of the sincere commitment the industry has made to reliability and safety, and to the improvement of maintenance.

Additional improvements, such as embodied in our Conduct of Maintenance, do not come easily nor quickly. We believe that the program we identified and have begun will require at least three years to implement and several more years of monitoring before we are confident that we have hit the mark.

However, we are making great progress. When we are done, we will have committed over $40 million in program, development, implementation, and staffing. l

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i As I review the progress across our stations, I see improvements in many aspects of the maintenance programs. The staffing levels of the maintenance departments have increased this year with an increase in work analysts from just two or three analysts in some cases to the desired number of fif teen work analysts at Dresden, LaSalle, and Byron. The other stations have increased their numbers and will reach fif teen this year or in 1990.

All six stations are presently in various stages of implementing a program equipment to failures.

analyze maintenance problems to determine the root cause of By utilizing the work history records and correctly identifying will be enhanced.the root cause of failure, equipment performance and availability I must also mention that Dresden is leading our older stations in a computerized technique. preventive maintenance program utilizing a time series analysis piece of equipment in the top fif teen priority systems.This It uses a unique program col approach for failure event patterns and statistical methods to obtain a broad scope of analysis for preventive maintenance schedules. As this program progresses, other stations will be using this concept.

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. 1 L. Zech Apr11'14, 1989 A few of the other improvements include the development and utilization of company-wide standard modification installation procedures improved work package content, assessment of utilization of existing machinery  ;

history programs and improvement for use in work package preparatica and  !

planning. All of our plants are in the process of implementing these improvements. The direction is established toward implementation of a consistent company-wide approach that still leaves room for individual station innovation.

In conclusion, I be13 eve that our station maintenance has significantly improved over the past several years. We believe that our )

l program is proactive and will continue to reinforce itself through a living j Conduct of Maintenance Directive.. I appreciate this opportunity to give you _

j an understanding of our commitment, and welcome the' opportunity to discuss j this further if you desire.

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i Sincerely,

("me. .

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Cordell Reed Senior Vice-President RC sci 0080T 1-3 cci Commissioner K.M. Carr Commissioner T.M. Roberts Commissioner K.C. Rogers Commissioner J. Curtis  ;

Mr. Victor Stello, EDO Mr. Byron Lee, NUMARC

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