ML20046C674
| ML20046C674 | |
| Person / Time | |
|---|---|
| Issue date: | 08/11/1993 |
| From: | Marcus G Office of Nuclear Reactor Regulation |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308110339 | |
| Download: ML20046C674 (12) | |
Text
- 1 1
j# %%,
UNITED STATES e
't NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. N0001
\\...../
August 11, 1993 MEMORANDUM FOR:
Document Control Desk Document Management Branch Division of Information Support Services Office of Information Resources Management FROM:
Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation
SUBJECT:
DOCUMENTS ASSOCIATED WITH THE PROPOSED GENERIC LETTER REGARDING REMOVAL OF ACCELERATED TESTING AND SPECIAL REPORTING REQUIREMENTS FOR EMERGENCY DIESEL GENERATORS FROM PLANT TECHNICAL SPECIFICATIONS The Electrical Engineering Branch and Technical Specifications Branch have prepared the subject draft generic letter.
The Committee to Review Generic Requirements (CRGR) has reviewed and endorsed this draft generic letter. The generic letter language concerns of the Office of ED0 and the CRGR have been resolved in this draft generic letter. The Generic Communications Branch (0GCB) is preparing to publish the draft generic letter in the f_ederal Reaister for public comment. This memorandum provides a compilation of the background material relevant to the subject generic letter that should be made available to the public.
By copy of this memorandum we are providing the enclosed documents to the Public Document Room. The enclosures are the draft generic letter as approved by the CRGR, and the CRGR Review Package.
We request that you provide us with the Nuclear Documents System accession number for this memorandum. This information can be provided to the listed contact by telephone or by E-Mail.
$YMM Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation
Enclosures:
As Stated CONTACT: Nancy E. Campbell, NRR 504-2836 1
0 9308110339 930811 V
PDR ORG NRRB
'\\
[
i
. MEMORANDUM FOR:
Document Control Desk Document Management Branch' Division of Information Support Services Office of Information Resources Management FROM:
Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation
SUBJECT:
DOCUMENTS ASSOCIATED WITH THE PROPOSED GENERIC LETTER REGARDING REMOVAL 0F ACCELERATED TESTING AND SPECIAL REPORTING REQUIREMENTS FOR EMERGENCY DIESEL GENERATORS FROM PLANT TECHNICAL SPECIFICATIONS The Electrical Engineering Branch and Technical Specifications Branch have prepared the subject draft generic letter. The Committee to Review Generic Requirements (CRGR) has reviewed and endorsed this draft generic letter.
The generic letter language concerns of the Office of ED0 and the CRGR have been resolved in this draft generic letter. The Generic Communications Branch (0GCB) is preparing to publish the draft generic letter in the Federal Reaister for public comment.
This memorandum provides a compilation of the background material relevant to the subject generic letter that should be made available to the public.
By copy of this memorandum we are providing the enclosed documents to the Public Document Room. The enclosures are the draft generic letter as approved by the CRGR, and the CRGR Review Package.
We request that you provide us with the Nuclear Documents System accession number for this memorandum. This information can be provided to the listed contact in person, by' telephone, or by E-Mail.
Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation
Enclosures:
As Stated CONTACT: Nancy E. Campbell, NRR 504-2836 Distribution w/
Enclosures:
NCampbell, NRR OGCB R/F JConran, AE0D Central Files PDR Distribution w/o
Enclosures:
BK Grimes, NRR GHMarcus, NRR Achaffee, NRR CGrimes. NRR SWeiss, NRR 0Chopra, NRR WReckley, NRR TDunning, NRR NCampbell, NRR DORS R/F OGCB R/F DOCUMENT NAME:
GLEDGTEA.NEC OGCB: DORS:NRR C/0GCB: DORS:N,Rf NECampbell GHMarcusdit/D 08/#/93 fc.
