Comment Supporting Opinions Expressed by NUMARC on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Supports Philosophy of Proper Maint as Important Part of Safe & Reliable Nuclear Power Plant OperationML19353B200 |
Person / Time |
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Site: |
Arkansas Nuclear |
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Issue date: |
12/04/1989 |
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From: |
Tison Campbell ARKANSAS POWER & LIGHT CO. |
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To: |
Chilk S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF THE SECRETARY (SECY) |
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References |
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FRN-54FR33983, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-DG1001, TASK-RE 0CAN128903, 54FR33983-00023, 54FR33983-23, CAN128903, NUDOCS 8912130182 |
Download: ML19353B200 (6) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212L0841999-10-0101 October 1999 Exemption from 10CFR50,App R,Section III.G.2 to Ensure That Adequate Fire Protection Features Provided for Redundant Cables or Equipment Located in Same Fire Area Outside of Primary Containment ML20141D7351997-06-19019 June 1997 Comment Supporting Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Reactor Operating W/Framatome Cogema Fuels Mark-B Fuel Requested to Be Excluded from Final Bulletin Suppl DD-97-15, Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request1997-06-18018 June 1997 Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request 0CAN049709, Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants1997-04-21021 April 1997 Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants ML20136E7591997-03-0707 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20128M3411996-09-30030 September 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements ML20099M4921995-12-18018 December 1995 Comment on Draft Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses 0CAN119504, Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI1995-11-13013 November 1995 Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20086N6551995-07-14014 July 1995 Comment on Proposed Generic Ltr Re 10CFR50.54 Process for Changes to Security Plans W/O Prior NRC Approval. Agrees W/ Proposed Clarification of Language & W/Provided Screening Criteria in Notice ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20058D8581993-11-26026 November 1993 Comment on Proposed Rule 10CFR72 Re Notification of Events at Isfsi.Believes General Licenses Should Not Be Required to Use New 10CFR72.75 ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 0CAN059206, Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety1992-05-28028 May 1992 Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML20006C5721990-01-15015 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. ML19353B2001989-12-0404 December 1989 Comment Supporting Opinions Expressed by NUMARC on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Supports Philosophy of Proper Maint as Important Part of Safe & Reliable Nuclear Power Plant Operation ML20247N1311989-07-0707 July 1989 Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Existing Regulations,Codes & Stds Including Industry Procurement Improvement Activities Are Adequate ML20235T4141989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20206M6171988-11-17017 November 1988 Comment Supporting Proposed Rule 10CFR26 Re NRC Rulemaking on Fitness for Duty Programs.Endorses NUMARC 881118 Comments on Subj Proposed Rule & Suggests Incorporation of NUMARC Suggested Changes ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group 0CAN088804, Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress1988-08-0404 August 1988 Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress ML20149E8581988-02-0404 February 1988 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Licensee Response to Notice of Violation & Proposed Imposition of Civil Penalty by ML20236A0441987-10-13013 October 1987 Comment Opposing Proposed Rule 10CFR50 Re Rev to Backfitting Process for Power Reactors.Proposed Rule Devoid of Objective Guidance or Criteria for Distinguishing Between Cases Where cost-benefit Analysis Permissible & Where Not ML20215D6741987-06-12012 June 1987 Suppl 4 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.Ucs Reply to Responses from NRC & B&W Owners Group.* Certificate of Svc Encl ML20214Q6151987-06-0101 June 1987 Order Imposing Civil Monetary Penalty in Amount of $50,000 for Violation Noted in Insp on 860106-31.Evaluations & Conclusions Encl ML20210C4191987-04-0606 April 1987 Principal Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Petition Should Be Denied ML20205F2911987-03-23023 March 1987 Suppl 3 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Requests That Listed Names Be Added to List in Paragraph 1 of 870210 Petition ML20210C2691987-03-0606 March 1987 Initial Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Request for Immediate Suspension Should Be Summarily Denied.W/Certificate of Svc ML20211F5091987-02-20020 February 1987 Suppl 2 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Lists Names to Be Added to 870210 Petition & Corrects Address for Save Our State from Radwaste ML20210N4861987-02-10010 February 1987 Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W Co.