NRC-89-0266, Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Development & Implementation of Goals & Objectives Program Will Divert Resources from Identified Equipment/Hardware Deficiencies

Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Development & Implementation of Goals & Objectives Program Will Divert Resources from Identified Equipment/Hardware Deficiencies

ML19353B211
Person / Time
Site:	Fermi
Issue date:	11/30/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
CON-NRC-89-0266, CON-NRC-89-266, FRN-54FR33983, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-DG1001, TASK-RE 54FR33983-00015, 54FR33983-15, NUDOCS 8912130332
Download: ML19353B211 (5)

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g Novenber 30, 1989 NIC-89-0266 l

Regulatory Publications Branch Division of Freedom of Information and Publications Services f[

Office of Mministration U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ((M33f83 i 4lO/Ef

References:

1) Fermi 2 NIC Docket No. 50-341 NIC License No. l@F-43

2) NIC Draft Regulatory Guide DG-1001, "Mainten,me Programs for Eclear '

Power Plants," dated August 1,1989

3) Proposed Rule, "Ebsuring the Effectiveness of  !

Maintenance Programs for Nuclear Power Plants" l (Federal Register, Vol. 53, No. 228, dated Monday, L . November 28, 1988) ,

Subject:

Detroit Edis7n's Review and Response to Draft Regulatory i l< Guide DG-1001, " Maintenance Programs for Nuclear Pobel Plants"

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l' Detroit Edison believes that a si.rong maintenance program is essential  !

to the safe and reliable operation of any nuclear facility. Fermi 2  !

l 1s continuany striving for excellence and feels that the maintenance '

programs in place, together with activiti2s in progress to stengthen  !

the programs, confirm this eminitment (as evidenced by our recent I successful, continuous operational run of 169 days) . Personnel of the Fermi 2 facility have reviewed Draft Regulatory Guide DG-1001,

" Maintenance Programs for Nuclear Power Plants" (Reference 2), and are  ;

submitting the following comments for consideration. j

1) The draft regulatory guide uses many adjectives anS adverbs to describe the characteristics of the maintenance program requirements. This subjective teminology should be removed to prevent incc sistent interpretation throughout the industry.

2) Many program elements addressed in the draft guide are alrea3y included in other regulatory requirerents (e.g., training, corrective action programs under 10 CFR 50, Apperdix B, procedure control, surveillance and operating experiences). This duplication should be eliminated.

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3) . Development and inplenentations of the goals' and objectives -

program specified by the draft guide will divert resources from

-identified equipment / hardware deficiencies. Dira:t action l

. focused upon plant equipment / hardware is a more suitable approach to inproving the naterial condition of- a facility. "

4)  : Portions of the regulatory guide address management structure.

'Ihis-is not an zppropriate. topic for regulation.

5) . The draft guide proposes to use performance indicators as a primary tool for neasuring the adequacy of maintenance program-inplementation. These indicators have no proven correlation to ' ,

achieving or maintaining a reliable level of safety. ).

In addition to the general conments discussed above, text specific d comments addressing draft regulatory guide DG-1001 are presented in. 1 the body of this letter below.

Page 2, Section B, Discussion, secord paragrzph, third- and fourth lines: .

1 The word "pronptly", and the phrase "all parts of the plant that could significantly inpact safe operation and security" require clearer definition'.

Page 3, Section 1, Summary of an Effective Maintenance Program:

If. the assumed regulatory position is sc.ind, maintenance programs that apply sound preventive and predictive maintenance will by oefinition minimize corrective maintenance. Statenents regarding minimization of

. corrective .naintenance as a program element are too vague and indefinite for consistent interpretation.

Page 4, Scotion 1.1, Establish Overall Policy, Goals, and Objectives, last sentence:

When discussing quantitative goals, are these goals expectoS to be individual for each structure, system, etc.? The benefits of such an approach are indeterminate and the effort to establish the program will divert resources from actual problems.

Page 4, Section 1.2, Conduct of Maintenance, fifth line:

The Gaality Assurance Program for safety related equipnent should not be diluted by application to Balarc'. of Plant (BOP) natcrials; possibly some form of peer inspection would be more desirable. When B@ functions are concerned, the quality assurance functions could/should come from within the naintenance organization.