08/11/93
Enclosure
.,p.
x4 e
.e
$ i
- E UNITED STATES li I
NUCLEAR REGULATORY COMMISSION 8
WASHINGTON, D.C. 20555 0001
\\.....j T0:
ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS
SUBJECT:
REMOVAL OF ACCELERATED TESTING AND SPECIAL REPORTING REQUIREMENTS FOR EMERGENCY DIESEL GENERATORS FROM PLANT TECHNICAL SPECIFICATIONS (GENERIC LETTER 93
_)
The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to advise licensees that they may request a license amendment to remove accelerated testing and special reporting requirements for emergency diesel generators (EDGs) from plant technical specifications (TS).
The NRC developed this line-item TS improvement in response to the Commission decision on SECY-93-044, " Resolution of Generic Safety Issue B-56, ' Diesel Generator Rel i abil i ty '. " Enclosure 1 is the guidance on preparing the amendment request and Enclosure 2 is the model TS for this change.
In Option 4 of SECY-93-044, the staff recommends that licensees adopt the accelerated testing provisions of the improved Standard Technical Specifications with an option to relocate accelerated testing requirements for EDGs from the TS to the maintenance program after the maintenance rule goes into effect.
However, after further consideration, the staff has concluded that it is not necessary to await the effective date of the maintenance rule to remove the associated TS requirements.
Licensees may now implement the provisions of the maintenance rule for EDGs, including staff guidance, which will provide a program to assure EDG performance.
Licensees may request the removal of the TS provisions for accelerated testing and special reporting requirements for EDGs at this time.
However, when requesting this license amendment, licensees must commit to implement within the next 90 days a maintenance program for monitoring and maintaining EDG performance consistent with the provisions of Section 50.65 of Title 10 of the Code of Federal Reaulations (10 CFR 50.65), " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and the guidance of Regulatory Guide (RG) 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The NRC staff developed RG 1.160 to provide guidance for complying with the provisions of 10 CFR 50.65.
Licensees that plan to adopt this line-item TS improvement are encouraged to propose TS changes that are consistent with the enclosed guidance in Enclosures 1 and 2.
NRC project managers will perform the review to assure that the amendment requests conform to this guidance.
Licensee action to propose TS changes under the guidance of this generic letter is voluntary. Therefore, such action is not a backfit under the provisions of 10 CFR 50.109. As such, the staff will not perform a backfit
- analysis,
4 4
- Generic Letter 93-XX q This generic letter contains voluntary information collection requirements j
that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 i
et seq.).
These voluntary requirements were approved by the Office of Management and Budget, approval number 3150-0011, which expires June 30, 1994.
i The public reporting burden for this voluntary collection of information is
)
estimated to average 40. person-hours per licensee response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.
Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for further reducing reporting burden, to the Information and Records Management Branch (MNBB-7714), U.S. Nuclear Regulatory Commission, Washington, D.C.
20555; and to the Desk Officer, Office of Information and Regulatory Affairs, NE0B-3019, (3150-0011), Office of Management and Budget, Washington, D.C.
20503.
Compliance with the following request for information is purely voluntary.
The information would assist NRC-in evaluating the cost of complying with this generic letter:
(1) the licensee staff time and costs to prepare the amendment request (2) an estimate of the long-term costs or savings accruing from this TS change If you have any questions about this matter, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation project manager.
Sincerely, James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosures:
1.
Guidance on Preparing the Amendment Request 2.
Model TS for Change 3.
List of Recently Issued NRC Generic Letters Technical contacts:
Om Chopra, NRR (301) 504-3265 Tom Dunning, NRR (301) 504-1189
GUIDANCE FOR IMPLEMENTING A LINE-ITEM TECHNICAL SPECIFICATION (TS)
IMPROVEMENT TO REMOVE ACCELERATED TESTING AND SPECIAL REPORTING REQUIREMENTS FOR EMERGENCY DIESEL GENERATORS (EDGs)
FROM PLANT TECHNICAL SPECIFICATIONS Backaround As part of the resolution of Generic Safety Issue (GSI) B-56, " Diesel Generator Reliability," the staff of the U.S. Nuclear Regulatory-Commission (NRC) recommended Option 4 in SECY-93-044, " Resolution of Generic Safety Issue B-56, ' Diesel Generator Reliability'." The Commission ~ approved Option 4 on-March 25, 1993.
