ML20042D091
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7590-01 NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 AGENCY: Nuclear Regulatory Comission ACTION: Backfit Analysis for Regulatory Guide 1.9, Proposed Revision 3,
" Selection, Design, Qualification, Testing, and Reliability of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants."
SUMMARY
The Nuclear Regulatory Comission has amended its regulations to require that light-water-cooled nuclear power plants be capable of withstanding a total loss of alternating current (ac) electric power (called station blackout) for a specified duration and maintaining reactor core cooling during that period. That amendment, 10 CFR 50.63, was published in the Federal Register, June 21, 1988 (53 FR 23203).
The resolution of USI A-44, " Station Blackout," included a regulatory guide on station blackout (Regulatory Guide 1.155,
" Station Blackout"), which identified a need for a reliability program designed to maintain and monitor the reliability level
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. 7590-01 of each power source over time for assurance that the selected reliability levels are being achieved. Regulatory Guide 1.9, Revision 3, which is the resolution of GSI B-56, will provide guidance for use by the 5 ff or industry to review the adequacy of diesel generator programs consistent with the station blackout rule.
ADDRESSES:
Copies of the documents mentioned in this backfit analysis are available for inspection or copying for a fee at the NRC Public Document Room (PDR), 2120 L Street NW., (Lower Level),
Washington, DC. Copies of rules, NUREG documents, and regulatory guides may be purchased from the Superintendent of Documents, U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20013-7082. Copies are also available from the National Technical Information Service, 5825 Port Royal Road, Springfield, VA 22161. Single copies of draft regulatory guides are available at no charge by writing to the U.S. Nuclear Regulatory Comission, Washington, DC 20555, Attention:
Director, Division of Information Support Services.
FOR FURTHER INFORMATION CONTACT:
Aleck W. Serkiz, Division of Safety Issues Resolution, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Comission.
Washington, DC 20555, telephone:
(301)492-3923.
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SUPPLEMENTARY INFORMATION:
7590-01 BACKFIT ANALYSIS FOR REGULATORY GUIDE 1.9, REVISION 3, " SELECTION, DESIGN, QUALIFICATION, TESTING, AND RELIABILITY OF DIESEL GENERATOR UNITS USED AS ONSITE ELECTRIC POWER SYSTEMS AT NUCLEAR POWER PLANT 5" Revision 3 to Regulatory Guide 1.9 is closely related to the resolution of USI A-44, " Station Blcckout." The station blackout rule (10 CFR 50.63) was published in the Federal Register on June 21, 1988. Regulatory Guide 1.155,
" Station Blackout" (which provides guidance for compliance with the rule),
specifies that an emergency diesel generator (EDG) reliability program be implemented to maintain and monitor the reliability level of each power source over time for assurance that the selected reliability levels are being achieved.
An EDG reliability of 0.95 (or higher) is needed to limit the frequency of station blackout events to an acceptable level.
Regulatory Guide 1.155 identifies program elements that should be included in an EDG reliability program.
Revision 3 to Regulatory Guide 1.9 will not introduce any additional regulatory requirements or guidance beyond those required to meet 10 CFR 50.63, " Loss of All Alternating Current Power." The guide incorporates a " reference" EDG reliability program similar to that described in NUREG/CR-5078, Vol.1, April 1988.
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. 7590
- The regulatory analysis developed for USI A-44 is also applicable to the resolution of B-56. The regulatory analysis for USI A-44 is reported in NUREG-1109, June 1988.
The information that follows is provided in answer to specific requirements of 10 CFR 50.109(c).
(1) Statement of specific objectives that the proposed backfit is to achieve.
The objective of Revision 3 to Regulatory Guide 1.9 is to ensure that an adequate EDG reliability program will be implemented by licensees:
to achieve and maintain the EDG reliability levels selected for compliance with 10 CFR 50.63.
(2) General description of activity that would be required by the licensee or applicant in order to complete the backfit.
To conform with the guide, licensees must have a reliability program consisting of surveillance testing, reliability monitoring, and maintenance programs for the emergency diesel generators. An information and data collection system and a management oversight program are also specified.
Licensees currently have plant-specific EDG maintenance and operational procedures 'that result in industry-wide _ average
. 7590-01 reliability levels on the order of 98% or higher. Thus most licensees will have to make little or no changes.
(3) Potential change in the risk to the public from accidental offsite release of radioactive material.
The risk estimates provided in NUREG-1109 are applicable.
In the absence of an adequate EDG reliability program, assurance would be lacking that proper levels of EDG reliability and these estimates of risk were being maintained.
(4) Potential impact of radiological exposure of facility employees.
No radiological exposure is projected. The implementation of an EDG reliability program is not expected to require personnel to be exposed to radiation.
(5) Installation and continuing costs associated with the backfit, the cost of facility downtime, or the cost of construction delay.
No facility downtime or construction delays due to the implementation of Revision 3 to Regulatory Guide 1.9 are envisioned. The continuing costs associated with maintaining a diesel reliability program should be small since most operating plants currently have some form of an EDG reliability and maintenance program.
Cost estimates for improving
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lt 7590-01 EDG reliability were est'inted at $150,000 to $400,000 per reactor (10 reactors affected) as part of the station blackout regulatory analysis (NUREG-1109).
(6) The potential safety impact of changes in plant or operational complexity, including the relationship to proposed and existing regulatory requirements.
i This guide will not increase operational complexity. This l
regulatory guide provides an acceptable means of ensuring that the reliability of the diesel generators used in determining the station blackout duration, as specified in 10 CFR 50.63, is maintained.
(7) The estimated resource burden on the NRC associated with the proposed backfit and the availability of such resources.
The principal cost to the NRC would be associated with reviewing EDG reliability programs at the respective plants sites via the temporary instructions. The estimates presented in NUREG-1109 are that such efforts would not exceed 0.5 person-months per site. At an l
estimated $12,000 per staff month and 50 sites, the total cost is l
projected to be $300,000.
If NUMARC's B-56 working group is involved during the coment period on Proposed Revision 3 to Regulatory Guide 1.9, a standardized (or
' 7590-01 industry-wide) EDG reliability program approach could be defined, and therefore NRC costs would be less than estimated above.
(8) The potential impact of differences in facility type, design, or age on the relevance and practicality of the proposed backfit.
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l There is no significant anticipated impact due to difference in plant type, design, or age.
(9) Whether the proposed backfit is interim or final, and if interim, the l
justification for imposing the proposed backfit on an interim basis.
The proposed action is final.
The factors discussed above support the determination that Regulatory Guide 1.9, Revision 3 as guidance for implementation of the station blackout rule (10 CFR 50.63) would provide a substantial increase in the overall protection of the public health and safety, and the direct and indirect costs of the implementation are justified in view of this increased protection.
(5 U.S.C. 552(a))
Dated at Rockville, Maryland, this N
day of M v4,n d e 1988.
For the Nuclear Regulatory Commission
']jhl&'u/d i
R. Wayne Houston, Director i
Division of Safety Issue Resolution j
Office of Nuclear Regulatory Research
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2 U.S. NUCLEAR REGULATORY COMMISSION November 1988 i
i.k1h7 j OFFICE OF NUCLEAR REGULATORY RESEARCH Division 1
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DRAFT REGULATORY GUIDE
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Contact:
A. W. Serkiz (301) 492-3923
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PROPOSED REVISION 3 TO REGULATORY GUIDE 1.9 SELECTION, DESIGN, QUALIFICATION, TESTING, AND RELIABILITY 0F DIESEL GENERATOR UNITS i
USED AS ONSITE ELECTRIC POWER SYSTEMS j
AT NUCLEAR POWER PLANTS j
i A.
INTRODUCTION i
l Criterion 17, " Electric Power Systems," of Appendix A, " General Design l
Criteria for Nuclear Power Plants," to 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," requires that onsite electric power systems have sufficient independence, capacity, capability, redundancy, and i
testability to ensure that (1) specified acceptable fuel design limits and l
design conditions of the reactor coolant pressure boundary are not exceeded as j
a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents, assuming a single failure.
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Criterion 18, " Inspection and Testing of Electric Power Systems," of l
Appendix A to 10 CFR Part 50 requires that electric power systems important to 4
safety be designed to permit appropriate periodic inspection and testing to assess the continuity of the systems and the condition of their components.
Criterion XI, " Test Control," of Appendix B, " Quality Assurance Criteria
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l for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50 1
requires that (1) measures be provided for verifying or checking the adequacy 9
This regulatory guide is being issued in draf t form to involve the public in the early stages of ihe oewelop-ment of a regulatory position in this area. It has not received complete staff review and does not represent an official NRC staff position.
Public comments are being solicited on the draft guide (including any implementation schedule) and its associ-i ated regulatory analysis or value/ impact statement. Comments should be accompanied by appropriate supporting data. Written connents may be submitted to the Regulatory Publications Branch. DFIPs. Dffice of Administra-tion and Resources Management. U.s. Nuclear Regulatory Commission. Washington. DC 20$55. Copies of consents received may be examined at the NRC Public Document Room. 2120 L street NW.. Washington, DC. Comments will be most helpful if received by Requests for single copies of draft guides (which may be reproduced) or for p14 cement on an automatic distri-bution list for single copies of future draft guides in specific divisions should be made in writing to the l
U.s. Nuclear Regulatory Commission. Washington. DC 20555. Attention: Director. Division of Infonnation support services.
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j of design by design reviews, by the use of alternative or simplified calcu-lational methods, or by the performance of a suitable testing program and l
(2) a test program be established to ensure that systems and components per-l form satisfactorily and that the test program include operational tests during j
nuclear power plant operation.
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l The Commission has amended 10 CFR Part 50.
Paragraph (a), " Requirements,"
f of 6 50.63, " Loss of All Alternating Current Power," now requires that each light-water cooled nuclear power plant be able to withstand and recover from a station blackout (i.e., loss of offsite and onsite emergency ac power system) i 4
for a specified duration. Section 50.63 identifies the reliability of onsite i
i emergency ac power sources as being one of the main factors contributing to risk of core melt resulting from station blackout.
