View source for 3F1298-06, Comment Supporting Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Expresses Concern Re Absence of Definition of risk-significant Configurations & Unacceptable Level for Safety Function Degradation

{{Adams
| number = ML20198A149
| issue date = 12/09/1998
| title = Comment Supporting Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Expresses Concern Re Absence of Definition of risk-significant Configurations & Unacceptable Level for Safety Function Degradation
| author name = Bernhoft S
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF THE SECRETARY (SECY)
| docket = 05000302
| license number = 
| contact person = 
| case reference number = FRN-63FR52201, RULE-PR-50
| document report number = 3F1298-06, 3F1298-6, 63FR52201-00002, 63FR52201-2, NUDOCS 9812160164
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 1
}}

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l   The Secretary of the Commission Attention: Rulemaking and Adjudication Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

==Subject:==
Comments on Proposed Rule Changes, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants; Vol. 63, No. 189, Federal Register 52201, dated September 30,1998

==Dear Secretary:==

This letter provides Florida Power Corporation's (FPC) comments on the above-referenced Proposed Rule change. FPC welcomes the NRC's initiative to enhance the Maintenance Rule.
FPC believes the two main areas being enhanced by the subject Proposed Rule change will ensure the Maintenance Rule is applied in all modes of plant operation including plant shutdown, and safety / risk assessments are performed when removing equipment from service for plamled maintenance activities.
An area of concern for FPC is the absence of a definition of " risk-significant configurations" and
   " unacceptable level" for safen function performance degradation. Item 5 under Proposed Rule states, "...the objective of performing safety assessments is to ensure the plant is not placed in risk-significant configurations or configurations that would degrade the performance of safety functions to an unacceptable level." Without uniform definitions, safety assessment decisions for what is acceptable may be subject to future enforcement action due to varying opinions in these issues. Therefore, FPC reconunends definitions for these issues be incorporated into Regulatory Guide 1.160, Revision 3, concurrent with the development of the Proposed Rule change. Guidance would then be available to assist with rule implementation.
FPC appreciates the opportunity to comment on this important NRC Proposed Rule. We would be happy to meet with you or your staff to discuss these comments further.
Sincerely, I
M    M nh t Sherry L. Bernh t b
l Director, Nuclear Regulatory Affairs                                                                         f I                      9812160164 981209 SLB/tak             PDR     PR 50 63FR52201            PDR xc:     Document Control Desk        AO"U            '
CRYSTAL RIVER ENERGY COMPLEX: 15760 W. Power Line Street
* Crystal RJver, Florida 34428-6708 * (352)795-6488 A Florlds Progress Company h}}