ML20235T414

Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants

ML20235T414
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/24/1989
From:	Tison Campbell ARKANSAS POWER & LIGHT CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR47822, RULE-PR-50 0CAN02806, 53FR47822-00029, 53FR47822-29, CAN2806, NUDOCS 8903080274
Download: ML20235T414 (4)

Text

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vice Presadent . Nuclear BCAN028906 Mr. Samuel J. Chilk, Secretary Docketing and Service Branch U. S. Nuclear Regulatory Commission Document Centrol Desk Washington, D. C. 20555

SUBJECT:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Proposed Rule 10CFR Part 50 Ensuring the Effectiveness of Maintenance Programs for Nuclear Power Plants 53 FR 47822 (November 28, 1988)

Request for Comments

Dear Mr. Chilk:

Arkansas Power & Light (AP&L) is submitting these comments in response to the request of the U. S. Nuclear Regulatory Commission (NRC) for comments on the referenced NRC proposed rule regarding the effectiveness of maintenance programs for nuclear power plants (53 FR 47822).

AP&L has supported and directly participated in the development of the comments of the Nuclear Management and Resources Council (NUMARC) on the proposed maintenance rule. AP&L strongly endorses the NUMARC comments and takes no exceptions to the many points presented which oppose the proposed maintenance rule.

Because of AP&L's support of the NUMARC comments, AP&L will not herein reiterate those comments. Instead AP&L specificity will be presented.

Commissioner Roberts' views, published in the Federal Register with the proposed maintenance rule, provide compelling reasons for withdrawing the proposed rule. Among Commissioner Roberts' reasons are the following:

(1) the Commission is going beyond its authority in applying the rule to undefined Balance-of-Plant, (2) no problem has been identified which the proposed rule is supposed to correct, (3) the proposed rule is, without an implementing document, " specious."

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l 50 53FR47822 MEMBEA MIDDLE SOUTH UTILITIES SYSTEM

OCAN028906 FGbruary 24, 1989 Page 2 For example, paragraph (b) of the proposed rule purports to define maintenance by providing an exhaustive list of program elements and activities most of which are not defined. There are no widely accepted definitions of predictive, preventive, and corrective maintenance yet the rule would require that each utility establish, implement, and maintain an effective and documented maintenance program for each of these (and many more) elements and activities.

Although the rule would require that the utility measure the overall maintenance program effectiveness, the phrase " maintenance program effectiveness" is completely undefined. Since effectiveness can only be defined in terms of a particular objective it is imperative that the objective be identified. No such definition is offered.

The proposed maintenance rule invites misinterpretation, arbitrary enforcement, endless reinterpretation and an open door for local inspector interpretation. It is for these reasons that AP&L agrees with Commissioner Roberts that the proposed maintenance rule is, indeed, specious.

Safety, of course, is the number one priority. AP&L is committed to the goal of achieving safe, reliable and cost competitive nuclear generated electricity. Unsafe power plants cannot be reliable or cost competitive in the long term. It is for these reasons that AP&L has invested and continues to invest heavily in improvement efforts which upgrade maintenance and virtually all of the support functions for the conduct of maintenance activities. A partial list of these improvements is as follows:

1) Established a comprehensive equipment database which contains information on all installed power plant equipment and identifies quality requirements for the equipment.

2) Added plant staff to maintain the equipment database and modify appropriate documentation as the plant configuration is modified.

3) Computerized the equipment database and the entire maintenance work planning and scheduling cycle.

4) Centralized maintenance planning and scheduling and added qualified reactor operators to the scheduling group to improve communications.

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5) Established a work history function to obtain consistent and detailed work history at the component level.

6) Computerized the component work history documents.

7) Reviewed and updated vendor technical manuals and added engineering l staff to maintain the technical manuals.

8) Established an improved on-site modification organization to improve the modification process and better integrate maintenance requirements into the process.

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9) Placed engineering in a strong maintenance support role by assigning engineering the responsibility for the preventive and predictive maintenance program, quality designations and maintenance technical manuals.

10) Developed and computerized an engineered predictive and preventive maintenance program.

11) Incorporated trending programs in appropriate maintenance activities.

12) Improved maintenance record keeping by controlling and keying the record to equipment tag numbers.

13) Developed controlled procedures for preventive maintenance tasks.

14) Developed, maintain and control corrective maintenance procedures.

15) Added engineering staff which directly supports maintenance.

16) Strengthened the Quality Control function in maintenance.

17) Established an INP0 accredited maintenance training program. ,

18) Implemented the use of mock-ups to reduce radiation exposure.

19) Pro-actively remove loose contamination from the auxiliary building to reduce personnel exposure.

20) Implemented improved contracting procedures which provide for better control of contracted maintenance.

21) Greatly upgraded motor operated valve maintenance.

The preceding list is only a high level summary and not all inclusive of AP&L's efforts to improve maintenance. It does serve to demonstrate the commitment made by AP&L and the strong belief that there will be a long term return on this investment. Additionally, the Commission is aware that not all of our actions to improve maintenance were self-initiated. It is clear to AP&L that the NRC has adequate authority to cause utilities to improve in all the areas of the maintenance activities listed in the proposed maintenance rule when maintenance activities impact reactor safety.

AP&L has made a considerable investment in many areas in order to improve the quality of the maintenance being performed at ANO. A deep concern exists that if the proposed maintenance rule is issued, much of what we have accomplished will be lost in an effort to standardize and conform so that regulatory bodies can compare one plant's maictenanca practices to another. At this point, the effort required to standardize maintenance programs and practices to a regulatory norm would drain off resources which could be put to much more productive uses.

The final comment, and perhaps the most important one, is that maintenance <

costs provide the largest opportunity to manage the operating cost of a nuclear generating facility. AP&L, and we believe the nuclear industry,

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l has learned that~a well managed maintenance program is also the safest and least costly maintenance program. Lack of proper maintenance, in the long run, is the most costly maintenance program. Economic forces will cause maintenance to improve or, for those plants which do not improve, economic forces will penalize them Nch more severely than regulator enforcement actions.

AP&L firmly believes that the combination of existing regulations and the i

economic forces of~the electric utility business are fully adequate to cause the nuclear utilities to develop the very best maintenance programs l

which current technology supports. Implementation of the proposed maintenance rule will only add to the cost of such maintenance improvements.

Very truly yours Ah T. Gene Campbell TGC: dm cc: Regional Administrator Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive Suite 1000 Arlington TX 76011