* OLs & CPs for Facilities Should Be Suspended Until Listed NRC Actions Taken ML20203A1491986-03-10010 March 1986 Affidavit of Jh Taylor Demonstrating That Encls May Be Withheld Per 10CFR2.790 & Listing B&W Procedures for Withholding ML20137L5911985-09-10010 September 1985 Response Opposing Jf Doherty 850611 Petition for Show Cause Order Requesting NRC to Institute Consolidated Proceeding Per 10CFR2.202.Certificate of Svc Encl ML20126A3531985-06-11011 June 1985 Petition/Request for Order to Show Cause Why Plants Should Not Be Shut Down Until CRD Mechanisms Inspected ML19343B1761980-11-13013 November 1980 Affidavit Supporting Proprietary Treatment for CEN-139(A)-P, Statistical Combination of Uncertainties.. ML20126M2581980-03-14014 March 1980 Affidavit for Withholding Proprietary Info Re Low Pressure Turbine Rotor (Ref 10CFR2.790).Nonproprietary Version Attached ML19326C6621978-09-28028 September 1978 Forwards Executed Amend 7 to Idemnity Agreement B-65, Including New Article Viii ML19326C6511978-08-0707 August 1978 Executed Amend 6 to Indemnity Agreement B-65,changing License Numbers ML19326C6531975-03-27027 March 1975 Executed Amend 3 to Indemnity Agreement B-65,increasing Liability Premiums ML19317H1351974-05-0303 May 1974 Acknowledgement of Svc of Amend 45 to Application for OL ML19326B8481973-08-10010 August 1973 Acknowledges Svc of Amend 40 to OL Application on 730810 1999-10-01
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20141D7351997-06-19019 June 1997 Comment Supporting Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Reactor Operating W/Framatome Cogema Fuels Mark-B Fuel Requested to Be Excluded from Final Bulletin Suppl 0CAN049709, Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants1997-04-21021 April 1997 Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants ML20136E7591997-03-0707 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20128M3411996-09-30030 September 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements ML20099M4921995-12-18018 December 1995 Comment on Draft Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses 0CAN119504, Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI1995-11-13013 November 1995 Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20086N6551995-07-14014 July 1995 Comment on Proposed Generic Ltr Re 10CFR50.54 Process for Changes to Security Plans W/O Prior NRC Approval. Agrees W/ Proposed Clarification of Language & W/Provided Screening Criteria in Notice ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20058D8581993-11-26026 November 1993 Comment on Proposed Rule 10CFR72 Re Notification of Events at Isfsi.Believes General Licenses Should Not Be Required to Use New 10CFR72.75 ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 0CAN059206, Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety1992-05-28028 May 1992 Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML20006C5721990-01-15015 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. ML19353B2001989-12-0404 December 1989 Comment Supporting Opinions Expressed by NUMARC on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Supports Philosophy of Proper Maint as Important Part of Safe & Reliable Nuclear Power Plant Operation ML20247N1311989-07-0707 July 1989 Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Existing Regulations,Codes & Stds Including Industry Procurement Improvement Activities Are Adequate ML20235T4141989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20206M6171988-11-17017 November 1988 Comment Supporting Proposed Rule 10CFR26 Re NRC Rulemaking on Fitness for Duty Programs.Endorses NUMARC 881118 Comments on Subj Proposed Rule & Suggests Incorporation of NUMARC Suggested Changes ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group 0CAN088804, Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress1988-08-0404 August 1988 Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress ML20236A0441987-10-13013 October 1987 Comment Opposing Proposed Rule 10CFR50 Re Rev to Backfitting Process for Power Reactors.Proposed Rule Devoid of Objective Guidance or Criteria for Distinguishing Between Cases Where cost-benefit Analysis Permissible & Where Not 1997-06-19
[Table view] |
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December 4, 1989 i
SCAN 128953 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station P1 137 h3 Washington, D.C. 20555 ATTN: Mr. Samuel J. Chilk 54PO3W3 '
Secretary of the Commission g
Subject:
Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Draft Regulatory Guide DG-1001, Maintenance Programs for Nuclear Power Plants Gentlemen:
On August 1,1989, the Nuc1 car Regulatory Comission requested csmments on the Draft Regulatory Guide DG-1001, Maintenance Programs for Nuclear Power Plants. This letter transmits Arkansas Power & Light s (AP&L) comments on the proposed regulatory guide. AP&L supports the opinions expressed by the Nuclear Management and Resources Council Inc. (NUMARC) on this proposed regulatory guide.
