View source for 3F0289-18, Comment on Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants.Industry Actions in Maint Area Effective W/Continuing Improvement Across Industry.Balance of Plant Equipment Inappropriate

{{Adams
| number = ML20235V571
| issue date = 02/28/1989
| title = Comment on Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants.Industry Actions in Maint Area Effective W/Continuing Improvement Across Industry.Balance of Plant Equipment Inappropriate
| author name = Widell R
| author affiliation = FLORIDA POWER CORP.
| addressee name = Chilk S
| addressee affiliation = NRC OFFICE OF THE SECRETARY (SECY)
| docket = 05000302
| license number = 
| contact person = 
| case reference number = FRN-53FR47822, RULE-PR-50
| document report number = 3F0289-18, 3F289-18, 53FR47822-00062, 53FR47822-62, NUDOCS 8903100236
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 2
}}

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Power C ORPO R ATION February 28, 1989 3F0289-18 Samuel J. Chilk U. S. Nuclear Regulatory Commission Washington, D.C. 20555

==Subject:==
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Proposed Rule on " Ensuring the Effectiveness of Maintenance Programs for Nuclear Power Plants"

==Dear Sir:==

Florida                   Power    Corporation            (FPC)      is   concerned with the                impact a maintenance rule will have on the industry and provides our general comments on the proposed rule.
Florida Power Corporation supports the concept of a comprehensive maintenance program including all aspects required to assure that correct maintenance takes place.                                    FPC is concerned that a rule would have a significant adverse impact on the industry and may not fully accomplish the stated objectives of the commission either from a technical                   or    resource       perspective.               FPC   considers            the   industry actions in the maintenance area have been effective and have resulted in continuing improvement across the industry over the last several years.                    Significant effort has been expended by FPC to improve our program and to optimize our equipment maintenance.                                                     Much of this effort could be wasted and we could lose much of the gain we have made if we are required to redirect resources to achieve compliance with a rule.                    Since the rule would be issued before a Regulatory Guide or Industry Guide for maintenance is developed and finalized, the impact of the rule can not be fully assessed.                                     However, any rule will require some degree rework.
FPC further does not consider including Balence of Plant equipment in the rulemaking appropriate.                                This will have significant impact on our resources as formalized requirements move into an area not previously under direct NRC regulation.                                  Since Balance of Plant is not defined,                      ;
significant resources may be directed at systems and equipment to assure compliance with regulations for no benefit.                                                                       l 8903100226 090228                                                                                   l PDR PR 50 53FR47822       PDR Of CVJ n  '
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POST OFFICE BOX 219
* CRYSTAL alVER, FLORIDA 32629 0219 . (t04) 563-2943 A Florida Progress Company

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February 28, 1989 3F0289-18 Page 2 1
FPC has a good maintenance program and we are continuously working to make   it better.      FPC considers                                the current industry efforts on maintenance including the initiatives.being undertaken by NUMARC and the on going INPO program are the most effective way to assure a rising standard of excellence in maintenance. The NRC already has the ability to effectively deal with poor maintenance at ' individual utilities. A rule would provide no additional capability for dealing with any plants that may have poor performance in maintenance but would have a significant negative impact on the majority of plants who have been working hard for years to improve maintenance.
Florida Power Corporation believes the NRC's objective is the same as the industry's; that is, obtaining effective maintenance to support safe and reliable plant operation.                                   Achievement of mutually desirable goals can best be served by working together to establish acceptable methods and measures for improving                                        maintenance,   including                           the development and/or enhancement of an                                      industry standard (s).                             FPC believes this can best be achieved without a maintenance rule.
In addition to these comments, FPC also supports and endorses Bishop, Cook, Purcell and Reynolds, Nuclear Utility Backfitting and Reform Group (NUBARG) and Nuclear Management and Resources Council (NUMARC) submittal on this' issue.
Sincerely, Rolf C. Widell, Director Nuclear Operations Site Support RCW/GMF/sdr xc:  Regional Administrator, Region II Senior Resident Inspector Walter Smith (NUMARC)
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