I Diesel generator units have been widely used as the power source for the j
l onsite electric power systems. This regulatory guide describes a method
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j acceptable to the NRC for complying with the Commission's requirements that
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i diesel generator units intended for use as onsite power sources in nuclear j
power plants be selected with sufficient capacity, be qualified, and be
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maintained for reliability equal to or above the levels selected for design
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basis accidents and station blackout.
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This guide has been prepared for the resolution of Generic Safety Issue l
B-56, " Diesel Reliability," related to Unresolved Safety Issue (USI) A-44, j
" Station Blackout." The resolution of USI A-44 established a need for an l
emergency diesel generator reliability program that has the capability to l
achieve and maintain the emergency diesel generator reliability. levels in the range of 0.95 per demand or better.
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This guide recognizes the fact that unless diesel generators are properly j
maintained their capabilities will degrade with age. The condition of the 7
diesel units must be monitored during the test and maintenance programs, and
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appropriate parametric trends must be noted to detect potential failures; appropriate preventive maintenance should be performed.
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Any information collection activities mentioned in this draft' regulatory guide are contained as requirements in 10 CFR Part 50, which provides the 1
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regulatory basis for this guide. The information collection requirements in 10
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CFR Part 50 have been cleared under 0MB Clearance No. 3150-0011.
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B.
DISCUSSION i
A diesel generator unit selected for use in an onsite electric power j
system should have the capability to (1) start and accelerate a number of large motor loads in rapid succession while sustaining the loss of all or any part of such loads and maintaining voltage and frequency within acceptable limits, (2) provide power promptly to engineered safety features if a loss of offsite power and an accident occur during the same time period, and (3) supply power con-tinuously to the equipment needed to maintain the plant in a safe condition 4
if an extended loss of offsite power occurs.
IEEE Std 387-1984, "IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations,"*
delineates principal design criteria and qualification testing requirements that, if folluwed, will help ensure that selected diesel generator units meet performance and reliability requirements.
(IEEEStd 387-1977 was endorsed by Revision 2 of Regulatory Guide 1.9, " Selection, Design, and Qualification of 4
Diesel-Generator Units Used as Standby (0nsite) Electric Power Systems at Nuclear Power Plants.")
IEEE Std 387-1984 was developed by Working Group 4.2C of the Nuclear Power Engineering Committee (NPEC) of the Institute of Electrical and Electronics Engineers, Inc. (IEEE), approved by NPEC, and subsequently l
approved by the IEEE Standards Board on March 11, 1982.
IEEE Std 387-1984 is supplementary to IEEE Std 308-1974, "IEEE Standard Criteria for Class IE Power Systems and Nuclear Power Generating Stations,"* and specifically amplifies paragraph S.2.4, " Standby Power Supplies," of IEEE Std 308 with respect to the application of diesel generator units.
IEEE Std 308-1974 is endorsed, with i
certain exceptions, by Regulatory Guide 1.32, " Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants."
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- Copies may be obtained from the Institute of Electrical and Electronics Engineers, Inc., United Engineering Center, 345 East 47th Street, New York, New York 10017.
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A knowledge of the characteristics of each load is essential in establish-ing the bases for the selection of a diesel generator unit that is able to l
accept large loads in rapid succession. The majority of the emergency loads are large induction motors. This type of motor draws, at full voltage, a starting current five to eight times its rated load current. The sudden large increases in current drawn from the diesel generator resulting from the startup l
of induction motors can result in substantial voltage reductions. The lower j
voltage could prevent a motor from starting, i.e., accelerating its load to l
rated speed in the required time, or the reduced voltage could cause a running l
motor to slow down or stall. Other loads, because of low voltage, might be j
lost if their contactors drop out. Recovery from the transient caused by
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starting large motors or from the loss of a large load could cause diesel l
engine overspeed that, if excessive, might result in a trip of the engine, i.e., loss of the Class IE power source. These same consequences can also l
result from the cumulative effect of a sequence of more moderate transients if j
the system is not permitted to recover sufficiently between successive steps in a loading sequence.
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Generally it has been industry practice to specify a maximum voltage j
reduction of 10 to 15 percent when starting large motors from large-capacity j
power systems and a voltage reduction of 20 to 30 percent when starting these motors from limited-capacity power sources such as diesel generator units.
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Large induction motors can achieve rated speed in less than 5 seconds when powered from adequately sized diesel generator units that are capable of I
restoring the bus voltage to 90 percent of nominal in about I second.
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Protection of the diesel generator unit from excessive overspeed, which can result from a loss of load, is afforded by the insnediate operation of a f
j diesel generator unit trip, usually set at 115 percent of nominal speed..In j
addition, the generator differential current trip must operate immediately in
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order to prevent substantial damage to the generator, i
There are other protective trips provided to protect the diesel generator j
units from possible damage or degradation. However, these trips could i
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interfere with the successful functioning of the unit when it is most needed, l
i.e., during accident conditions. Experience has shown that there have been i
numerous occasions when these trips have needlessly shut down diesel generator I
units because of spurious operation of a trip circuit. Consequently, it is l
important that measures be taken to ensure that spurious actuation of these I
other protective trips does not prevent the diesel generator unit from j
performing its function.
j The uncertainties inherent in estimates of safety loads at the construction permit stage of design are sometimes of such magnitude that it is prudent to j
provide a substantial margin in selecting the load capabilities of the diesel l
generator unit. This margin can be provided by estimating the loads con-j servatively and selecting the continuous rating of the diesel generatgr unit j
so that it exceeds the sum of the loads needed at any one time. A more accurate estimate of safety loads is possible during the operating license a
stage of review because detailed designs have been completed and component fa st j
and preoperational test data are usually available. At this point the NRC permits the consideration of a somewhat less conservative approach, such as operation with safety loads within the short-time rating
' the diesel 2
j generator unit.
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l The issue of station blackout identifies the reliability of diesel genera-l tors as being one of the main factors affecting the risk of core damage from a station blackout event. Thus, attaining and maintaining high reliability of l
diesel generators at nuclear power plants is necessary to reduce the probability i
of station blackout.
In Regulatory Guide 1.155, " Station Blackout," the reliability of the diesel generator is one of the factors to be used to determine the length of time a plant should be able to cope with a station
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blackout.
If all other factors (redundancy of emergency diesel generators,
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frequency of loss of offsite power, and probable time needed to restore offsite l
power) remain constant, a higher reliability of the diesel generators will j
result in a lower probability of a total loss of ac power (station blackout) 4
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with a consequent shorter coping duration according to Regulatory Guide 1.155.
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j High reliability must be designed into the diesel generator units and l
maintained throughout the entire time they are in service. This can be accomplished by appropriate surveillance monitoring, testing, trend analysis, l
maintenance programs, and the institution of a reliability program designed to I
improve and maintain reliability at a specified level necessary for protection j
against design basis accidents and station blackout events.
i In order to provide explicit guidance in the areas of preoperational test-
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j ing, periodic testing, reporting requirements, and valid demands and failures, this guide provides a logical extension of the corresponding sections of IEEE Std 387-1984. The preoperational and periodic testing provisions set forth in
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this guide provide a basis for taking corrective actions needed to maintain -
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high inservice reliability of installed diesel generator units. The data j
developed will provide an ongoing demonstration of performance and reliability i
for all diesel generator units af ter installation and during service.
This revision of Regulatory Guide 1.9 endorses IEEE Std 387-1984.
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addition, this guide describes a means for meeting the minimum diesel generator j
reliability goals for Regulatory Guide 1.155. This guide also provides prin-cipal elements of a diesel generator reliability program to be instituted at nuclear power plants that is designed to maintain and monitor the reliability
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1evel of each diesel generator unit over time for assurance that the selected j
reliability levels are being achieved. This reliability guidance is provided l
in Regulatory Position 18 of this guide.
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C.
REGULATORY POSITION j
Conformance with the requirements of IEEE Std 387-1984, "IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for j
Nuclear Power Generating Stations," is acceptable for meeting the requirements
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of the General Design Criteria (GDC) and for performing qualification and periodic testing of diesel generator units used as onsite electric power i
systems for nuclear power plants subject to the following:
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1.
Section 1.2 of the standard, " Inclusions of IEEE 387-1984," should include diesel generator auto controls, manual controls, and the diesel generator output breaker.
2.
When the characteristics of loads are not accurately known, such as during the construction permit stage of design, each diesel generator unit of an onsite power supply system should be selected to have a continuous load rating (as defined in Section 3.7.1 of IEEE Std 387-1984) equal to or greater than the sum of the conservatively estimated loads (nameplate) needed to be powered by that unit at any one time.
In the absence of fully substantiated i
performance characteristics for mechanical equipment such as pumps, the f
electric motor drive ratings should be calculated using conservative estimates of these characteristics, e.g., pump runout conditions and motor efficiencies of 90 percent or less and power factors of-85 percent or higher.
3.
At the operating license stage of review, the predicted loads'should not exceed the short-time rating (as defined in Section 3.7.2 of IEEE Std 387-1984) of the diesel generator unit.
4.
Section 4, " Reference Standards," of IEEE Std 387-1984 lists addi-tional applicable IEEE standards. The specific applicability or acceptability of these referenced standards has been or will be covered separately in other regulatory guides, where appropriate.
5.
In Section 5.1.1, " General," of IEEE Std 387-1984, the requirements of IEEE Std 308-1974 should be used subject to the guidance in Regulatory Guide 1.32.
6.
Section 5.1.2, " Mechanical and Electrical Capabilities," of IEEE Std 387-1984 pertains, in part, to the starting and load-accepting capabilities of the diesel generator unit.
In conformance with Section 5.1.2, each diesel generator unit should be capable of starting and accelerating to rated speed, in the required sequence, all the needed engineered safety feature and emergency shutdown loads. The diesel generator unit. design should be such that at no time during the loading sequence should the frequency decrease to less than 95 percent of nominal nor the voltage decrease'to less than 75 percent of 7
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s-nominal.