In Option 4, the NRC staff recommends that licensees adopt the accelerated testing provisions of the improved Standard Technical Specifications' (STS) with an option to relocate accelerated testing requirements for the EDGs from the TS to the maintenance program when the maintenance rule goes into effect in 1996. However, after further consideration, the staff has concluded that it is not necessary to await the effective date of the maintenance rule to remove the associated TS requirements.
Licensees may now implement the provisions of the maintenance rule for EDGs, including staff guidance, which will provide a program to assure EDG performance.
The elements of this program will' include the performance of a detailed root cause analysis of EDG failures, effective corrective actions taken in response to EDG failures, and' implementation of EDG preventive maintenance consistent with the maintenance rule.
The staff has concluded that licensees may also propose TS changes to remove special reporting requirements for EDGs from their plant TS.
Licensees would continue to comply with the provisionc of 10 CFR 50.72 and 50.73 to notify NRC and report EDG failures.
The staff approval of this option would be contingent upon a licensee commitment to implement within 90 days a maintenance program for monitoring and maintaining EDG performance in accordance with the provisions of 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and the guidance contained in Regulatory Guide (RG) 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Pl ant s. "
Discussion The NRC staff developed RG 1.160 to provide flexibility for licensees to structure their maintenance program based on the risk significance of the
'NUREG-1430 through NUREG-1434:
" Standard Technical Specifications, Babcock and Wilcox Plants; Westinghouse Plants; Combustion Engineering Plants; General Electric Plants, BWR/4;- and General Electric Plants, BWR/6,"
respectively.
IK LOSURE 1
, 1 structures, systems, and components that are within the scope of the maintenance rule. This guide endorses the Nuclear Utility Management and Resources Council (NUMARC) 93-01, " Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," which gives methods acceptable to the NRC staff for complying with the provisions of 10 CFR 50.65.
This guide, which offers guidance that licensees could follow to assure EDG performance, states that "The emergency diesel generator reliability performance criteria or goals selected for implementing the intent-of 10 CFR 50.63 for coping with station blackout could be monitored through 2
the use of the triggers and the monitoring methods described in Appendix D of NUMARC 87-00, Revision 1, " Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at LWRs," August 1991 (except for triggers and testing for " problem diesels" as described in paragraph D.2.4.4 of NUMARC 87-00, which will be addressed separately by the NRC). An acceptable unavailability goal could be to have fewer hours unavailable (on a rolling 1-year basis) than the number of hours established as acceptable by the licensee."
The NRC staff finds that licensees' commitments to implement a maintenance program for monitoring and maintaining EDG performance in accordance with the provisions of the maintenance rule and consistent with the guidance of-RG 1.160 would provide a basis for the staff to approve licensees' requests to remove the accelerated testing and special reporting requirements for EDGs from their plant TS.
Licensees must commit to implementing within 90 days, of the issuance of the license amendment, the provisions of 10 CFR 50.65 and guidance of RG 1.160 for EDGs when requesting the removal of the EDG accelerated testing and special reporting requirements from their plant TS.
These actions are intended to close the matter of triggers and testing for
" problem diesels." includes model EDG technical specifications which address these TS changes.
2The triggers are intended to indicate when emergency diesel generator performance problems exist such that additional monitoring or corrective action is necessary.
It is recognized that it is not practical to demonstrate by statistical analysis that conformance to the trigger values will ensure the attainment of high reliability, with a reasonable degree of confidence, of 1
individual EDG units.
l 1
i
MODEL STANDARD TECHNICAL SPECIFICATIONS FOR REMOVING ACCELERATED TESTING L
AND SPECIAL REPORTING REQUIREMENTS FOR EDGs Revisions to TS 4.8.1.1.2 (Changes are shown highlighted.)
4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:
Atli eaj Q @ e M fl31Eday son a STAGGERED TEST BASIS by:
l a.
- 1) through 7) no change.
l l
(Removes the reference to TS Table 4. 8.1.1.2-1 for the test schedule.)
