ML20045B171
| ML20045B171 | |
| Person / Time | |
|---|---|
| Issue date: | 04/05/1991 |
| From: | Carr, Carr K NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20042D089 | List:
|
| References | |
| FRN-57FR14514, REF-GTECI-B-56, REF-GTECI-EL, RULE-PR-50, TASK-B-56, TASK-OR AE06-1-051, AE6-1-51, VALB-910405, NUDOCS 9306160371 | |
| Download: ML20045B171 (2) | |
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NOTATION V0TE RESPONSE SHEET
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SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM:
CHAIRMAN CARR i
SUBJECT:
. RESOLUTION OF GENERIC SAFETY ISSUE B-56, " DIESEL GENERATOR RELIABILITY" hinpart lin part APPROVED
/commentBISAPPROVE
, w/commentsABSTAIN Nor PARTICIPATING REQUEST DISCUSSION
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C0fEENTS:
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SIGNATURE RELEASE VOTE
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WIDiHOLD VOTE
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ENTERED ON "AS" YES No
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61 371 930422 50 57FR14514 PDR,
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1 Revised notation vote of Chairman Carr on SECY-90-340,
" Resolution of Generic Safety Issue B-56,
' Diesel Generator Reliability'".
I approve in part and disapprove in part the staff's proposed actions in the subject SECY.
I approve of the staff's issuing a Regulatory Guide, subject to comments noted below.
I disapprove issuing the recommended Generic Letter requesting information i
pursuant to 10 CFR SO.54 (f) about licensees' voluntary implementation of NUMARC's initiative SA.
The staff should instead amend the appropriate section of Title 10 to require each licensee to have a program for monitoring and maintaining Emergency Diesel Generators (EDGs).
The staff should assure that the modification to the regulations contains adequate provisions for enforcement, or that adequate enforcement capability is already contained in existing regulations.
The Regulatory Guide should make clear that the monitoring and maintenance program discussed therein is only one valid, effective program and licensees with other effective programs can continue to use them, subject to concurrence by the staff.
It should be made absolutely clear that the trigger values referred to in the Regulatory Guide are arbitrary.
j I believe that it is necessary for the staff and the industry to have a common understanding of the program elements that would provide for monitoring and maintaining diesel generator reliability at the desired level and for actions to be taken to I
correct a deteriorating situation.
With the existing variability of Technical Specifications among the plants, with differing definitions of valid failures and with uneven monitoring and maintenance programs at the plants, providing this common understanding is imperative.
The incident at Vogtle, mentioned in SECY-90-340, is a case in point.
A problem existed for several years without the licensee's monitoring program leading to its discovery.
The failure of the diesels to operate when they were actually needed led to discovery of this longstanding problem.
The failures at Vogtle would still have not been classified as valid failures, but the trending part of a good maintenance program would have revealed the unsatisfactory situation.
i I am not persuaded that the suggested approach (COMJC-91-001A) of defining arbitrary trigger values, exceedance of which would indicate unsatisfactory performance of EDGs - but perhaps even more importantly would indicate gross failure of management at the plant - is appropriate in this case.
Where small numbers of tests per unit time are involved'and where it is imperative to have an acceptably small " false alarm" rate in order to avoid punative enforcement action where no fault actually exists, the l
time between the onset of degradation of EDG performance and the sure detection of it can be long.
During this time, the plant could be in a vulnerable position, where the underlying risk of
$.4R station blackout could have risen to unacceptable levels; the
' kfh requirement to have an effective monitoring and maintenance programshouldforestallthisundesirablecondition{}{
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COMJC-91-001A I
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& A-Comments and additions to my previous vote on SECY-90-340
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K.C. Rogers jg April 10, 1991 J
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Because I share Commissioner Curtiss's interest in non-prescriptive U * ' '/
regulation and in its possible application to resolving GSI B-56, Diesel Generator Reliability, I have followed his proposals very carefully.
He has made a good case for use of the trigger values approach he proposes, and I find it appealing.
However, I also share the Chairman's concern regarding the possibility of a plant falling into a station blackout vulnerable position during the time between onset of EDG degradation and its clear detection.
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requirement that an effective EDG monitoring and maintenance
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program be in place would provide needed assurance that serious undetected degradation of EDGs does not take place.
I therefore propose a non-prescriptive requirement (rule) that every licensee only have in place a program, for monitoring and maintaining emergency diesel generators, comprised of the elements i
described in a Regulatory Guide such as that provided as a draft in SECY-90-340.
With this addition, I support the approach, through rulemaking, proposed by Commissioner Curtiss and its focus on trigger values for enforcement as described in COMJC-91-001A, and the staff's iissuing a Regulatory Guide to accompany the Rule.
I disapprove the issuing a Generic Letter requesting information pursuant to 10 CFR 50.54(f) as proposed by the staff.
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