(A larger decrease in voltage and frequency may be justified for a diesel generator unit that carries only one large connected load.) Frequency e
I should be restored to within 2 percent of nominal, and voltage should be restored to within 10 percent of nominal within 60 percent of each load-sequence time interval.
(A greater percentage of the time interval may be used if it can be justified by analysis. However, the load-sequence time interval should j
include sufficient margin to account for the accuracy and repeatability of the load-sequence timer.) During recovery from transients caused by step-load increases or resulting from the disconnection of the largest single load, the speed of the diesel generator unit should not exceed the nominal speed plus 75 percent of the difference between nominal speed and the overspeed trip setpoint l
or 115 percent of nominal, whichever is lower.
Furthermore, the transient following the complete loss of load should not cause the speed of the unit to attain the overspeed trip setpoint.
7.
Section 5.4, " Design and Application Considerations," of IEEE Std
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387-1984 pertains to design features for consideration in diesel generator unit design. Section 5.4 should be supplemented as follows i
7.1.
Diesel generator units should be designed to be testable during operation of the nuclear power plant as defined in Regulatory Position 10.2.
The design should include provisions so that testing of the units will simulate 3
the parameters of operation (manual start, automatic start, load sequencing, f
load shedding, operation time, etc.), normal standby conditions, and environ-
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ments (temperature, humidity, etc.) that would be expected if actual demand were to be placed on the system.
(If prewarm systems designed to maintain lube oil and jacket water cooling at certain temperatures or prelubrication system or both are normally in operation, this would constitute normal standby con-ditionsforthatplant.)
7.2.
Capability should be provided to test each diesel generator unit independently of redundant units. Test equipment should not cause a loss l
of independence between redundant diesel generator units or between diesel generator load groups.
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7.3.
Testability should be considered in the selection and location of instrumentation sensors and critical components (e.g., governor, starting system components).
Instrumentation sensors should be readily accessible and designed so that their inspection and calibration can be verified in place.
Testability should be considered in selecting critical components, and the overall design should include status indication and alarm features.
7.4.
Detailed step-by-step procedures should be provided for each test listed in Regulatory Position 10.
The procedures should identify those special arrangements or changes in normal system configuration that must be made to put the diesel generator unit under test. Jumpers and other nonstandard configurations or arrangements should not be used subsequent to initial equipment startup testing.
7.5.
Subsequent to any failure, the root cause should be determined and corrective action taken to prevent a reoccurrence of the failure.
8.
Section 5.5.3.1, " Surveillance Systems," of IEEE Std 387-1984 pertains to status indication of diesel generator unit conditions. This r.ection should be supplemented as follows:
8.1.
A surveillance system should be provided with remote indication in the control room as to diesel generator unit status, e.g., under test, ready-standby, lockout. A means of communication should also be provided between diesel generator unit testing locations and the main control room to ensure that the operators are cognizant of the status of the unit under test.
8.2.
In order to facilitate trouble diagnosis, the surveillance system should indicate which of the diesel generator protective trips is activated first.
9.
Section 5.5.4, " Protection," of IEEE Std 387-1984 pertains to bypass-ing diesel generator protective trips.
In this section, the "shall" indicating a requirement should be treated as "may."
In conjunction with Section 5.5.4, the diesel generator protective trips other than engine overspeed and generator-differential overcurrent should be handled in one of two ways:
(1)a 9
trip should be implemented with two or more measurements for each trip I
parameter with coincident logic provisions for trip actuation, or (2) a trip l
may be bypassed under accident conditions, provided the operator has sufficient
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time to react appropriately to an abnormal diesel generator unit condition.
l The design of the bypass circuitry should include the capability for (1) j testing the status and operability of the bypass circuits, (2) alarming in the j
i control room for abnormal values of all bypass parameters, and (3) manually 1
resetting the trip bypass function. (Capability for automatic reset is not j
acceptable.)
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l The requirement of Section 5.5.4(2) for retaining all protective devices f
during diesel generator testing does not apply to a periodic test that demon-
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strates diesel generator system response under simulated accident conditions.
- 10. Section 6.4, " Site Acceptance Testing," and Section 6.5, " Periodic i
Testing," of IEEE Std 387-1984 should be supplemented as follows:
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j 10.1.
Pre-operational Testing i
i There should be a pre-operational test program for all diesel genera-f tors following assembly and installation at the site. This test program should demonstrate the required reliability (0.95 per demand targeted for each diesel generator for station blackout) by means of any 69 consecutive valid tests
- on a per plant basis with no failures, with a minimum of 23 or 69/n tests, l
whichever is the larger per installed diesel generator unit (where "n" is equal z
to the number of diesel generator units of the same design and size). A series of 69 consecutive tests without a failure constitutes a reliability of 0.95 per j
demand at a 97 percent confidence level for the diesel generators on a per plant basis. A series of 23 consecutive tests without a failure constitutes a i
reliability of 0.95 per demand at a 69 percent confidence level for each diesel generator. This program should also include tests performed according to
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Regulatory Positions 10.2.4.1 through 10.2.4.10.
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- Valid test is defined in Regulatory Position 14.
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i 10.2.
Periodic Testing 5
After the plants are licensed, periodic surveillance testing of each l
diesel generator must demonsi. rate continued capability and reliability of the j
diesel generator unit to perform its intended function.
10.2.1.
Monthly Testing i
j After completion of the diesel generator unit reliability demon-l stration during preoperational testing, periodic testing of diesel generator units during normal plant operation should be performed. Each diesel generator should be started at least once in 31 days (with maximum allowable extension l
not to exceed 25 percent of the surveillance interval) on a staggered basis and 1
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10.2.1.1.
Demonstrate proper startup from standby con-ditions and verify that the required voltage and frequency are automatically attained within acceptable limits and time.
For these tests, the diesel i
generator should be slow started (brought up to full speed slowly), be pre-lubricated, have prewarmed oil and water circulating, and should reach rated voltage and frequency on a prespecified schedule that is selected to minimize 4
stress and wear. This test should also verify that the components of the
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diesel generator unit required for all automatic and manual startups are operable.
10.2.1.2.
Demonstrate full-load-carrying capability (con-tinuous rating) for an interval of not less than one hour ind until temperature equilibrium at the continuous rating has been attained. This test could be accomplished by synchronizing the generator with the offsite power. The loading and unloading of a diesel generator during this test should be gradual, based on a prescribed schedule that is selected to minimize stress and wear on the diesel generator.
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Accelerated Testing
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The following criterion for increasing the test frequency is f
f necessary to determine whether a major degradation in diesel generator j
reliability is indicated.
j Whenever a diesel generator unit has experienced two or more j
failures in the last 20 demands, the maximum time between tests for that diesel generator unit should be reduced to 7 days. This test frequency should be 4
f maintained until seven consecutive failure-free demands have been performed i
and the number of failures in the last 20 tests has been reduced to one or
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i less. Two failures in 20 demands provides a reliability of 0.90 at a confidence level of 32 percent. This is an indication of possible degradation of the l
reliability of the diesel generator. Increasing the test frequency-will allow for a more timely accumulation of additional test data upon which to base judgment of the reliability of the unit.
1 10.2.3.
Six Months (or 184 Days) Testing
- j The design basis for nuclear power plants requires a capacity l
for the diesel generator units to make fast starts (i.e.,10 seconds) from standby conditions to provide the necessary power to mitigate the large loss-of-i coolant accident coincident with loss of offsite power. -It has been determined l
(based on a probabilistic risk analysis performed to examine the change in core j
melt frequency associated with lengthening the fast-start test interval) that i
relaxation of fast-start test frequency from once per month to once per 6 months
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l would not appreciably increase risk.
In order to retain loss-of-coolant accident i
design considerations, the following fast-start and load test should be performed at least once each 6 months on a staggered basis.
j 10.2.3.1.
Demonstrate that each diesel generator unit i
starts from standby conditions (if a plant has normally operating prelube and l
prewarm systems this should constitute its standby conditions) and verify that
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the diesel generator reaches stable rated voltage and frequency within acceptable limits and time.
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- This test may be conducted in accordance with the manufacturer's recomendations I
i regarding engine wear.
12 4{
i
-.- - -. D
i T
i 10.2.3.2.
Demonstrate full-load-carrying capability by verifying the generator is synchronized to the offsite power and loaded to its continuous rating in less than or equal to its total design accident loading sequence time and operates for at least one hour.
10.2.4.
Eighteen-Month Testing During Shutdown
- i Overall diesel generator system design capability should be verified as follows. Testing of diesel generators during a refueling outage or plant shutdown should:
10.2.4.1.
Demonstrate by simulating a loss of offsite power that (1) the emergency buses are deenergized and the loads are shed from j
the emeroency buses and (2) the diesel generator starts on the auto-start signal 4 a its standby conditions, attains the required voltage and frequency within
,eptable limits and time, energizes the auto-connected shutdown loads through the load sequencer, and operates while loaded with its shutdown loads for greater than or equal to 5 minutes.
)
10.2.4.2.
Demonstrate that on a safety injection auto-start i
(SIAS) signal, the diesel generator starts on the auto-start signal from its
[
standby conditions, attains the required voltage and frequency within acceptable i
limits and time, and operates on standby for greater than or equal to 5 minutes.
10.2.4.3.
Demonstrate by simulating a loss of offsite power in conjunction with SIAS that (1) the emergency buses are deenergized and loads are shed from the emergency buses and (2) the diesel generator starts on the auto-start signal from its standby conditions, attains the required voltage i
and frequency within acceptable limits and time, energizes auto-connected loads through the load sequencer, and operates while loaded with the auto-connected loads for greater than or equal to 5 minutes.
In addition, verify that the i
auto-connected loads do not exceed the 2-hour rating of the diesel generator.
- These tests may be conducted in accordance with the manufacturer's recommenda-tions regarding engine wear.
4 13
i
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3-i i
^
2 10.2.4.4.
Demonstrate the diesel generator capability to reject a loss of the largest single load and verify.that the voltage and fre-(
t l
quency requirements are met.
i i
10.2.4.5.