AP&L supports.the philosophy of proper maintenance as an inportant part of safe and reliable nuclear power plant operation. AP&L has taken steps to upgrade maintenance personnel perfomance by constructing a new, well equipped Maintenanco Facility, expanding and improving mt.intenance training, emphasizing good work 3racticos, rewriting maintenance procedures to a standardized guide wit 1 emphasis on human factors, and upgrading our vendor technical manuals .
To continue the trend of improvements of maintenance activities at ANO, AP&L is partici1ating in consolidated utility activities associated with EPRI, INPO, NUMARC, NSSS Owners Groups, and Codes and Standards Developing Organizations. These groups are addressing improvements in the areas of scif assessment, performance monitoring,1cng-range goals, training, equipment reliability, root cause enelysis, and preventive / predictive maintenance. Having reviewed the draft regulatory guide in detail and considering the industry and NRC activities in the area of maintenance, AP&L believes that the intent of the regulatory guide can be met by other means.
1 8912130182 891204 An Entegy company PDR REQQD 01.XXX C PDR b
cc 05 'h9 09:33 Gr%L TCDY-19 bTI r<OcK _ _ P.3 .
e-7 U. S. NRC .
Page 2 December 4,~1989 .
i, AP&L provides the following responses to the specific questions posed by the l NRC:-
f: Question.I' What' level of detail should be included in the regulatory guide?
Respnnse In general the content of the draft regulatory uide is written at an appropriate level of detail. This allows the f exibility for the utility to have procedures to define its specific maintenance program.
Some improvements, however, are recommended. The addition of examples and/or additional information to describe the intent would ensure consistency of interpretation. In previous regulatory guides the E technique of providing questions with their responses as part of the
-regulatory guide helped to ensure a consistent interpretation.
-Further, the use of vague terms such as " effective" has the potential for subjective interpretation. Defining or eliminating such terms would be appropriate. Another alternative would be qualify terms with "as determined by utility management assessment.,ing This the would indicate that the element is to be interpreted by the individual ,
!- utility. l Question 2 Is the scope of systems, structures, and components covered by the !
- regulatory guide appropriate? j Resp _o_nse The scope of including all systems, structures, and components, as reflected in the policy statement, is too broad. Use of the '
methodology being developed by the utility industry for the selection of equipment as a result of appropriate technical assessment is more appropriate. This would allow each utility to base its selection of equipment on plant specific experience and revisions to the list would be accomplished in a timely manner. Use of this methodology would '
further minimize interpretational differences between the NRC and the i utility. Currently AP&L maintains equipment appropriate to the >
equipment's importance to safety and the individual components' design.
The intent is to converge both the regulatory and industry emphasis on a specific set of important equipment, i
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DCC 05 '89 09:33 APLL TCDY-19 LITTLE PCG P,4 ;
U. S. NRC Page 3 December 4, 1989 Question 3 What criteria could be used to determine that a maintenance program is fully effective and additional improvement is not essential from a '
safety standpoint?
Response
Multiple measures are needed to determine the effectiveness of naintenance performance. The regulatory processes and industry programs and controls, in the aggregate, when appropriately implemented, monitored, and adjusted on en on-going basis ensure safety. Long term experience with the NRC and INP0 evaluation processes indicates areas of needed improvenent are identified and rer,olved. Similarly, overall performance indicators presently in use by the NRC and industry facilitate short-term and long-term identification of adverse trends.
Question 4 Is it appropriate to use s,uantitative goals, which are described in Regulatory Position 3 of the draft regulatory guide, directed toward '
achieving a satisfactory level of performance in plant maintenance programs consistent with the level achieved by the top performing U.S. ,
plants of similar design?