L i
Revisions to Tab 1e 4.8.1.1.2-1 (Changes are shown highlighted.)
i TABLE 4.8.1.1.2-1 DIESEL GENERATOR TEST SCHEDULE
}NS$fk5dd{
(Removes accelerated testing requirements for EDG's which were based on the number of failures in the last 20 and 100 valid tests.)
l l
l Revisions to TS 4.8.1.1.3. " Reports" (Changes are shown highlighted.)
H 4.8.1.1.3 Reports (N6tL[Used{
(10 CFR 50.72 and 50.73 address the remaining regulatory requirements for licensees to notify NRC and report EDG failures.)
l
{
CRGR REVIEW PACKAGE
- 0 POSED ACTION:
Issue a generic letter to give licensees guidance for implementing a line-item technical specifications (TS) improvement to remove accelerated t.esting and scecial reporting reoutrements for emergency diesel generators (EDGs) from plant technical specifications.
CATEGORY:
2 PESPONSE TO RE0VIREMENTS FOR CONTENT OF PACKAGE SUBMITTED FOR CRGR REVIEW (i)
The proposed generic requirements or staff position as it is proposed to be sent out to licensees.
Where the objective or intended result of a proposea generic requirement or staff position can be acnieved by setting a reaoily quantifiable standard that has an unambiguous relationsnip to a readily measurable quantity and is enforceable, the proposed requirements should merely specify the objective or result to be attained, rather than prescribing to the licensee how the objective or result is to be attained.
See the proposeo generic letter, " Removal of Accelerated Testing and Special Reporting Reouirements for Emergency Diesel Generators from the Plant Technical Specifications."
(Attachment)
(ii)
Draft staff papers or other underlying staff documents supporting the requirements or staff positions.
SECY-92-015, the staff's proposed resolution of Generic Safety Issue (GSI) B-56, " Diesel Generator Reliability," including proposeo revisions to the station olackout (SBO) rule. On Novemoer 12, 1991, the staff discussed its proposed revisions to the SB0 rule with the CRGR.
Federal Reoister Notice (57 f3 14514) on proposed revisions to the SB0 rule.
Letter from Byron Lee, NUMARC, to Commissioner Curtiss, May 12, 1991, requesting relaxation of TS requirements for accelerated EDG testing.
SECY-93-044, " Resolution of Generic Safety Issue B-56, 'Diesei Generator Reliability'," February 22, 1993.
Staff Reouirements Memorandum. SECY-93-044, " Resolution of GSI B-56.
' Diesel Generator Reliability'," Maren 25, 1993.
(iii)
Each proposed reouirement or staff position snali contain the sponsoring office's position as to whether the proposal would increase 1
requirements or staff positions, would implement existing recuirements or staff positions, or would relax or reduce existing requirements or staff positions.
The proposed generic letter allows the removal of accelerated testing and special reporting reouirements for EDGs from plant technical specifications.
The proposed change would relax current technical specifications requirements for diesel generators.
(iv)
The proposed method of implementation along with the concurrence (and any comments) of the Office of the General Counsel (0GC) on the method proposed, including the concurrence of affected program offices or an explanation of any nonconcurrence.
Each licensee would voluntarily propose TS changes and commit to implement, within 90 days, a maintenance program for monitoring EDG performance in accordance with the provisions of the maintenance rule and guidance of Regulatory Guide (RG) 1.160, developed by the staff for complying with 10 CFR 50.65. consistent with the generic letter.
Project managers would review the proposed changes, prepare the safety evaluation report (SER), and process the license amendment to implement the TS changes.
0GC reviewed the proposed generic letter and had no comment or objections. This line-item TS improvement is in response to the Commission SRM issued dated March 25, 1993, approving option 4 of SECY-93-044, " Resolution of GSI B-56, ' Diesel Reliability'."
(v)
Regulatory analyses generally conforming to the directives and guidance of NUREG/BR-0058 and NUREG/CR-3568.
A regulatory analysis is not required because action taken by licensees in response to this generic letter would be voluntary.
(vi)
Identification of the category of reactor plants to which the generic requirement or staff position is to apply.
This generic letter applies to all power reactor plants that have reouirements for accelerated testing or reporting failures of EDGs.