Demonstrate the diesel generator capability to i
reject a full short-time rating load and verify that the voltage requirements are met and that the unit will not trip on overspeed.
(If the auto-connected I
loads do not exceed the continuous rating of the diesel generator, the load rejection test should be conducted at its continuous rating.)
\\
10.2.4.6.
Diesel generator endurance and margin test:
1 demonstrate full-load-carrying capability for an interval of not less than 24 1
i j
hours, of which 2 hcurs should be at a load equivalent to the 2-hour rating of
]
the diesel generator and 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> at a load equivalent to the continuous rating
)
of the diesel generator. Verify that voltage and frequency requirements are maintained. The test should also verify that the mechanical systems such as
}
fuel, lubrication, and cooling function within design limits.
i i
10.2.4.7.
Demonstrate hot restart functional capability at 1
4 full-load temperature conditions by verifying that the diesel generator. starts 4
on a manual or auto-start signal, attains the required voltage and frequency
[
within acceptable limits and time, and operates for longer than 5 minutes.
10.2.4.8.
Demonstrate the ability to (a) synchronize the diesel generator unit with offsite power while the unit is connected to the 4
3 emergency load, (b) transfer this load to the offsite power, (c) isolate the diesel generator unit, and (d) restore it to standby status.
i 3
i 10.2.4.9.
Demonstrate that all automatic diesel generator
)
trips (except engine overspeed and generator differential) are automatically bypassed upon loss of voltage on the emergency bus concurrent with a safety injection actuation signal.
1 1
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10.2.4.10.
Demonstrate that with the diesel generator operating in a test mode while connected to its bus, a simulated safety j
injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizing the emergency loads.from f
offsite power.
I 10.2.4.11.
Demonstrate once per 10 years (during a plant l
shutdown), or af ter any modifications that could affect diesel generator independence, whichever is the shorter, by starting both redundant units simultaneously to help identify certain common failure modes undetected in single diesel generator unit tests.
11.
In Sect. ion 7.1, " Qualification," of IEEE Std 387-1984, the qualifica-tion testing requirements of IEEE Std 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations," should be used sub-ject to the regulatory position of Regulatory Guide 1.89, " Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants."
- 12. Section 7.2.2, " Start and Load Acceptance Qualification," of IEEE Std 387-1984 pertains to test requirements for diesel generator unit qualification.
Per Section 7.2.2, fewer successful start-and-load tests and allowed failures than that specified (300 valid tests with no more than 3 failures) may be justified for a diesel generator unit that carries only one large connected load tested under actual conditions, provided an equivalent reliability or confidence level is demonstrated.
13.
In Section 7.2.1(3), " Load Capability Tests," of IEEE Std 387-1984, theorderofsequenceloadtestsdescribedinparts(1)and(2)shouldbeas follows: Load equal to the continuous rating should be' applied for the time required to reach engine temperature equilibrium, at which time the rated short-time load should be applied for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Immediately following the 2-hour short-time load test, load equal to the continuous rating should be applied for 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
15
1 i
- 14. The definition of valid tests and failures in Section 7.2.2(5) of
~
IEEE Std 387-1984 should be supplemented as follows for the purpose of cal-j culating the reliability of diesel generator s:
Validdemands(inadvertent, actual,ortest)andfailuresshouldbe j
based on the following criteria. All start-only demands (as defined in Regula-tory %sition 17.2.2) and start and load-run demands (as def)..ed in Regulatory l
Position 17.2.3), whether automatic or manually initiated, that result in f
failure to start or start and load-run should be ccnsidered valid demands and failures except as noted below.
l i
Unsuccessful attempts to start or to start and load-run should not be counted as valid starts or failures
- for both design basis accidents and station blackout reliability calculation purposes when they can be definitely attributed to any of the following:
j a.
Operating errors that definitely would not prevent the diesel generator from being restarted and loaded within a few minutes (i.e., without corrective maintenance).
b.
Spurious operation of a trip that would be bypassed in emergency operating mode, c.
Malfunction of equipment that is not operable during the emer-gency operating mode (e.g., synchronizing circuitry).
d.
Tests that are terminated intentionally because of an alarmed abnormal condition that would not have ultimately resulted in diesel generator damage or failure.
- An automatic start failure, if immediately restarted manually from the control room'or.fromthelocal-panel (inlessthan5 minutes)withoutcorrectivemain-tenance, should not be counted as a failure for station blackout reliability calculations.- However, it should be counted as a failure for design basis accident reliability calculations.
16
, - _ - ~ _
l l.
i e
i e.
Tests performed in the process of troubleshooting and tests per-l formed while the diesel generator is declared inoperable.
(A diesel generator i
should be considered inoperable from the time it is declared inoperable for preventive maintenance or following a failure that resulted in the diesel generator being declared inoperable through the period required for trouble-l shooting and corrective actions and until a valid successful test is completed I
to declare it operable.)
i l
f.
A failure of equipment that is not part of the defined diesel j
generator unit design.
j
- 15. Sections 7.3.2 and 7.4 of IEEE Std 387-1984 identify IEEE Std 344-1975, j
" Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear I
Power Generating Stations," for seismic analysis or seismic testing by equipment
)
manufacturers. Revision 2 of Regulatory Guide 1.100, " Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants," endorses a later version of the standard, IEEE Std 344-1987.
i f
- 16. Section 7.5.2, " Records and Analysis," of IEEE Std 387-1984 should be j
supplemented as follows:
l j
i 16.1.
Recordkeeping Criteria
)
All valid and inadvertent start demands, including all start-only i
demands and all start and load-run demands whether by automatic or manual i
initiation, should be logged for each diesel generator. The log should be maintained in a.
au '
and retrievable form as described in Regulatory l
' e lag Thould describe each occurrence in sufficient detail to Position 18.7.
i' j
permit independent det<.11 nation of statistical validity in accordance with
}
Regulatory Position 14. The log should also note whether the diesel generator f
successful start was immediate (for design basis accident reliability calcula-i tions) or delayed (for station blackout reliability calculations). Maintenance, 1
i repair, and out-of-service time histories, as well as cumulative maintenance and operating data (hours of operation), should also be logged. The out-of-I service time should include the hours the diesel generator is removed from service (declaredinoperable)forpreventivemaintenance, corrective i
i i
i 1
17
maintenance following a failure, modifications, or for support systems out of j
service. The out-of-service time for diesel generators during refueling should not be counted if the diesel generator is electively removed from service (i.e., no failure has occurred). Corrective maintenance time after failures should be counted as out-of-service time even when unlimited removal of a diesel generator from service is allowed during refueling.
16.2.
Reporting Criteria If the number of failures in the last 20 valid tests is 3 or more.or in the last 100 tests is 8 or more, this should be reported to the NRC within 14 days, and a detailed report should be prepared and maintained at the site in auditable form. This report should include the following.
i i
16.2.1.
A sumary of all. tests (valid and invalid) that occurred within the time period over which the last 20 and 100 valid tests were performed, including dates and the periodic testing interval in effect.
{
16.2.2.
Analysis of the failures experienced and determination-of root causes of failures.
l 16.2.3.
Identification of all actions taken or planned to (1) l correct the root causes of failures defined in Regulatory Position 16.2.2 and (2) increase the reliability of the diesel generator units.
16.2.4.
A schedule for implementation of each action from Regulatory Position 16.2.3.
l 16.2.5.
An assessment of the existing unavailability of j
electric power to engineered safety feature equipment.
16.2.6.
The basis for continued plant operation if that is planned.
1 i
16.2.7.
An assessment of the need for improvement in the reliability program implemented in accordance with Regulatory Position 18.
18
3 i
- 17. Reliability Demonstration of Diese1 Generator Units To Meet Station Blackout and Design Basis Accident Requirements 17.1.
Diesel Generator Reliability Goals 1
1 The following reliability goals for the diesel generator units have been established and should be demonstrated throughout their service lifetime.
i 17.1.1.
Station Blackout In order to comply with 10 CFR Part 50, 5 50.63, " Loss of All Alternating Current Power," and the guidelines provided in Regulatory Guide 1.155, the minimum reliability goals of 0.95 per demand for each diesel gen-3 erator should be targeted for plants in emergency ac Groups A, B, and C, and 4
0.975 per demand for plants in emergency ac Group D (see Table 2 of Regulatory Guide 1.155). These reliabilities are calculated according to Regulatory Position 17.2.1.
i 17.1.2.
Design Basis Accidents Although a quantitative reliability goal for use in risk assess-ment analysis for design basis accidents has not been established, a goal of l
0.95 per demand (as calculated for station blackout) provides a reasonable estimate for such assessments.
If a more rigorous reliability calculation is 4
required specifically for design basis accidents, the reliability calculation should be performed using only the successful diesel generator immediate starts.
That is, the delayed starts (within 5 minutes) that were deemed successful for i
station blackout should be considered failures.
i To ensure that the above goals are achieved and maintained throughout the life of the plant, a monthly testing and an accelerated testing (should a diesel generator's reliability fall below its specified level) should be performed as defined in Regulatory Positions 10.2.1 and 10.2.2 to determine whether a major degradation in reliability is indicated.
19
l 17.2.
Diesel Generator Reliability Determinations l
17.2.1.
Diesel Generator Reliability Calculations The reliability of each diesel generator is based on the number of starts and load-run failures in the last 20 and 100 valid demands (if the total number of valid demands is less than 100, the actual demands may be used instead of 100) accumulated over no more than 3 years.
The reliability should be calculated as follows:
Reliability (Q) = (start reliability) x (load-run reliability)
A sample calculation is provided below.
l Humber of valid demands to start = 100 l
Number of successful starts = 99 Number of valid demands to load = 90*
Number successful load runs = 88
- Thus, Start-only reliability = h = 0.99 h
= 0.977 Load-run reliability
=
Q = 0.99 x 0.977 = 0.967
- The 90 demands to load are included as part of the 100 demands to start. Ten of the demands to start did not continue on to demands to load.
l 20
l l'
17.2.2.
