ML20045B151
| ML20045B151 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/1991 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Carr NRC COMMISSION (OCM) |
| Shared Package | |
| ML20042D089 | List:
|
| References | |
| FRN-57FR14514, REF-GTECI-B-56, REF-GTECI-EL, RULE-PR-50, TASK-B-56, TASK-OR AE06-1-049, AE6-1-49, NUDOCS 9306160349 | |
| Download: ML20045B151 (2) | |
Text
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u UNITED 5TATES Taylor 9
NUCLEAR REGULATORY COMMISSION Sniezek 5,%,,(*[ g
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May 17, 1991 Mat Taylor Beckjord Murley OFFICE OF THE COMMISSION E R MEMORANDUM FOR:
Chairman Carr FROM:
James R.
Curtiss vs M.
SUBJECT:
EMERGENCY DIESEL GENERATOR RELIABILITY As a result of our discussions earlier this week on the subject of emergency diesel generator (EDG) reliability, and upon reviewing the draft Staff Requirements Memorandum that you circulated, I understand that your principal concern with the approach that I have recommended in COMJC-91-001A is that the focus on overall EDG starts and failures will not capture certain important elements of EDG performance (e.a., the failure of calcon sensors at Vogtle).
In order to come to terms with the resolution of this issue, I i
believe that it is important to reach an understanding on certain basic factual issues, including the following:
1)
In the agency's approach to EDG testing to date, l
have we established a testing regime that is j
l comprehensive in nature, so that all aspects of the EDG that are necessary to ensure that it will perform its intended function when called upon are adequately tested under our testing regine?
In this regard, how have we defined the terms " start" and " failure"?
2)
Assumina that tests are conducted in accordance with the specified testina reaime, are there aspects of the EDG that are necessary to ensure that it will perform its intended function when called upon that will not be captured by the j
testing regime?
3)
For those specific aspects that are not captured l
by the testing regime, is there a results-oriented l
approach that would properly address such l
concerns?
If not, do we need to consider a programmatic solution to such concerns?
l I have directed Dave Trimble of my staff to get together with your staff for the purpose of focusing on the.above questions.
l Once these issues are addressed, I believe that we will be in a l
better position to move forward on this matter.
I 9306160349 930422 57 14514 PDR
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Commissioner Rogers Commissioner Remick SECY OGC EDO /
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SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM:
COMMISSIONER REMICK
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SUBJECT:
SECY-90-340 - RESOLUTION OF GENERIC SAFETY ISSUE-B-56, " DIESEL GENERATOR RELIABILITY" D ).LF 1,, f)nf-APPROVED K DISAPPROVED k ABSTAIN Nor PARTICIPATING REQUEST DISCUSSION COMMENTS:
See ah' l
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s V ' SIGNATURE RELEASE VOTE
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DATE
. WITHHOLD VOTE
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ENTERED ON "AS" YES No
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Commissioner Remick's revised vote sheet on SECY-90-340 and response to COMJC-91-001/A.
I approve in part and disapprove in part the staff's proposed actions in SECY-90-340.
I approve staff's issuing a Regulatory Guide on diesel generator reliability.
I disapprove staff using the 50.54(f) generic letter process as a means to impose new regulatory requirements by requesting licensees to commit to a reliability / maintenance program.
In regard to staff's March 29, 1991 response to Commissioner
. expectations that the Rogers' questions, staff states: "..
reliability targets will be met is provided by the licensee's commitment to a reliability program and to take corrective action after any failure."
That implies, in general, that licensees are not presently committed to a reliability program and are not committed to take corrective action after a failure to start a diesel generator.
According to staff, however, the handful of j
specific licensees who fall below their reliability targets appear to vary from year-to-year.
That, to me, implies that all l
licensees have a corrective diesel generator maintenance program which detects and corrects for any regulatory non-conformance.
In addition, staff has stated that there is no urgency to resolve this issue.
I am therefore not persuaded that as part of the resolution of the B-56 GSI the Commission must impose on licensees specific maintenance / corrective action requirements on their diesel generators.
It is my understanding from prior staff briefings that all but a handful of licensees have an acceptable maintenance program in place and that the few outliers are upgrading their pro' grams to meet industry's increasing maintenance standard.
I also note that the Commission will consider a maintenance rule in the near future.
I believe the Commission should consider the need for a maintenance rule in toto at that time and not on a system by l
system basis.
For the reasons set above, I am not persuaded that I
a 10 CFR 50.63 needs to address maintenance.
From discussions held in recent months, it has become clear that the Station Blackout Rule may be incomplete because it does not i
specifically state that licensees must maintain their diesel generator reliability target assumed in their station blackout coping analysis and does not require licensees to report when they fall below that target value.
I therefore acree with j
Commissioner Curtiss's recommendations, as set forth in COMJC-91-001, for a non-prescriptive rule to be issued for public I
Comment.
l
.