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Page 5,. Section 1.3, Monitor and Assess Effectiveness and Perfornance, first line What is neant by "other quantitative neans"? Are QA aidits and

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E surveillance activities considered qualitative only? - The statenents C ;on: these topics are vague, nubject to varied opinion and not anenable >

to conristent regulation.

Page 5, Section 1.4, .Obtain Feedback on the Program and Take Corrective Actions, first sentence:

The phras_et" effectiveness of the program is not consistent with the established goals and objectives or if the other quantitative and qualitative". shou]r3 be stricken, Page 5, Section 2, overall Maintenance Policy, seventh line Replace " written standards" with procedures.

Page 6, Section 3.2, Goals, second paragraph, last line Fermi 2 supports the concept that extensive goals at the conponent level are not useful.

Page 7, Section 3.2, Goals, last paragr@h How are goals alone going to help ensure that equipment has been maintained? Will monitoring the equipment upon return to service help achieve the goal? Direct focus on equipnent performance is nore consistent with achieving safe reliable operation.

Page 7, Section 3.2, Goals, last paragraph:-

This paragr@h appears uronsistent with the previously stated concept

- that extensive goal.a at the conponent level are not expected.

Page 8, Section 4.1.1, Maintenance Management and Organization:

Fermi 2 agrees with the ccncepts presented in this section; however, the L;anagement structure is not an appropriate regulatory tcpic.

Page 8, Sect.lon 4.2, Maintenance Personnel Qualification and Training, second : sentence:

>> The guidelines of the Institute of Nuclear Power Operations Training Accreditation Program should be utilized for the qualification of licensee _ personnel. However, it may be more appropriate to require

- contractor personnel to take task specific training as they will be .

supervised by licensee personnel.

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NIC-89-0266 Page 4 4

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. Page .9, Section 4.2, Maintenance Personnel Qualification and Training, second line:.

To " perform maintenance activities" should be clarified to reflect that individuals could be qualified in specific activities (i.e., task l qualifications) as opposed to the generic term " fully qualified". 7 Page 9, Section 4.3.2, Control of Vendors and Contracted Maintenance l Services, second lines '  ;

The word " plant" shouM be replaced by "ntility".

Page 10, Section 4.3.3, Control of Radiological Exposure:

This section should be deleted. As-Low-As-Reasonably-Achievable (ALAPA) program already address these concerns.

Page 10, Section '4.3.4, Quality Assurance and Quality Control of '

Maintenance Activities: "

Maintenance Management can perform sone of the referencal QA/0C activities mentioned in this section, especially on BCP systems. Peer inspections and surveillar.de activities are smetimes preferred methods over QA/0C activities.

Page 11, Stetion 4.3.6, Centrol of Ca'ibration atd Test Equipment, first senter.;e:

The word "pror ;r' s ald bo deleted.

Page ll, Sect: .n 1.4, Maintenance Procedures, final sentence:

It is not necessary to document the location of procedures.

Subjective requirements such as systematic guidance and sound principles should be eliminated.

Page 13,- Section 4.6.4, Maintenance Surveillance:

This section seems to be the same as a performance evaluation program, which would include vibration analysis, thermoscope, lube analysis, etc. It is not clear what is meant by maintenance surveillance.

Detroit Edison, as a mcmber of the Naclear Management and Resources Council (NtNA}C), has reviewed the NLMAIC Draft Industry Response to the NIC Draft Regulatory Guide DG-1001, " Maintenance Progratrs for

- Nuclear Power Plants" letter dated November 22, 1989, and would encourage a careful and thorough review of the generic commnts presented to the Commission.

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Noventer 30,' 1989 >

~ NIC-89-0266 Page 5 If you have any questions regarding these comnents or this subject, please contact Mr. Arnold Jaufmann on (313) 586-421.1

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i Sincerely,

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cc: A. B. Daviu R. W. Defayette W. G. Rogers W. Smith (NLNAIC)-

J. F. Stang 1

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