Diesel Generator Start Criteria j
A start-only demand (inadvertent, actual, or test), whether by automatic or manual initiation, is a demand in which the diesel generator is started, attains rated voltage and frequency within a prespecified schedule as in Regulatory Position 10.2.1.1 and within a prescribed schedule as in Regulatory Positions 10.2.3 and 10.2.4, and no attempt is made to load.
17.2.3.
Diesel Generator Load-Run Criteria Load-run demands are those demands for which the diesel generator is started, attains rated voltage and frequency within a prespecified schedule as in Regulatory Position 10.2.1.1 and within a prescribed schedule as in l
Regulatory Positions 10.2.3 and and 10.2.4, and is loaded to at least 50 percent l
of continuous rating and continued operation for at least one hour. A load-run demand on the diesel generator may be inadvertent, actual, or test, and it may be by automatic or manual initiation. A load-run failure should be counted when the engine successfully starts but does not pick up the load and run suc-cessfully for at least one hour.
17.3.
Reliability Records A reliability record saould be maintained at all plants for each diesel generator using data recorded in accordance with Regulatory Position 16.1.
It should include the number of failures in the last 20, 50, and 100 valid demands and indicate the time history for these failures. The criteria for determining the reliability of the diesel generator are as follows:
17.3.1.
Valid demands and failures should be determined in accordance with Regulatory Position 14.
17.3.2.
The reliability of the diesel generator should be calculated in accordance with Regulatory Position 17.2.1 based on the number of failures in the last 20, 50, and 100 valid demands.
21
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4 1
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- 18. Diesel Generator Reliability Program j:
An acceptable reliability program should be designed to attain and maintain f
the reliability level of each diesel generator unit over time for assurance j
that the specified reliability levels (for design basis accidents and station i
blackout) are being achieved. A reliability program should be comprised of, l
but not limited to, the following principal elements.
(Theseelementsalso l
supplement Regulatory Guide 1.155, " Station Blackout," Regulatory Position 1.2.)
j
)i 18.1.
Diesel Generator Reliability Target 1
i i
j The diesel generator reliability target will be derived from'the guide-lines provided in Regulatory Guide 1.155. These guidelines establish diesel j
generator reliability levels of 0.95 or 0.975. The diesel generator reliability program will key on minimum reliability targets; all diesel generator failures l
i should be acted upon without dependence on either achieved reliability levels or target reliability levels. The diesel generator reliability can serve as an i
indicator of how well.a plant's diesels are prepared to cope with a loss of offsite power and design basis accidents. The following issues should be con-l sidered to define the diesel generator reliability target and to measure the I
achieved diesel generator reliability.
i
)
18.1.1.
The diesel generator load-run time should be in accord-ante with Regulatory Position 17.2.3.
l e
i 18.1.2.
Bot'n failures to start and failures to run are to be 3
included in the calculation of diesel generator reliability.
l 18.1.3.
The reliability of the diesel generator should be cal-j culated according to Regulatory Position 17.2.1.
18.1.4.
Criteria for determining the number of failures and
]
valid tests should be in accordance with Regulatory Position 14.
1 In order to determine if the diesel generators are performing satis-factorily and meeting the targets established in Regulatory Guide 1.155, the 22
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progression of failures as well as the overall failure history should be used l
to judge the acceptability of diesel generator performance. The diesel gen-erator reliability alert levels (barad on the past failure history and recent failure history) should be established related to the diesel generator reli-4 f
ability target to ensure the reliability program is working and is adequate l
to achieve the target reliability.
I 18.2.
Diesel Generator Surveillance Needs i
A diesel generator reliability program should specify a task for analyzing the surveillance needs of this equipment. This diesel generator sur-l veillance should provide measurement and assurance that the diesel generator reliability target is being achieved. The surveillance needs of the diesel j
generator system should be assessed so that, in the long term, the diesel gen-erator goal will be met.
i 1
Surveillance is defined to include all failure detection and in-plant reliability information-gathering activities and condition monitoring. The
)
surveillance strategy for the diesel generators should be a result of an analysis of diesel generator surveillance needs. This analysis should be systematically performed and the resultant surveillance needs periodically evaluated.
The diesel generator equipment boundary should be explicitly defined so that all subsystems or parts considered part of the diesel generator system i
will be assessed as to their surveillance needs. The subsystems to be associated
)
with the diesel generator are those whose sole function is related to diesel generator operability.
For instance, a diesel generator may require service 4
water for operability, but only those service water components and parts whose function is solely to support the diesel generator should be included in the diesel generator boundary.
4 Analysis is required to ensure that surveillance of diesel generators addresses a minimum set of criteria for acceptable surveillance. The analysis should result in a documented surveillance plan. The surveillance plan should s
specify components and operating parameters to be surveyed and the rationale 23
l l'
i for the specified plan. The surveillance plan should define the parameters to l
be monitored, the types of surveillance to be employed, the intervals for each j
type of surveillance, and other considerations such as test staggering. The i
i considerations that should be addressed to provide acceptable diesel generator surveillance are:
j 18.2.1.
All critical diesel generator failure modes should be
{
covered in the surveillance plan. Critical failure modes are failure modes j
that would prevent the diesel generator from providing emergency ac power.
j 18.2.2.
The analysis should identify engineering conditions i
that are precursors to critical failure modes and suggest surveillance methods i
j (e.g., condition monitoring) to detect those conditions in a timely fashion.
i j
i 18.2.3.
The analysis should identify likely standby diesel 4-
)
generator aging mechanisms, identify surveillance methods to detect them, and
{
establish a method of trend analysis to determine the significance of each aging mechanism in regard to incipient failure.
1 18.2.4 The analysis should emphasize consideration of common cause failure mechanisms that could fail more than one diesel generator at a site and identify surveillance ts protect against these failures.
l i
18.2.5.
Diesel generator repair outages can result from off-j normal conditions or failures that are caused by stress on the diesel from 4
starting and running. Failures can also result from mechanisms that operate on j
the diesel generator while it is in standby. The failure analysis should evaluate both types of stresses.
18.2.6.
Justification based on engineering, human, or relia-
)
bility considerations should be given as to why the surveillance types were chosen and why they are sufficient to achieve the reliability target.
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i 18.3.
Diesel Generator Performance Monitoring 4
A diesel generator reliability program should specify how to monitor l
diesel generator performance with time, using both statistical trending and engineering data, to spot degradation (of components or the diesel generator) in performance. The reliability program should contain provisions for tracking l
diesel generator performance, using the results of successive surveillances.
In this way, trends in aging, reliability, and operability and the related f
4 l
engineering conditions can be observed. This performance tracking aspect of an acceptable diesel generator reliability program will provide the basis for j
i detecting deteriorating diesel generator performance and instituting corrective l
actions before the performance becomes unacceptable (i.e., before the diesel j
generator reliability falls below the target value).
j Performance monitoring includes two types of monitoring activities:
l condition monitoring and reliability monitoring. Condition monitoring refers j
to means by which the state of a component, subsystem, piece part, or engineer-l ing condition is tracked over time or use and includes the criteria for alerting when abnormal conditions or trends are observed.
Examples of condition monitor-ing for diesel generators are tracking lube oil pressure or crank case pressure l
and temperature, measurement of moisture content in starting air systems, track-j ing water jacket outlet temperature while the diesel generator is running, and i
periodically measuring electrical contacts to detect and track corrosion or f
burning. Reliability monitoring for diesel generators refers to the tracking of component, subsystem, or piece part failures or repairs with the objective
{
of providing an alert when the failure / repair frequency, or trends in frequency, i
indicate a deteriorating condition. Examples of diesel generator reliability monitoring include direct tracking of repair frequency, tracking of repair l
frequency for failures of specific types (e.g., by distinguishing among failure j
severities or failure causes), and tracking repair or failure frequencies of -
diesel generator subsystems such as the governor or automatic actuation system.
Whereas condition monitoring is primarily an engineering activity, reliability monitoring is primarily a statistical activity.
i 25
l l
The performance monitoring aspei.t of the reliability program provides the necessary information on diesel generator performance to trigger preventive maintenance actions. An acceptable diesel generator reliability program will contain adequate provisions for performance monitoring. These " adequate provi-sions" are addressed below in terms of the characteristics that the performance monitoring portion of a diesel generator reliability program should have as a j
minimum.
18.3.1.
The reliability information necessary to tiack diesel performance should be identified and correlated to the proposed surveillance.
This is to ensure that the proposed surveillance will provide all the reliability information necessary to track diesel generator performance.
18.3.2.
All performance monitoring computations required to obtain diesel generator information (i.e., physical condition data) and repair outages or failures should be explicitly defined.
18.3.3.
Alert levels that signal possible diesel generator degradation should be defined for each engineering and statistical parameter used for the diesel generator performance monitoring program. The alert levels should be chosen to minimize false alarms but should be sufficiently sensitive I
j to detect problems.
l 18.4.
Diesel Generator Maintenance Program l
l A diesel generator reliability program should include a documented maintenance policy that clearly exhibits a reliability focus. Maintenance actions should be driven by surveillance and performance monitoring results.
All required elements of a maintenance program should exist to some extent in an existing plant maintenance program. However, to be an effective part of a diesel generator reliability program, diesel generator maintenance should be based on reliability considerations and actively interface with the other ele-1 ments of the reliability program. The maintenance policy is needed for a sat-I isfactory preventive maintenance program, an acceptable spare parts inventory, correctly prioritized responses to problems, and the input of needed i
26
B data for other review items such as failure analysis and root cause investig-ations.
In order for a maintenance program to function as an effective part i
of a nuclear power plant diesel generator reliability program, it should include the following elements:
18.4.1.
A distinction and prioritization in the treatment of failures or conditions that result in, or could proceed to, catastrophic fail-ure (sudden and complete cessation of one or more component functions) of the I
diesel generator versus those that do not.
18.4.2.
A distinction and prioritization in treatment of those repair or maintenance actions that result in disabling the diesel generator versus those that do not.
18.4.3.
A recognition that preventive maintenance actions can be triggered on either time (using failure mode mean time between failures as a guide) or cc..ditions observed during surveillance.
