ML20055E998
| ML20055E998 | |
| Person / Time | |
|---|---|
| Issue date: | 07/09/1990 |
| From: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML20055E997 | List: |
| References | |
| REF-GTECI-B-56, REF-GTECI-EL, RTR-REGGD-01.009, RTR-REGGD-1.009, TASK-B-56, TASK-OR NUDOCS 9007130167 | |
| Download: ML20055E998 (3) | |
Text
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..t UNITED STATES
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NUCLEAR REGULATORY COMMISSION n
WASHINGTON, D. C. 20555
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JUL 9 1990 MEMORANDUM FOR:
E.
L. Jordan, Chairman Committee to Review Generic Requirements FROM:
E.-S.
Beckjord, Director Office of Nu71 ear Regulatory Research
SUBJECT:
PEVISION TO B-56 CRGR PACKAGE Enclosed is a revision to Section C.5,
" Reporting Criteria" of Regulatory. Guide 1.9, Revision 3 which-incorporates the reporting requirements desired by NRR.
This revision calls for a special report to be submitted when a " problem" EDG situation occurs (i.e. 4 failures in the last 25 valid. demands).
The need for such a report is justified in the enclosed A. Thadani (NRR) to W. Minners (RES) memo dated July 6, 1990.
The revised portion of,the regulatory analysis dealing with this reporting requirement is also enclosed.
This backfitting is necessary to provide uniform reporting requirements for all plants.
This report is a relaxation of the special EDG failure reporting requirements found in most Tech Specs which reference RG 1.108, which requires the reporting of all EDG failures, valid _or non-valid.- However, there are some older plants that do not have any Tech Spec EDG failure reporting requirements and therefore this-requirement is a-backfit.
A suggestion for submittal of revised Tech Specs associated with these relaxations-is contained in page 2 of the 50.54 (f)-letter (see Enclosure C of the B-56 package previously_ submitted to the CRGR),
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E.
S.
Beckjord,, Director office of Nuc1earsRegulatory Research
Enclosures:
As stated cc:
W.
Russell, NRR A. Thadani, NRR F. Rosa, NRR O.
Chopra, NRR J.
Calvo, NRR T.
Dunning, NRR l
9007130167 900710 REVGPERONg!gC PDR
7-9-90 REVISION TO SECTION C.5,_RG 1.9,-REV.
3-5.
-REPORTING CRITERIA When reporting EDG failures, all plants should conform with the provisions of 10 CFR 50.4.
10 CFR 50.72, 10 CFR 50.73, 10 CFR 21,> plant technical specifications, and other current NRC reporting regulations.
In addition, if an individual EDG experiences 4 or more valid failures in the last 25 demands, these failures and any
-non-valid failures experienced by that EDG in that time period should be reported in 30 days.
This report should inplude the following information:
l 12_The nuclear unit EDG performance and reliability indicators as compared to the accropriate 20. 50, and 100 demand =triacer values.
2.
A description of the failures. underlyina causes, and corrective actions taken.
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I 7-5-90
' REVISION TO B-56 PKG,_ ENCLOSURE D, PAGE 8 i
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the total cost would be $150,000.
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'4he development. of guidelines by staff and. industry -
.I representatives which resulted in Revision 3 of j
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' Regulatory' Guide 1.9, and of NLMARC-8700, Rev.
1, Appendix D provides for uniform guidance and conformity of approaches, thereby reducing NRC review costs.
u (8) 'The-potential impact of differences in facility type, j
design, or age on the relevance and practicality _of the proposed backfit, j;
Differences in facility type, design, or age will not 1
have any significant effect on the relevance or practicality of complying with the EDG reliability l
monitoring program since the proposed chances reflect j
current industry practices.
l In. addition, Revision 3 of Regulatory Guide.l.9 and NUMARC-8700, _ Rev.
1, Appendix D have been subjected to extensive discussions with NUMARC's B-56. working group j
and also dssued for external review to solicit a wide I
spectrum of review and_ ensure conformity with proven practice, thereby-further reducing potential impacts, j
l However, reportina recuirements associated with the oroblem EDG will imoact older olants that currently are not subiect to reportina any EDG failures throuch Tech Spec recuirements. Current EDG oerformance indicates that such reports should be extremelv minimal. The occurence of a-problem EDG situation is indicative of an inability to correct failures j
throuch on-sito EDG maintenance practices and also i
represents a sianificant deterioration of nuclear unit EDG reliability level.
Onithe other hand the revised EDG failure reportina recuirements are a relaxation of reocrtina reauirements for the maiority of plants which currently report all EDG failures, valid or non-valid, per RG 1.108, Rev.2.
(9)
Whether the proposed backfit is interim or final and, if interim, the justification for' imposing the proposed backfit on an interim basis.
i The p.roposed action is final.
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