ML20035D695
| ML20035D695 | |
| Person / Time | |
|---|---|
| Site: | 07002932, 07003057 |
| Issue date: | 03/30/1993 |
| From: | John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-57FR55601, RTR-REGGD-01.012, RTR-REGGD-1.012 57FR55601, TXX-93152, NUDOCS 9304140010 | |
| Download: ML20035D695 (2) | |
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Log # TXX-93152 g]
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File # 10086 4 F TUELECTRIC March 30, 1993 Wi!!iam J. Cahill, Jr.
Group Der hnhknt Regulatory Publications Branch DFIPS Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
COMMENTS TO SECOND PROPOSED REVISION 2 TO REGULATORY GUIDE 1.12
" NUCLEAR POWER PLANT INSTRUMENTATION FOR EARTHOUAKES.*
Gentlemen:
TU Electric is pleased with the opportunity to provide comments to the Second Proposed Revision 2 to Regulatory Guide 1.12
- Nuclear Power Plant Instrumentation for Earthquakes.'
The Draf t Regulatory Guide (DRG) DG-1016 proposes a substantial upgrade in seismic instrumentation over what is required in either revision 1 of Regulatory Guide 1.12 or the 1974 and 1978 versions of ANSI N18.5.
In general, TV Electric supports the proposed upgrades as being consistent with the industry initiatives sought by EPRI NUMARC, and the NRC to change the current analog technology to state of the art digital technology. The DRG proposes extensive use of Digital Time History Tri-axial Accelerographs instead of the current peak accelerographs and tri-axial spectrum recorders.
Digital time history accelerographs would in the future be easier to interface with other remote digital equipment.
The DRG should reference some industry standard that would allow common computer interf ace.
The DRG proposes to substantially increase the dynamic range and bandwidth of the instrumentation without providing a basis for the increase.
DRG DG-1016 proposes that the instrument recorders have a bandwidth from 0.20 bz to 50 hz and a dynamic range of 1000:1. yet most of the structural damage which occurs during an earthquake is attributable to the lower frequencies for which the current required range of 0.1 hz to 30 bz is adequate to cover.
The higher frequencies are typically quickly attenuated over distance.
The DRG does not provide a Regulatory Analysis, deferring instead 'o the Regulatory Analysis performed f or a proposed revision to 10 CFR Part 100 and 10 CFR Part 50.
In the draft Regulatory Analysis provided for the revisions to Parts 100 and 50 to 10 CFR, the point is made that a backfit analysis is not performed because the revisions apply only to applicants for future licenses and permits.
This infers that the DRG like the proposed revision to Parts 50 and 100 will apply only to applicants for future licensees and 9304140010 930330 PDR RECCD 01.012 C PDR e s. ouve succi Lii. si natias. 7 exas 752ni
TXX-93152 Page 2 of 2 permits.
The value impact statement for the First Proposed Revision 2 to Regulatory Guide 1.12 states that a backfit is required for the revision.
As the cost of implementing and maintaining the proposed instrumentation would be high and not easily justified.
TV Electric would like some assurance that a backfit will not be required.
TV Electric believes the upgrades could best be accomplished on a voluntary basis and as part of the industry instrumentation analog to digital initiative, when a corresponding increase in reliability will offset the cost of the upgrades.
If you have any questions please contact Jose' D. Rodriguez at (214) 812-8674.
Sincerely.
William J. Cahill, Jr.
By:
J. S. Marshall Generic Licensing Manager JDR/grp 1
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