18.4.4.
A recognition that disabling repair times for noncata-strophic diesel generator failures or conditions, compared to the repair times and outage times for the catastrophic failures that could result from these conditions if the noncatastrophic conditions are not repaired, are an important element in the maintenance policy.
18.4.5.
A recognition that the maintenance policy is driven by j
the target reliability of the diesel generator.
18.4.6..A recognition that the spare parts policy should include-a consideration of both the frequency with which the. spare part is needed and the downtime necessary to complete the repair with and without the spare part.
on hand.
The purpose of preventive maintenance is to reduce the number of cat-astrophic failures and to reduce the long-term degradations' caused by aging
-27.
j J
- t.
i j
and wearing out. The preventive maintenance tasks should be determined based on systematic consideration of subsystem and component functions, failure modes, and priority-based consideration of safety and reliability to identify appli-cable and effective preventive maintenance.
I The key to the success of the maintenance program lies in successful interfaces with the other reliability program elements. One of the key func-tions of a reliability program is to deal with problems, failures, and other off-normal conditions so that they do not recur or lead to catastrophic emer-gency diesel generator failures.
18.5. Diesel Generator Failure Analysis and Root Cause Investigation A diesel generator reliability program should contain a structured approach to. systematically reduce identified diesel generator problems to cor-1 rectable causes. Substantial long-term benefits can be derived from the iden-tification of the root causes of problems and the development of solutions that either eliminate these causes or minimize their impact. Therefore, system-atically eliminating the root causes of problems will improve diesel generator reliability.
l l
Diesel generator problems requiring investigation and correction can be of several types. They include catastrophic failures, unsatisfactory condi-1 tions detected through surveillance or monitoring, or damage and other physical conditions found during maintenance work.
The investigation of these diesel generator problems can be carried i
out to various levels that, in most cases, are not clearly separated.
In order to show a progression in the degree of detail, a distinction is.made whenever possible between failure analysis, which covers the entire range, and its sub-set, root cause analysis.
Failure analysis starts from the most apparent symp-toms and progresses to the determination of the underlying failure or incipient condition. The root cause analysis attempts to find the cause or causes of the underlying failure or incipient condition that could be related to design or a procedure used in operation or maintenance.
l 28 i
I.
t j
In general, the likelihood of performing a successful analysis is increased by the availability of a large amount of meaningful data. The quality j
I of these data and the manner of their retrieval are critical to their usefulness.
j A root cause investigation should be conducted very methodically since the root j
may be several levels below the visible symptoms, or there may be several syn-j ergistic causes, some more dominant than others, i
The diesel generator reliability program should contain a structured j
approach for systematically reducing identified diesel generator problems to j
correctable causes. An example top-level structured approach is shown in Figure 1.
This structured approach involves the following steps:
j 18.5.1.
Use a failure cause analysis to determine the proximate l
cause of the failure. The proximate cause is expressed as a description of the piece part failure cause, e.g., " relay xx failed to transfer due to corroded i
contacts."
I l
18.5.2.
Compare the proximate cause to past failures or condi-l tions on the same and other diesel generators to determine if the problem i
appears to have a systematic root cause, e.g., corroded contacts could be l
caused by an environmental mechanism.
j 18.5.3.
If no systematic root cause is indicated, continue i
diesel generator operations as usual, including diesel generator performance f
monitoring.
If a systematic root cause is indicated, begin a structured root cause investigation.
I j
18.5.4.
Determine if the problem is generic or plant-specific l
by reviewing the Nuclear Plant Reliability Data System (NPRDS) and other data l
and analyses for similar problem symptoms, or through contact with other utilities or industry groups.
J i
18.5.5.
If the detected reliability problem is generic, contact other plants that have had the problem to determine what corrective actions, if 4
any, have proved effective.
If an effective corrective action has been de-vised, implement it and proceed to the problem closeout portion of the emer-i gency diesel generator reliability program.
If not, proceed to the next step.
}
-j.
29
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T Performance 9F Foilure or off normal condition observed ir ProMem Oosecut Determine proximate cause
^55'55 if (foilure cause onofysis) surveillonce or performance monitoring should be ottered ir Compere to post l
follures/ conditions g
to indicate possible systematic cause No systematic ecuse Systematic couse 3,
Perform root cause anotysis
+
Generic or Generic cause Review other plant A 9eneric records (NPRDS).
plant specific
' cure exists?
ccuse?
industry groups, etc.
Pioni No l
Specific Yes Couse o Y
1r Determine if Redew operationoi opemtion or imp ement procedures, instal!
-W demgn-related specio! monitoring cause if required Design Operational Related Reloted i
Redesign to Change W Jons to correct problem correct pr;olem ir i r FIGURE 1 Systematic Root Cause Approach 30
r Wonitor EDG (
performance
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Toilure or off normal condition observeda L
f Probkm Oosecu_t r
Assess sf Determire proximate cause surveillonce or (follure cause ono%s) performance monitority
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should be oftered ir a
u Compare to pcst
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feitures/ conditions to indicate possiNe systematic causeJ L
No systematic cause y
Systemotic cause 37 i
r Perform root cause onelysis i
r_
Generic coute r
Ger>eric or A genede y
Review other pront plant specific cure exists?
records (NPRDS),
cmuse?
industry groups, sic.
No j
Plant' Y'8 u
Specife L
Couse_'t sr r
7 Determine if implement
- Redew operational YO"~Of O
y procedures, insioD design 4aloted speciot monitodng cause J
a if required L
Operational a
L Design Related
-y Related m
Chonge opertfjons 7
Redesign to to correct proNem correct problem i
a i
o
't T
Systerstic Root Cause Approach FIGURE 1 30
i Wonitor EDG J
j 1
Performance 7 I
3r l
Foilure or off normal condition observed 3
5 1
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1r i
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j j
Determine proximate cause Probkm Dosecut l
(foHure cause onelysis)
Assess if surveihonce or performance mordtoring 1 r should be ottered 1
1
{
Compare to post
{
follures/ conditions J [
to indicate possible j
systematic cause j
Systematic cause No systematic cause 3,
m i
{
Perform root couse onelysis
+
4
{
Review other plont Generic or Generic cause records (NPRDS),
plant specific A generic r
j industry groups, etc.
cause?
' cure exists?
j Plant No l
i Specific Couse i r i
Yes i
1 r Review operational Mermine if
)
procedures, insion g
operation-or I
specio! monitoring desgn-related implement j
if required cause i
Design Operot'enot
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Related Related V
Redesign to Change operations correct problem to correct problem i
i f 1 r FIGURE 1 Systesatic Root Cause Approach 30
-w,r-e-
we w.
18.5.6.
If the detected reliability problem is plant-specific, determine if the cause is related to the system's unique design or to
~
operational aspects such as test or maintenance. This can be done by special monitoring during testing, review of operational procedures, or engineering design review.
18.5.7.
If the reliability problem is determined to be design-related, determine the particular design deficiency (perhaps through special condition monitoring) and redesign or specify other corrective action.
18.5.8.
If the reliability problem is related to faulty opera-tions, identify and correct the specific procedures that are the root cause of the problem.
18.5.9.
When the root cause has been identified and corrective action implemented, proceed to the problem closecut item of the diesel generator reliability program.
18.6.
Problem Closeout A diesel generator reliability program should have a formal problem closecut procedure that will be used for closing out diesel generator reliability problems. The purpose of formal problem closeout procedures is to ensure that effective solutions to detected diesel generator reliability problems have been devised and implemented in a timely manner.
An effective solution is one that corrects the observed diesel generator reliability problem and does not create any other reliability or performance problems. The problem closecut review item should ensure that consideration is given in the diesel generator reli-ability program to providing for any additional monitoring or surveillance that would expedite the assessment of corrective action effectiveness.
Two elements are nc :essary for an effective problem closeout procedure:
18.6.1.
The problem closeout procedure should establish specific criteria that have to be met before the detected reliability problem will be considered to be corrected. The actual criteria should be based on the nature of the reliability problem and cannot be specified beforehand.
31
i 18.6.2.
The problem closecut procedure should provide for any additional monitoring activity that might be necessary to provide a timely 3
judgment concerning the effectiveness of the corrective action. Again, the
]
additional monitoring used, if any, should be based on the characteristics of the detected problem and cannot be specified beforehand.
3 This item should be coordinated with the review conducted to ensure adequate management of the diesel generator reliability program (Item 8) if the closeout procedures are to involve a problem closecut committee. This problem j
closecut committee will be part of the management team for the reliability pro-gram. Assurance should be obtained that the committee members have adequate background and authority to act in this capacity.
~
18.7.
Data Collection and Utilization A diesel generator program should have a data gathering, storage, and i
retrieval system as described in Regulatory Postion 16.1 with sufficient cap-abilities to support all features of the reliability program tasks. A definitive
]
and aggregate set of information is required to properly address the reliability and availability issues associated with the reliability program. The data set j
should support the assessment of the specified goals and targets. The data set should also support the combined elements of the reliability program. Operating 2
hours, number of demands, number of failures, outage times, repair times, and other necessary information should be included in this element. The data j
should be kept until either the diesel generator is replaced or the plant is decommissioned.
Data storage and retrieval may be performed on a computer or may be 3
performed manually.
In either case, an organized system should be available or be developed. This may be accomplished in several ways, for example, by using a capable, readily available data base management system on a computer or by setting up and maintaining an adequate file system for manual data storage and retrieval.
i I
e 32
3 i
i i
1 It is not necessary to duplicate and store all information in one specified location. However, all information (e.g., maintenance work orders, j
completed test procedures, vendor manuals) should be stored in a systematic and i
easily accessible method. For example, vendor material and test procedures may easily be obtained in a well-organized plant library, while copies of completed test procedures may be available in a well-organized plant document room.
i i
l The diesel generator data collection system should contain the record-keeping requirements of Regulatory Position 16 and the following operational 7'
and maintenance data:
i 18.7.1.
