ML20101R621
| ML20101R621 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/06/1992 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-57FR14514, RTR-REGGD-01.009, RTR-REGGD-1.009, RULE-PR-50, TASK-DG-1021, TASK-RE 57FR14514-00022, 57FR14514-22, NUDOCS 9207160103 | |
| Download: ML20101R621 (2) | |
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Docket Number 50-346 00cm t Nr,. ;i ; vu.!
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License Number NPF-3 Serial Number 2064 July 6, 1992
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I Mr. Samuel J. Chilk i
Secretary of the Commission Nuclear Regulatory Commission Vashington, DC 20555 Attention:
Docketing and Service Branch
Subject:
Comments on Proposed Revision to 10 CFR 50.63, " Loss of All Alternating Current Pover", 57 Federal Register 14514, 1
April 21, 1992 i
Dear Mr. Chilk:
1 Toledo Edison tTE), a subsidiar; of Centerior_ Energy, ic partial owner of and is responsible for operation of the Davis-Besse Nuclear Power Station. Toledo Edison has been authorized for power operation of the Dr.vis-Besse Nuclear Power Station since. April 1977.
As a 10 CFR 50 licensee, Toledo Edison has a vested interest in any policies the U.S.
j NRC may adopt which can affect the management and-operation of a commercial nuclear power plant.
i Toledo Edison has reviewed the comments drafted on behalf of the nuclear power industry isy the Nuclear Management and Resources Council (NOMARC) and the Nuclear Utility Backfitting and Reform Group (NUBARG) and endorses their comments.
In addition, Toledo Edison provides the following comments:
1.
The proposed rule effectively endorses Regulatory Guide 1.9 (Revision 3) as the only means of ensuring compliance with the rule for design, testing and_ monitoring performance of diesel generators. The Emergency Diesel Generators (EDGs) at the Davis-Besse Nuclear Power Station are designed and tested in accordance with an earlier revision of Regulatory Guide 1.9 and EDG performance is monitored in_accordance with TE's commitment to r.
NUMARC 87-00, " Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout of Light Vater Reactors".
Over the past several years, TE has maintained high reliability of the EDGs.
Therefore, the imposition of any additional-requirements beyond TE's current commitments vould not be cost or risk beneficial-to TE.
l h7ig103920706 Operenng comconies creseicna Electne niuminating 50 57FR14514 PDR Toleco Ec: son
Docket Number 50-346 License Number NPF-3 Serial Number Page 2 2.
Modification to the enforcement policy in 10 CFR Part 2, Appendix C, which would consider exceeding a " double trigger" an example of a Severity Level III violation, is inappre,r.riate.
The NRC states that the purpose of considering this change Is to " emphasize the importance of having reliable diesel generators".
By virtue of the industry's improvement in diesel generator reliability over the past several years, it is evident that the industry also considers this important and the perceived " threat" of a Severity Level III violation is unnecessary.
Should you have any questions or require additional infornation, please contact Mr. Robert V. Schrauder, Manager - Nuclear Licensing at (419) 1 249-2366.
Sincerely yours, "u
I N / c cc:
A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NRC/NRR Senior Project Manager V. Levis, DB-1 NRC Senior Resident Inspector USNRC Document Control Desk l
Utility Radiological Safety Board i
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