ML20247A297

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

ML20247A297
Person / Time
Site:	Peach Bottom, Limerick, 05000000
Issue date:	04/04/1989
From:	Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Zech L NRC COMMISSION (OCM)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00080, 53FR47822-80, NUDOCS 8905230105
Download: ML20247A297 (3)

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-PHILADELPHIA ELECTRIC COMPANY

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PHILADELPHIA Ac PA.19101

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"r (2 m s m 221 April'4F1989 "

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, Cx2cuTavs vics pass sosNT. NUCLE AR The BonorablelLando_W.~Zech, Jr.

Chairman

,k U.S. Nuclear Regulatory Commission M

Washington,~D.C.

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Dear. Chairman Zech:

In. view of-the continued.high. level of interest in the proposedtrulemaking for nuclear plant maintenance, I feel it is appropriate.to emphasize our. commitment to improved maintenance andTto pass.along to you some of.our recent initiatives and our

'long-term maintenance-improvement strategy.

-We'have' reorganized our station maintenance. forces to

. reduce the layers of management between the first-line-worker and.

the! site vice president"from 7 to 4.

We feel this will give us

.significantly improved management control and improved communications with respect'to maintenance field activities.

One of the key' strategies of the Nuclear Group's commitment to excellence is'a 3 to 5 year detailed plan for maintenance improvement..This plan has been divided into 9 key clements which we feel are the; root cause solutions to existing maintenance deficiencies.

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We are defining the role of our centralized maintenance forces and maintenance contractors such that during non-outage periods, we will have a work force that contains essentially no contractors, 90%

station maintenance personnel, and 10% central maintenance personnel.

During outage periods, we will use all available central maintenance resources with specialty technical services provided by vendors.

We anticipate using no contractors for supplemental maintenance purposes.

o We have initiated a task force to streamline the i

permit and blocking system such that a minimum number of' safety tags are applied while at the same time the level of safety is maintained or improved.

We will Ilf O also. develop a visual method to provide an overview of what is safety blocked on a system-by-system basis.

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PDR PR 50 53FR47822.

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We.are developing a~ simplified and more effective if

. maintenance work flow control system.

This improved work-process system will'have minimal and. efficient-Linterface. stages to improve coordination between all the groups involved.with field maintenance activities.

A portion of this task is devoted to the development of, acceptance of and training in the new system by all involved. personnel.

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We are developing an~ organized and efficient warehousing.systemLof qualified components and parts which have ?xan evaluated to be prudent to stock.

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- are also de m toping the dynamic capability to obtain items which are no longer stocked or are no longer available from the original manufacturer.

o We;will continually increase and improve the job

. planning activity until work package planning is an Y

' integral part of the maintenance function.

We will schedule andrintegrate work packages and generate a resource loaded schedule for all groups.

This will allow maintenance to be performed int a well-planned, predictable, and timely manner.

o We are developing work standard and productivity tools to be used for the planning of maintenance activities

- and the prediction of work content and' manpower I

' requirements.

o One of our-major thrusts is the development of the genaral mechanic concept.. We feel that a general V

mechanic can~ perform approximately 80% of the maintenance tasks normally.found at a nuclear plant.

By.using a composite-type crew, we can eliminate numerous interfaces between specific trades.

We also expect to develop maintenance radiation workers with less. dependence on specialized health ~ physics h

technicians for normal maintenance functions.

By doing this, we will clearly improve efficiency, enhance the team concept, and develop a stronger sense of ownership on the part of maintenance personnel.

o We are moving forcefully towards a reliability based preventive maintenance program.

Such a program will include equipment history, NPRDS input, corrective maintenance feedback, vendor recommendations, probabilistic risks assessment guidelines, industry

,3 experience, and predictive maintenance techniques.

We have already implemented the use of predictive maintenance techniques with respect to vibration analysis and the balancing of rotating equipment.

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April"4, 1989

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- o We will continue the development of qualified' crafts-fand supervisors using the Institute of Nuclear Power L perations accredited training programs.

In addition, O

we-will, select maintenance first-line supervision based.on their qualifications for supervision and not just their seniority and craft skill qualifications.

We will, train these men in supervisory techniques before they are assigned to line foreman positions.

For each of the 9 strategy elements listed above, we have appointed a task force.

Implementation of the task force output.will.be a line function.

I have provided this brief outline of'our maintenance otrategy to highlight the point that a strong maintenance program is clearly in our own best 1nterest.

As recent events have

~

clearly proven, the health and safety of the general public and the financial well.being of the Philadelphia Electric Company are clearly inter-related.

We have undertaken this effort despite recent NRC maintenance program" inspections at both Limerick and Peach Bottom which have concluded that the Philadelphia Electric Company is implementing an effective maintenance program.

If I can provide any more information relative to our maintenance strategy,-please do not hesitate to contact me.

Sincerely, T

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cc:. K. M. Carr, Commissioner, USNRC J. R. Curtis, Commissioner, USNRC

'T. M. Roberts, Commissioner, USNRC L

LK. Rogers, Commissioner, USNRC Byron Lee, Jr., NUMARC lr l

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