ML20127L878

Comment Supporting Comments Submitted by NUMARC Re Draft Reg Guide DG-1020

ML20127L878
Person / Time
Site:	Davis Besse
Issue date:	01/19/1993
From:	Shelton D CENTERIOR ENERGY, TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-57FR55286, RTR-REGGD-1.160, RTR-REGGD-XX.XXX, TASK-DG-1020, TASK-RE 2109, 57FR55286, NUDOCS 9301280035
Download: ML20127L878 (3)

Text

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! Donald C. Shelton 300 Madison Avenue i Vce President Nuclear Toledo, OH 43652Kl01 j Davis Besse (419)249-2300 l

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Docket Number 50-346 =g i.a License Number NPF-3 g Serial Number 2109 @ ,

January 19, 1993 2 I i.9

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Regulatory Publications Branch, DFIPS i Office of Administration i United States Nuclear Regulatory Commission Vashington, D.C. 20555 i

Subject:

Comments On Draft Regulatory Guide DG-1020, Monitoring The l

Effectiveness Of Haintenance At Nuclear Power Plants Gentlemen Toledo Edison, a subsidiary of Centerior Energy, is partial ovner of and is responsible for operation of the Davis-Besse Nuclear Power Station. Toledo Edison has been authorized for power operation of the Davis-Besse Nuclear Power Station since April 1977. . As a 10 CFR 50 licensee, Toledo Edison has a vested interest in any policies the NRC may adopt which can affeet the management and operation of a commercial nuclear power plant.

The purpose of this letter is to provide comments on Draft Regulatory-Guide DG-1020, entitled "Honitning the Effectiveness of Maintenance at Nuclear Power Plants." However, Toledo Edison vould like to preface these comments by reiterating our posit.on i that the Maintenance Rule, 10 CFR 50.65, and the backfit analysis performed in support of the Maintenance Rule are both flawed. Implementation of the Maintenance Rule vill place an unnecessary financial burden'on operating nuclear plants without resulting in a substantive improvement in safety.

9301280035 930119 PDR. REGGD.

XX.XXX C PDR' Operating Companies:

Cleveland Electnc murmnating .

Toledo Edison

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Docket Numb 2r 50-346

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• License Numbar NPF-3 4

Serial Numbar 2109 Page 2 NRC regulations should be limited to protecting the health and safety of the public. The Haintenance Rule is flaved in that:

1. Operating costs vill be increased.

2. No improvement in safety vill result from its impleme7tation; because of reallocation of resources, safety msy be diminished.

1 The nuclear industry has improved maintenance practices to the point where tL.e average frequency of scrams resulting from failure of safety-related structures, systems, and components (SSCs) is extremely lov. Enhanced monitoring of safety-related S$cr and nonsafety-related SSCs "whose failure could cause a reactor scram or actuation of a safety-related system" may increase operating reliability but vill not improve safety. Implementation of the Maintenance Rule vill cost money

that could be more effectively used to improve safety elsewhere if needed. Although failures of nonsafety-related SSCs may occasionally result in a reactor scram or safety-related system actuation, when such t

failures occur, the consequences are not significant since the resulting scram or safety system actuation is designed to place the plant in a safe state.

The 10 CFR 50.109 backfit analysis performed to justify issuance of the i Maintenance Rule is inadequate and contains serious flaws. It is Toledo Edison's position thats

1. The Maintenance Rule vill improve performance for only a few poor

performing plants.

2. Inappropriate data was used as the basis of the backfit analysis.

3. The cost of implementing the Haintenance Rule vill consume resources from improvements with actual safety benefit.

The nuclear industry is continually striving to improve performance and

, the average plant availability has improved substantially since 1985.

These improvements were accomplished without the Maintenance Rule and

, were not considered in the backfit analysis. Vith the exception of a 4

few poor performing plants, availability has improved to the point where further gains vill be made by reducing the length of outages, not improving equipment reliability. The backfit analysis assumes a $998 million savings in avoided replacement power cost due to increased availability. This cost savings was based on pre-1985 average preventable downtime for a satiafactory plant and is not achievable l given the already improved performance of the nuclear industry. '

f Toledo Edison believes that, if current availability figures are used, the avoided replacement power cost savings vould be much less than

$998 million. This, in turn, raises the estimated cost of implementing the Maintenance Rule. Toledo Edison contends that this money would be better spent in areas which could provide actual safety improvements.

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Docket Numb 2r 50-346

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• Licensa Numbar NPF-3 Serial Numbar 2109 Page 3 In conclusion, Toledo Edison believes that the . Maintenance Rule, as well ss the supporting regulatory activities such as issuance of the Re5ulatcry Guide 1020 is another example of where the regulatory prccess has an impact on O&E costs without an appreciable benefit in public safety. However, if the rule is not rescinded, Toledo Edison supports the comments submitted by NUMARC regarding DG-1020,

• • lonitoring the Effectiveness of Maintenance at Nuclear Power Plants."

if you have any questions regarding these comments, please contact .

H:. Robert V. Schrauder at (419) 249-2366.

l Very truly yours,

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cc A. B. Druist Regiona) Administrator, NRC Region III J. B. Neph)nri 160 Senior Project Manager S. Stasek, DC-1 1RC Cenior Pesident Inspector

0. Rothberg USWRC USNRC Document Control Pesk Utility Raalological Safety Board 1

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