Store the time of _ detection, times when repair was-j initiated and completed, and restoration time of the equipment for each diesel generator repair action.
l 18.7.2.
Store a description of the root cause or condition that t
l led to repair and the method by which it was detected.
i j
18.7.3.
Store in a retrievable way all the information identi-fied in all of the above-stated reliability program elements.
In addition to the identified information, the data gathering, stor-j age, and retrieval system should contain operating experience information on l
similar diesel generators as provided through NPRDS, Part 21 reports, 50.55(c) l reports, licensee event reports, consultants, and especially diesel generator i
manufacturersandtheirsuppliers(e.g.,governorvendors). This information j
would be used to supplement data on plant experiences and as a basis for cor-rective actions to preclude problems experienced by other diesel generator owners. Diesel generator vendor correspondence and recommendations and updated i
operation test and maintenance procedures should also be stored in support of
]
the reliability program.
}
33 I
1 1.
1 1
s.
j The diesel generator data system is the primary repository for the l
information required by the NRC to evaluate diesel generator performance.
I Therefore, all information identified as necessary to evaluate diesel generator j
performance should be collected and stored by this system. The diesel generator j
documentation describing the proposed reliability program should identify this j
I l
information explicitly and present a plausible description of the techniques to be used to collect and store it.
j I
18.8.
Responsibilities and Management Controls 4
i I
j A diesel generator reliability program should have clear line j
j responsibilities and management controls in place that identify responsible i
individuals for implementing and operating the diesel generator reliability pro-j gram, and the program should ensure that these individuals are qualified to i
perform the functions for which they are responsible.
j i
I A diesel generator reliability program is a management system for j
)
managing diesel generator reliability. The rules and procedures that flow from the management system are all based on a consistent philosophy, which states j
l that a specified reliability target can be achieved by understanding the factors l
that drive a diesel generator's reliability and then applying reliability and
]
f engineering techniques in sufficient depth to ensure that the target is reached.
i l
Management reviews and controls are necessary to ensure that the diesel l
generator reliability program results in achieving the reliability target for l
the diesel generators. Also, individuals responsible for implementing and operating the reliability program should be identified. These individuals should be qualified or suitably trained to carry out their assigned responsibilities.
3 j
Achievement of the diesel generator reliability target depends on there being
]
adequate management review and controls of the reliability program, as well as j
qualified individuals responsible for implementing and operating the program
.j who have the authority to manage the program to achieve the target. Even though consultants and vendors may assist the utility in implementing the diesel gen-erator reliability program, the plant management retains the ultimate responsi-bility and is the key to the program's success.
i 34
.l
~ ~ ~ _
included in this item:
The following considerations should be t the diesel A procedure and schedule for verifying tha 18.8.1.
i met.
generator relidbility targets are be ng diesel genera-An identified mechanism for altering the 18.8.2 it become necessary, tor reliability program should will implement h
Identification of qualified personnel w oPe 18.8.3.
and maintain the reliability program. design, reliability methodology diesel operation, maintenance, diesel implementation of reliability programs.
ent to implement A comitment on the part of plant managem 18.8.4.
ility program.
and maintain a diesel generator reliab liability Detailed reviews of the diesel generator re the plant management.
18.8.5.
program performed periodically by the l mentation Full support by plant management of the imp e 18.8.6.
liability program.
and operation of the diesel generator re IMPLEMENTATION D.
information to applicants The purpose of this section is to providethis regulatory guide.
regarding the NRC staff's plans for using courage public participation This proposed revision has been released to en licensee Except in those cases in which an appl in its development.
proposes an acceptable alternative met o the guidance to be portions of the Comission's regulations, ill be used in the evalu active guide reflecting public comments w 35
~
l
- The following considerations should be included in this item:
l 18.8.1.
A procedure and schedule for verifying that the diesel generator reliability targets are being met.
18.8.2.
An identified mechanism for altering the diesel genera-tor reliability program should it become necessary.
18.8.3.
Identification of quelified personnel who will implement and maintain the reliability program. Personnel qualifications should include diesel operation, maintenance, diesel design, reliability methodology, and implementation of reliability programs.
18.8.4 A commitment on the part of plant management to implement and maintain a diesel generator reliability program.
18.8.5.
Detailed reviews of the diesel generator reliability program performed periodically by the the plant management.
18.8.6.
Full support by plant management of the implementation and operation of the diesel generator reliability program.
D.
IMPLEMENTATION The purpose of this section is to provide information to applicants regarding the NRC staff's plans for using this regulatory guide.
This proposed revision has been released to encourage public participation l
in its development. Except in those cases in which an applicant or licensee i
proposes an acceptable alternative method for complying with the specified portions of the Commission's regulations, the guidance to be described in the active guide reflecting public comments will be used in the evaluation of 35 i
gno-,a----
,g g---wegg 9
y g p +i*+ -
g-tim v
9 selection, design, qualification, testing, and reliability programs for diesel generator units used as onsite electric power systems for the following nuclear power plants:
1.
Plants for which the construction permit is issued after the issue date of the final guide, 2.
Plants for which the operating license application is docketed 6 months or more after the issue date of the final guide, 3.
All operating plants that have been issued an operating license at the issue date of the final guide.
i i
l 36
REGULATORY AN LYSIS A separate regulatory analysis was not prepared for this regulatory guide.
The regulatory analysis prepared for the station blackout rule, NUREG-1109,
" Regulatory /Backfit Analysis for the Resolution of Unresolved Safety Issue A-44, Station Blackout," provides the regulatory basis for this guide and examines the costs and benefits of the rule as implemented by the guide.
A copy of NUREG-1109 is available for inspection and copying for a fee at the llRC Public Document Room, 2120 L Street NW., Washington, DC. Copies of NUREG-1109 may be purchased from the Superintendent of Documents, U.S. Government e
Printing Office, Post Office Box 37082, Washington, DC 20013-7802; or from the National Technical Information Service, Springfield, VA 22161.
37
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UNITED STATES
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NUCl.E AR RElOL ATORY COMMISSION y
.VASWNG TON. D. C. 20555
, - e.
N..~.e/
October 5,1988 MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations FROM:
Edward L. Jordan, Chairman l
Committee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 146 i
l The Committee to Review Generic Requirements (CRGR) met on Wednesday, September 14, 1988 from 1-5 p.m.
A list of attendees for this meeting is attached (Enclosure 1).
The following items were addressed at the meeting:
1.
J. Zwolinski (NRR) and D. Morisseau (NRR) presented for CRGR review a proposed Commission Policy Statement on Nuclear Power Plant Working Hours.
The Committee recommended in favor of forwarding the proposed policy statement to the Commission subsequent to several modifications that are to be coordinated with the CRGR staff.
This matter is discussed in Enclosure 2.
l 2.
A. Serkiz (RES) and F. Rosa (NRR) presented for follow up CRGR review a draft Reg. Guide 1.9, Rev. 3, " Selection, Design, Qualification, Testing and Reliability of Diesel Generator Units Used as Onsite Electric Power i
Systems at Nuclear Power Plants." The Committee recommended in favor of l
issuing the proposed Reg. Guide for public comment subject to resolution l
of the remaining CRGR recommendations that are to be coordinated with the i
CRGR staff.
This matter is discussed in Enclosure 3.
3.
B. Morris (RES) and T. King (RES) presented for CRGR review a proposed
}
rule on maintenance.
The Committee recommended in favor of forwarding the prcposed rule to the Commission subject to incorporation of minor l
clarifications that are to be coordinated with the CRGR staff.
This matter is discussed in Enclosure 4.
In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure of CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes.
The response, which is required within five working days after receipt of these minutes, is to be forwarded to the CRGR Chairman and if there is disagreement with CRGR recommendations, to the EDO for d,ecisionmaking.
l
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2-Questions concerning these meeting minutes should be referred to Cheryl Sakenas (492-4148).
l
/
'a r Le an, Chairman Committ(etoReviewGeneric Requi
.ents
Enclosures:
As stated cc w/ enclosures:
Commission (5)
SECY Office Directors Regional Administrators CRGR Members W. Parler J. Zwolinski D. Morisseau A. Serkiz F. Rosa B. Morris T. King 9
.i
4
^
1 1
ATTENDANCE LIST CRGR MEETING NO 146 i
j September 14, 1988 l
I i
2 CRGR t
]
E. Jordan J. Goldberg i
C. Paperiello R. Bernero j
J. Sniezek
}
D. Ross i
j NRC STAFF i
J. Conran j
C. Sakenas J. Persensky 1
D. Morisseau W. Regan
}
J. Zwolinski j
D. Tondi
}
P. Norian l
W. Minners F. Rosa A. Serkiz 1
M. El-Zeftawy l
G. Mizuno j
E. McKenna i
J. Jankovich j
R. Frahm B. Richter i
B. Morris M. Dey M. Taylor 3
T. King i
i 5
)
i 1
i:
i 1
4 C.
l w s to the Minutes of CRGR Meeting No. 146 Proposed Policy Statement on Work Hours TOPIC J. Zwolinski (NRR) and D. Morisseau (NRR) presented for CRGR review a proposed Commission Policy Statement on Nuclear Power Plant Working Hours. This revised policy statement is intended to clarify and update the NRC's current j
policy regarding shift schedules and evertime and provides guidance for overtime beyond 7 days and addresses 12-hour shifts.. A copy of the briefing slides used by the staff is attached.
BACKGROUND The package submitted by the staff for review by CRGR in this matter was transmitted by memorandum dated August 30, 1988, J. H. Sniezek to E. L. Jordan and contained the following documents:
1.
Proposed Policy Statement 2.
Draft Regulatory Analysis CONCLUSIONS / RECOMMENDATIONS
)
The Committee discussed the proposed policy statement with the staff and made the following recommendations:
1 1.
The policy statement as written includes limits on work hours for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, 7 days, 14 days, 28 days and 365 days. The Committee i
stated that this seems redundant and overly complex and may be an administrative burden on supervisors. The Committee recommended reviewing these limits for areas where they can be simplified and still meet the intent of limiting overtime.
2.
