ML20101R479
| ML20101R479 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/06/1992 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF ADMINISTRATION (ADM), NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-57FR14593, RTR-REGGD-01.009, RTR-REGGD-1.009, TASK-DG-1021, TASK-RE 2065, 57FR14593-00002, 57FR14593-2, AE41-1-179, NUDOCS 9207160038 | |
| Download: ML20101R479 (2) | |
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jcf/hA ENERGY 6?y Donald C. $hetton 300 Madeon Avenue Vice Presidert Nuclear Toledo. OH 436520001 De s Besse (419)249 2300 g 4
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Regulatory Publications Branch DF1PS Office of AdJ nistration United States Nuclear Regulatory Commission Vashington, DC 20555
Subject:
Comments on Draft Regulatory Guide DG-1021, " Selection, Design, Qualification, Testing and Reliability of-Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems and Nuclear Power Plants" Gentlemen Toledo Edison (TE), a subsidiary of Centerior Energy, is partial ovner of and is re2nonsible for operation of the Davis-Besse Nuclear Power Station. -Toledo Edison has been' authorized for-power operation of the Davis-Bess-Nuclear Power Station since April 1977.
As a 10 CFR 50 licensee, Toledo Edison has a vested interest in any_ policies the U.S.
NRC may-adopt which can-af feet - the manageent and opention of a commercial nuclear power plant.
Toledo Edison has reviewed the comments drafted-on behalf of the nuclear power = industry by the Nuclear _Hanagement and Resources Council (NUMARC) and endorses NUHARC's comments.
In' addition,_ Toledo Edison provides the following comments:
1.
Section 2.2 contains a listing of various EDG and-Safety Features Actuation System (SFAS) tests-_that should be performed._ These-tests include the Full Load Rejection Test,.the 24. hour Endurance-Run, the Hot Restart Test, the Test Mode Changeover Test and the Redundant Unit. Test. These tests are presently not conducted at Davis-desse and would require additional procedures and outage time to perform vith no apparent benefit.. Toledo' Edison recommends these tests be performed only following major correttive maintenance or modification of the EDGs and not periodically.
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The last paragrapn of Section 3.2 discussos a desired EDG planned unavailability goal of 0.7 percent which int.udes-outage. times during refueling outages. This number is unrealistic since it conflicts with the stated goal of improved reliability.
Toledo Edison estimates an unavailability of 1.8 percent is needed to conduct the present EDG preventive maintenance program.
Minimizing EDG unavailability time ~to 0.7 percent vould require a considerable reduction'in the actual amaunt of preventive maintenance performed on the EDGs, especially during the refueling overhauls.
This, in turn, vould subject the engines to a higher probability of failure during the operating cycle, reducing the overall reliability of the engines. Therefore, a goal similar to the Institute of Nuclear Power Operations (1NPO) goal of 2.5 percent is more realistic.
3.
Section 3.3 of the Regulatory Guide, entitled " Recovery _From a Double Trigger", vould require testing the EDGs on an accelerated frequency to clear the double trigger exceedance.
This conflicts with data collected which indicates that accelerated-testing actually reduces-FnG reliability.
Based on the interval between failures, this section has the potential to require weekly testing of the EDGs for over a year. Toledo Edison recommends the actions described in Appendix D of NUMARC 87-00, " Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Vater Reactors" be specified in the Regulatory Guide.
Should you c ve any questions or require additional information, please contact Mr Rouert V. Schrauder, Manager - Nuclear Licensing at (419) 249-2366.
Very truly yours, l'
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l NKP d c l
l' cc:
A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NF,C/NRR Senior Project Manager V. Levis, DB-1 NRC Senior Resident Inspector l
USNRC Document Control Desk Utility Radiological Safety Board