View source for L-98-306, Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP

{{Adams
| number = ML20198J419
| issue date = 12/10/1998
| title = Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP
| author name = Kundalkar R
| author affiliation = FLORIDA POWER &amp; LIGHT CO.
| addressee name = Hoyle J
| addressee affiliation = NRC OFFICE OF THE SECRETARY (SECY)
| docket = 05000250, 05000251, 05000335, 05000389
| license number = 
| contact person = 
| case reference number = FRN-63FR52201, RULE-PR-50
| document report number = 63FR52201-00024, 63FR52201-24, L-98-306, NUDOCS 9812300179
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 1
}}

=Text=
{{#Wiki_filter:O P.O. Box 14000. Juno Beach. FL 33408-0420 ffdCg: '5 i
FPL                                                                   DEC 101998 John C. Iloyle                                                                   Y-98-306 Secretary of the Commission U.S. Nuclear Regulatory Commission                      C.
Washington, DC 20555                                    g~                           ,-
Attn: Rulemakings and Adjudications Staff Re:      Florida Power & Light Company Comments Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants
                                                                          '                 E (63 Fed. Reg. 52201 (Sept. 30,1998))                                                     l03#88'DO/)

==Dear Mr. Iloyle:==

Florida Power & Light Company (FPL), the licensed operator of the St. Lucie Nuclea Plant, Units 1 and 2, and the Turkey Point Nuclear Plant, Units 3 and 4, hereby submits the following comments on the above-referenced notice of proposed rulemaking. FPL also endorses the comments of the Nuclear Energy Institute on the proposed rulemaking.
While FPL supports the concept of the proposed rulemaking, which attempts to address the importance of plant configuration control during power operations and during normal shutdown operations, FPL has significant concerns with the rule as proposed. In short, FPL is concerned that the rule would add terminology in the maintenance rule that is subjective, leading to significant difficulties in implementation. Further, FPL does not agree that the rule should apply the requirement to assess out of service equipment to all structures, systems, and components covered by the maintenance rule, including those of no or low risk significance.
In this regard, FPL endorses NEI's recommendation that NRC withdraw and renotice the proposed rule with changes to risk-inform the scope of the maintenance rule.
Should NFC decline to withdraw and renotice the propased rule, FPL recommends that NRC incorporate in a final rule the changes and clarifications suggested in the NEI comments on the proposed rulemaking. Most importantly, the terminology used in the rule should be carefully defined to promote c'arity in implementation.
We appreciate the opportunity to comment on this important issue.
Sincerely yours,
         '\v         -
l Rajiv S. Kundalkar                                                                                        l Vice President                     9812300179 98121 Nuclear Engineering                                                                                         0
                                      @R cc: Anthony Pietrangelo, Nuclear Energy Institute an FPt Group compas.y ffh}}