The Committee questioned whether this may require discussion with the appropriate trade unions if the policy statement impacts them.
3.
The Committee questioned whether this should be incorporated into rulemaking but also recommended. hat the policy statement be issued in the interim.
4.
The Committee discussed the scope of the policy statement and recommended d
that it be broader to address all individuals assigned to work within the protected area, with the exception of administrative personnel.
As a result of their review of this matter, including discussions with the staff at this meeting, the Committee recommended in favor of forwarding the proposed policy statement to the Commission subject to incorporation of the preceding comments.
I
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m n, na I
1 I
1 2
I i
B-56 RESOLUTION 1
l R.G.1.9, Rev. 3 (Proposed) 1 Issuance for Public Comment 3
i 4
1 i
j CRGR Meeting 146 l
9-14-88 l
I RES/DSIR NRR/SELB i,
i l
4 i
I i
i i
i i
B-56 OBJECTIVES
\\
i
- 1. Resolve outstanding CRGR questions.
4 i
- 2. Obtain CRGR concurrence to issue l
RG 1.9, Rev. 3 FOR COMMENT.
i
- 3. Issue FOR COMMENT and initiate l
d.iscussions with NUMARC's B-56
" Working Group".
i i
i i
l i
l I
I 3
4 a
1 i
~
i i
RECENT ACTIONS
l 144; revised copy has been provided i
to the CRGR.
i
~
- 2. FRN has been modified to direct l
review attention to:
l a) Pre-Operational and Scheduled l
EDG testing, particularly accelerated testing.
b) Record keeping and reporting requirements.
l c) EDG reliability program guidance.
l l
4 i
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ff $ M,?,
1, Whs[
4 UNITED STATES p
g V NUCLEAR REGUL ATORY COMMIS-.JN g
n AsecTon. o c. zosss
's,
,/
August 26, 1988 y g,
&D (o MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations l
FROM:
Edward L. Jordan, Chainnan Committee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 144 The Comittee to Review Generic Requirements (CRGR) met on Wednesday, August 10,1988 from 1-5 p.m. and on August 16, 1988 from 12:30-2:00 p.m.
A list of attendees for this meeting is attached (Enclosure 1).
The following items were addressed at the meeting:
i 1.
G. Arlotto (RES) and S. Aggarwal (RES) presented for CRGR review the Batteries for Nuclear Power Plants." proposed final Reg. Guide, " Qualification of Safety-R The Committee recommended issuing the final Reg. Guide subject to incorporation of several recomendations (to be reviewed by CRGR staff).
This matter is discussed in Enclosure 2.
2 A. Serkiz (RES) and F. Rosa (NRR) presented for CRGR review a proposed Rev. 3 to Reg. Guide 1.9, " Selection, Design, Qualification, Testing and Reliability of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants."
The Committee recommended revisions in several areas and rereview by CRGR prior to issuing the proposed resolution.
This matter is discussed in Enclosure 3 3.
A. Thadani (NRR), W. Hodges (NRR) and G. Thomas (NRR) presented for CRGR review a proposed NRC staff SER on the BWR Owner's Group Topical Report NED-31331, "BWR Owners' Group, Emergency Procedure Guidelines, Revision 4."
The Committee recommended issuing the proposed SER subject to incor-poration of several recomendations (to be reviewed by CRGR).
The Committee questioned whether this document presents policy issues which may require Comission review.
The two issues identified by the Committee involve the decision to vent containment in an accident and the line of authority to make that decision.
This matter is discussed in Enclosure 4 In accordance with the ED0's July 18,1983 directive concerning " Feedback and Closure of CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes.
receipt of these minutes, is to be forwarded to the CRGR Chainnan and is disagreement with CRGR recomendations, to the EDO for decisionmaking.
p cp'o g l 3I h(b
's nW J
v
Questions concerning these meeting minutes should be referred to Cheryl Sakenas (492-4148).
i 3
~~
(,/
r n Chairman C
ittee to Review Generic Requirements
Enclosures:
As stated cc w/ enclosures:
Commission (5) 1 SECY Office Directors Regional Administrators CRGR Members W. Parler G. Arlotto S. Aggarwal A. Serkiz F. Rosa A. Thadani W. Hodges G. Thomas W
4 4
4 i
j
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f%.-)pi h NUCLEAR REGULATORY COMMISo.JN M k[
</.
6 1
~
UNITED STATES p
( #
usectom o. c. 2osss
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j
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August 26, 1988
)
g g, bEO bM i
i MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations h
FROM:
Edward L. Jordan, Chaiman y
Committee to Review Generic Requirements j
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 144 I.
i i
l
\\
The Comittee to Review Generic Requirements (CRGR) met on Wednesday, i
August 10, 1988 from 1-5 p.m. and on August 16,1988 from 12:30-2:00 p.m.
A 4
list of attendees for this meeting is attached (Enclosure 1). The following' j
items were addressed at the meeting:
1.
G. Arlotto (RES) and S. Aggarwal (RES) presented for CRGR review the proposed final Reg. Guide, " Qualification of Safety-Related Lead Storage
.l 4
Batteries for Nuclear Power Plants." The Committee recommended issuing
{
the final Reg. Guide subject to incorporation of several recommendations j
(to be reviewed by CRGR staff). This matter is discussed in Enclosure 2.
i j
2.
A. Serkiz (RES) and F. Rosa (NRR) presented for CRGR review a proposed
)
Rev. 3 to Reg. Guide 1.9, " Selection, Design, Qualification, Testing and.
i Reliability of Diesel Generator Units Used as Onsite Electric Power-Systems at Nuclear Power Plants." The Comittee recommended revisions in 1
several areas and rereview by CRGR prior to issuing the proposed
}
resolution. This matter is discussed in Enclosure 3.
4 1
3.
A. Thadani (NRR), W. Hodges (NRR) and G. Thomas (NRR) presented for CRGR i
review a proposed NRC staff SER on the BWR Owner's Group Topical Report
)
i NED-31331, "BWR Owners' Group Emergency Procedure Guidelines, Revision 4."
The Committee recommended issuin poration of several recommendations (g the proposed SER subject to incor-i to be reviewed by CRGR).
The Committee questioned whether this document presents policy issues which may require Comission review. The two issues identified by the Committee involve the decision to vent containment in an accident and the line of authority to make that decision. This matter is discussed in Enclosure 4 i
i In accordance with the ED0's July 18, 1983 directive concerning " Feedback and j
Closure of CRGR Reviews," a written response is required from the cognizant i
office to report agreement or disagreement with the CRGR recommendations in i
these minutes. The response, which is required within five working days after j
receipt of these minutes, is to be forwarded to the CRGR Chairman and if there 1
is disagreement with CRGR recommendations,.to the E00 for decisionmaking.
ol N kb i
7to9 4
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-., -.,., ~ _. -...
~2-0 Questions concerning these meeting minutes should be referred to Cheryl Sakenas (492-4148).
(
l h
qr or an Chai rman C
.ittee to Review Generic Requirements
Enclosures:
As stated cc w/ enclosures:
Commission (5)
SECY Office Directors Regional Administrators CRGR Members W. Parler G. Arlotto S. Aggarwal A. Serkiz F. Rosa A. Thadani W. Hodges G. Thomas
(
h l
l l
l l
l l
i r
h ATTENDANCE LIST CRGR MEETING NO. 144 August 10, 1988 August 16, 1988
)
CRGR i
{'
E. Jordan E. Jordan J. Sniezek J. Sniezek j
R. Bernero i
R. Bernero J. Scinto (for J. Goldberg)
J. Scinto (for J. Goldberg)
C. Paperiello Z. Rosztoczy (for D. Ross)
Z. Rosztoczy (for D. Ross)
NRC STAFF NRC STAFF j
C. Sakenas J. Heltemes S. Aggarwal C. Sakenas F. Faulitz A. Thadani G. Arlotto W. Hodges F. Rosa C. Thomas
- 0. Chopra C. Tinkler J. Burns M. Taylor A. Serkiz S. Crockett K. Kniel W. Minners P. Norian B. Wilson E. Tourigny M. Taylor D. Houston L. Soffer A. Notafrancesco J. Kudrick L. Shao W. Hodges G. Thomas A. Thadani
i
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i
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i i
3 to the Minutes of CRGR Meeting No.144 i
i Proposed Regulatory Guide, " Qualification of Safety-Related i
Lead Storage Batteries"
{
}
i TOPIC l
G. Arlotto (RES and S. Aggarwal'(RES) presented for CRGR review a final proposed Regulatory Guide, " Qualification of Safety-Related Lead Storage Batteries."
The intent of this Reg. Guide is to describe a method acceptable-i to the NRC staff for complying with Comission regulations with regard to i
qualification of safety-related lead storage batteries for nuclear power.-
plants. This Reg. Guide was previously reviewed by the CRGR in proposed form
-l at Meeting No.113 and issued for public comment.
Only five comments were.
i received, and this revision inccrporates those comments. A copy of the j
briefing slides used by the sta- - in their presentation and discussion with j
the Committee at this meeting i
>ttached.
}
BACKGROUND 1
j The package submitted by the staff for review by CRGR in this matter was i
transmitted by memorandum dated July 20, 1988, E. S. Beckjord to E. L. Jordan; the package contained the following documents:
1.
Regulatory Guide EE 006-5, dated May 1988 1
2.
3.
Public coment letters j
4.
Resolution of Public Comments CONCLUSIONS / RECOMMENDATIONS 4
'j The Committee discussed the proposed Regulatory Guide with the staff and made l
the following recommendations:
i i
1.
In order to provide more flexibility and meet the intent of the guide, j
Regulatory Position 1.a should be modified to read " purchase orders" I
rather than "on hand" and in 1.b the 18-month period should be extended j
to the design life of the battery.
The staff agreed to make these
{
changes.
l 2.
A substantial s W ty finding should be made since this is a backfit.
1 1
As a result of their review of this matter, the Committee recommended in favor
}
of issuing the proposed Reg. Guide, subject to incorporation of the preceding comments.
}
4 4
. ~..
_