(vii)
For backfits other than compliance or adequate protection backfits, a backfit analysis as defined in 10 CFR 50.109. The backfit analysis shall include, for each category of reactor plants, an evaluation that demonstrates how action should be prioritized and seneduled in light of other ongoing regulatory activities.
The backfit analysis shall document for consideration information available concerning any of the following factors as may be deemed appropriate and any other information relevant and material to the proposed action:
(a)
Statement of the specific objectives that the proposed action is designed to achieve:
(b)
General description of the activity that would be required by J
the licensee or applicant in order to complete the action; 2
)
1
(c)
Potential change in the risk to the public from the accidental offsite release of racioactive material; (d)
Potential impact on radiological exposure of facility employees and other onsite workers; (e)
Installation and continuing costs associated with the action, including the cost of facility downtime or the cost of construction delay; (f)
The potential safety impact of changes in plant or operational complexity, including the relationship to proposed and existing regulatory requirements and staff positions; (g) The estimated resource burden on NRC associated with the proposed action and the availability of such resources; (h) The potential impact of differences in facility type, design, or age on the relevancy and practicality of the proposed action; (i) Whether the proposed action is interim or final, and if interim, the justification for imposing the proposed action on an interim basis; (j) How the action should be prioritized and scheduled in light of other ongoing regulatory activities.
The following information may be appropriate in this regard:
(1) The proposed priority or schedule, (2)
A summary of the current backlog of existing requirements awaiting implementation, (3)
An assessment of whether implementation of existing requirements should be deferred as a result, and (4)
Any other information that may be considered appropriate with regard to priority, schedule, or cumulative impact.
For example, could implr. mentation be delayed pending public comment?
Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
(viii) for each backfit analyzed pursuant to 10 CFR 50.109(a)(2) (i.e., not adequate protection backfits and not compliance backfits), the proposing office director's determination, together with the rationale for the determination baseo on the considerations of paragraphs (1) through (vii) above, that:
3
l (a) there is a substantial increase in the overall protection of public health and safety or the common defense and security to be derived from the proposal; and (b) the direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection.
Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
(ix)
For adequate protection or compliance backfits evaluated pursuant to 10 CFR 50.109(a)(4)
(a) a documented evaluation ca. i y.ng of:
(1) the objectives of the modification, (2) the reasons for the modification, and (3) the basis for invoking the compliance or adequate protection exemption.
(b)
In addition, for actions that were immediately effective, the evaluation shall document the safety significance and appropriateness of the action taken and consideration of how costs contributed to selecting the solution among various acceptable alternatives.
Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
(x)
For each evaluation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office director's determination, together with the rationale for the determination based on the considerations of paragrapns (i) through (vii) above, that (a) the puolic health and safety and the common defense and security would be adequately protected if the proposed reduction in requirements or positions were implemented, and The proposed changes will have a positive impact on protection of public health and safety by eliminating the accelerated test 1ng required by current TS and thereby reducing the number of starts on EDGs, which may cause unnecessary wear on EDGs.
The early implementation (within 90 days) of the provisions of the maintenance rule and the associated regulatory guidance for EDGs will ensure that the EDG reliability levels cnosen for station blackout are being achieved.
(b) the cost savings attributed to the action would be substantial enougn to justify taking the action.
4
A licensee would reduce operational cost by removing accelerated testing of EDGs and would reduce administrative cost by not having to report every EDG failure.
(xi)
For each request for information under 10 CFR 50.54(f), an evaluation that includes at least the following elements:
(a)
A problem statement that describes the need for the information in terms of potential safety benefit.
(b)
The licensee actions required and the cost to develop a response to the information request.
(c)
An anticipated schedule for NRC use of the information.
(d)
A statement affirming that the request does not impose new requirements on the licensee, other thar, fcr the requested information.
The generic letter would not request information under 10 CFR 50.54(f).
However, it would request that the licensee voluntarily submit information on the time and cost to prepare the license amendment request and an estimate of the long-term savings to be realized from the proposed TS change.
(xii)
An assessment of how the proposed action relates to the Commission's Safety Goal Policy Statement.
The station blackout rule considered EDG reliability and was consistent with Commission's Safety Goal Policy Statement.
l 1
5