I
Response
from a regulatory perspective, it is not appropriate to use quantitative goals to achieve a satisfactory level of performanco in plant maintenance. Use of goals and objectives established by the utility to address specific performance problems is appropriste. Use of this management tool would ensure that the plant operates in a safe and reliable manner. Distorting the focus of maintenance activities to meet specific regulatory guides could lead to incorrect decisions resulting in reduced availability and operating less safely than could be otherwise achieved. Striving for safe and reliable plant operation should be the basis for :naintenance activities. Comparison of equipment failures with the plant specific and industry experience would achieve a more realistic approach to maintenance activities. It is also appropriate for the utility to compare its performance with plants of similar design to provide areas for focus of maintenance activities. However, plant specific elements should provide precedence for focus of emphasis.
LCC 05 : '99 09: 34 ArtL TCBY-19 LITTLE ROCI: . P,5 ,t l .0 ,
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U. S. NRC .
Page 5 December 4, 1989 i, i'
cc: V. S, Nuclear Regulatory Comission Document Control Desk .i Mail Station P1-137- ,
L Washington, DC 20555 .
Mr. Robert Martin U. 5. Nuclear Regulatory Commission .
Region IV .:
i 611 Ryan Plaza Drive. Suite 1000 !
, Arlington, TX 76011 .
Mr. C, Craig Harbuck NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Coninission ;
NRR Mail Stoo 13-D-18 One White Flint North ;;
11555 Rockville Pike Rockville, Maryland 20852 ,
1 n
Mr. Chester Poslusny NRR Project Manager, Region IV/ANO-2 '-
1 U. S. Nuclear Regulatory Comission NRR Mail Stop 13 D-18 .
One White Flint North J 11555 Rockville Pike Rockville,' Maryland 20852 4
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. K C 05 '83 09835 AP&L TCBY-19 LITTLC Row _.
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i U. S. NRC Page 3 I December 4, 1989 Question 3
- What criteria could be used to determine that a maintenance program is fully effective and additional improvement is not essential from a safety standpointi Respons_e 'l Multiple measures are needed to determine the effectiveness of maintenance performance. The regulatory processes and industry ;
programs and controls, in the aggregate, when appropriately implemented, monitored, and adjusted on an on-going basis ensure safety. Long-term experience with the NRC and INPO evaluation ,
processes indicates areas of needed . improvement are identified and resolved. Similarly, overall performance indicators presently in use by the NRC and industry facilitate short-term and long-term identification of adverse trends.
Question'4 Is it appropriate to uso quantitative goals, which are described in C Regulatory Position 3 of the draft regulatory guide, directed-toward achieving.a satisfactory level of perfontance in plant maintenance programs consistent with the level achieved by the top performing U 3.
plants of similar design? L N
Respons_e From a regulatory perspective, it is not appropriate to use F quantitative goals to achieve a satisfactory level of performance in plant maintenance. Use of goals and objectives established by the utility to address specific performance problems is appropriate. Use of this management tool would ensure that the plant operates in a safe and reliable manner. -Distorting the focus of maintenance activities to meet specific regulatory guides could lead to incorrect decisions resulting in reduced availability and operating less safely than could be otherwise achieved. Striving for safe and reliable plant operation Comparison of should be the basis for maintenance activities.
equipment failures with the plant specific and industry experience would achieve a more realistic approach to maintenance activities. It is also appropriate for the utility to compare its performance with plants of similar design to provide areas for focus of maintenance activities. However, plant specific elements should provide precedence for focus of emphasis.
(pmn y , j)CC 05 '89 03i35 Mtl TCBY-19 LITTLE P07 P,7 7 (
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L U 5. NRC Page 4 December 4, 1989 Question 5 Wiat quantitative measures would be appropriate for such goals? Should they be at the plant level, system level, component level, or some combination thereof?
Respons_e The INPO performance indicator program t.stablishes overall performance indicators and 'cals. AP&L currently monitors msinyrnsnvr performance at a plant level as part of its goals and objectives program and feels this level of performance monitoring is appropriote. Octermination of ap>ropriate performance monitoring for the achievement of long-term and $1 ort-term objectives, consistent with the individual improvement '
needed, should be plant specific and determined by the utility.
i AP&L-appreciates the opportunity to provide comments on this draft regulatory guide. We consider a well planned maintenance program to be of ,d utmost importance in tL safe and reliable operation of Arkansas Nuclear One and will continue to work with utility groups and the NRC to achieve this goal, o
Very truly yours, r
A/s T. G. Cam- ell ij TGC/lw b
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