RBG-30156, Comment on Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants.New Rules Will Divert Resources & Attention from on-going Improvements Resulting from Existing 10CFR50.65(b)(1)-(16) Initiatives

Comment on Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants.New Rules Will Divert Resources & Attention from on-going Improvements Resulting from Existing 10CFR50.65(b)(1)-(16) Initiatives

ML20235T305
Person / Time
Site:	River Bend
Issue date:	02/23/1989
From:	Booker J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 53FR47822-00021, 53FR47822-21, RBG-30156, NUDOCS 8903080235
Download: ML20235T305 (2)

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> ~,v February 23, 1989 RBG - 30156 File Code G9.23 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555-Gentlemen:

Gulf States Utilities Company (GSU) is pleased to comment on the Commission's proposed rule (53FR47822, dated November ~ 28, 1988)

" Ensuring the Effectiveness of Maintenance Programs for Nuclear Power Plants." GSU is concerned about the following aspects of this proposed rule:.

1) The . changes to Part 50, paragraph 50.65 intend to set a Maintenance standard vhich all plants can be measured against. Specifically, subparagraphs 50.65(b)(1) through 50.65(b)(16) identify seventeen-characteristics for an acceptable maintenance program. Each of these characteristics is already incorporated into River Bend's maintenance program and into the programs of many other plants.

Each- of the characteristics is also incorporated into the INPO programs. By way of industry initiatives being pursued through INPO, EPRI, owner's groups and other industry organizations, these characteristics are already being incorporated into the programs at tite remaining plants. There is data indicating that' existing initiatives are improving maintenance practices, but sufficient time has not been allowed for these initiatives to achieve their full benefit. Overlaying these initiatives with new rules will divert resources and attention from on-going improvements.

2) Part 50, paragraph 50.65, subparagraph 50.65(b) states that the Commission intends the scope of the rule to cover all systems, structures and components, including those in the balance-of-plant.

This addition of scope is unnecessary and will cost GSU and the-utility . industry more time, money, and create unessential record keeping with no increase in the safety of the public.

3) The NRC backfit analysis assumes no net cost to utilities on the basis of increased plant availability and capacity factor offsetting the costs of implementing the maintenance rule. The NRC states the implementation of this program will actually produce a cost savings based on each plant improving it's availability by 5% over it's current value. This could not be a realistic assumption for River Bend because of our already high availability and capacity factor.

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l GSU's equivalent availability for 1988 was 90.1% (GSU's 1988 goal was 85%) and GSU's net capacity factor for 1988 was 88.2% i (GSU's 1988 goal was 80%). Therefore, we believe this proposed rule if implemented by the Commission would cost us a great deal of money without necessarily achieving improvements in safety or reliability.

The NRC backfit analysis assumes that no availability and capacity factor increases would be achieved without the rule. . Historically, increases have been achieved with a few exceptions. Thus a cost analysis that allows for these improvements and that allows for {

continued favorable impact of existing industry initiatives is needed to provide a true picture of the maintenance rule costs.

Furthermore,- in cases where poor capacity factor and availability have been accompanied by poor regulatory performance, existing rules have been. effective in allowing the Commission to precipitate change.

GSU appreciates the opportunity to comment on this proposed rule.

Sincerely, i <

J. E. Booker Manager-River Bend Oversight River Bend Nuclear Group Em JEB/LLD/EKH/1p 4

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