ML20112G845

Comment Opposing Proposed Rule 10CFR50, Reporting Reliability & Availability Info for Risk-Significant Sys & Equipment

ML20112G845
Person / Time
Site:	Fermi
Issue date:	06/11/1996
From:	DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-96-0068, CON-NRC-96-68, FRN-61FR5318, RULE-PR-50 61FR5318-00012, 61FR5318-12, NUDOCS 9606130066
Download: ML20112G845 (8)

Text

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Detroit r.<mia essre'; I Edison EEF" '

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l Of fici t' P RETARY 00CKETi i qlct Bi< Am 9 June 11,19%

NRC-96-0068 q.

U.S. Nuclear Regulatory Commission PROPOSE) M =

Attn: Docement Control Desk Washington, D. C. 20555 g,gpg,33g)

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF -43

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2) Proposed Rule: " Reporting Reliability and Availability Information for Risk-Significant Systems and Equipmeng" published in the FederalRegister dated February 12,19%

(61FRS318)

3) Draft Regulatory Guide DG.1046 dated April 1996,

" Guidelines for Reporting Reliability and Availability Information for Risk-Significant Systems and Equipment in

- Nuclear Power Plants"

Subject:

Detroit Edison Comments on Proposed Rule: Reportmg Reliability and Availability Information for Risk-Significant Systems and Eouipment I Detroit Edison is pleased to have an opportunity to comment on the Nuclear Regulatory Commission's (NRC) proposed rule, " Reporting Reliability and Availability Information for Risk-Significant Systems and Equipment," pub'ished in the Reference 2 FederalRegister.

In summary, we believe the proposed rule is unnecessary and should not be promulgated by the NRC. Our view is based on the following points:

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9606130066 960611 i PDR PR i

\O 50 61FR5318 PDR

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f, JtJ4-11-1996 17:25 FERMI 2 DET EDISON 313 586 4208 P.02 USNRC June 11,1996 NRC-96-0068 Page 2 e The additional data reporting and recording keeping is not needed by the NRC for assessing compliance with any current regulatory requirement.

l e The estimate ofindustry burden provided in the supporting statement to OMB is inaccurate. The rule would actually impo .e an excessive burden on the industry.

e The potential total impact of the proposed rule is uncertain because definitiors of terms are not clear and would be subject to int-rmation.

. The data required by 10 CFR 50.76 represents a substantial increase in data j collection needs over and above the Maintenance Rule.

With regard to the first point above, the reporting and record keeping of reliability and availability information is not necessary for the NRC to oversee the implementation of current regulatory requirements by reactor licensees There an.e already hundreds of different reporting and record keeping requirements that fulfill '

this purpose (ref NUREG-1460, Guide to NRC Reporting and Record keeping Requirements). As stated in the Federal Re9' ster notice, the NRC believes "...the i

information is necessary to substantially improve the NRC's ability to make risk l effective decisions consists with the Commission's policy mat-ant on the use of I

probabilistic risk assessments (PRA)." It should be noted,' however, that there is no regulatory requirement for licensees to conduct PRAs or maintain PRA models.

Thus, the proposed rule has no statutory basis and would require record keeping l

reporting information for use in an analytical tool that n. is not re Its promulgation, in and ofitself, does not result in any improvement to public hdalth and safety.

l We believe that data mycnGug and record keeping requirements should be directly l

l associated with regulatory activities that are necessary for the NRC to fulfill its statutory miasion to protect public heahh and safety or that provide substantial additional protection under the provisions of the backfit rule. Furthermore, we believe it is premature for the NRC to require additional data reporting and record keeping in advance of future risk-based regulations or regulatory activities. Any additional data reporting or record keeping requirements should be integrated and in step with the risk-based regulatory initiative under consideration so that the associated costs and benefits can be assessed accurately.

Our second point above addresses the estimate ofindustry burden imposed by the

proposed rule. In the supporting statement provided to OMB, it is assumed thatl80

! of 110 licenses are collecting, or plan to collect, similar reliability and availabdity information A basis for this assumption is not provided.

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JUN-11-1996 17:26 FERMI 2 [ET EDI60N 313 566 4208 P.03 USNRC 4

. June 11,1996 NRC.96-0068 -

I Page 3 Based on our discussions with other utility personnel at Maintenance Rule conferences, few if any, licensees collect the information as described in the proposed rule. There are two major differences from what data is typicaDy collected and what the proposed rule would require. These major differences involve the collection and reporting of demand information and information on the concurrent unavailabilit) of two or more systems or trains.

Regarding demand information, the proposed rule caEs for the collection and reporting of actual demand information, whereas the industry typically estimates se number of demands on equipment. By requiring actual demand information that is equivalent to the information collected for actual failures, the burden of data collection is dramatically increased For example, for equipment that is tested on a monthly basis, the information associated with each of the twelve demands in a yN would be collected and reported under the proposed rule. Today, if one of those' twelve demands resuhed in a failure, the only equivalent information that would be collected would be on the demand that resulted in the failure. Thus, for this example, the proposed rule would increase the burden of data collection by greater than a factor of ten, just on test demand information alone. Given that the reliability of risk-significant equipment in the industry is generally well above 90%, and that the proposed rule calls for information on both failures and successes on all types of demands (test, inadvertent, or actual need), the actual burden of record keeping and reporting on demand information is substantially greater than the estimate provided to I

OMB.

The second key difference involves the collection of the number of hours when tp or more trams from the same or different systems are concurrently unavailable, as would be required under the proposed rule. Current industry practice focuses on monithring the number of hours that a single train is unavailable, not on the overisp of hourse

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when two or more trains are unavailable. This requirement would be particularld burdensome during refueling outages, when several plant systems are removed from service for maintenance Regarding the third and fourth points above, the NRC has preliminarily chosen a; set of basic systems for which reliability data (i.e., h==% failures to start, etc.) will be reported for all plants which have them. Basic Systems for Permi are seen in Table 1.

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l_ At4-11-19% 17:26 FERMI 2 IET EDISON 313 566 4U0 t' . 04 l i USNRC L4 June 11,1996 l NRC-96-0068

Page 4 Table 1 l 'IYPE g

, _ JBASIC SYS'IEMS *

,, AVAILABILITXOATAT DEMAND DATA'

<.u .x - a. .

NNOW E+ mrmTEDNOW Reactor core RCIC YES Start and run Isolation Feedwater HPCI YES Start and run coolant iniection Reactor RPS YES FunctionalFailures Protection only l Low pressure LPCI YES Start and'nm coolant injection CS* YES* Fwhd Failures only I Emergency EDGs YES Start and 'run-power i

• CS - Core Spray is not risk significant at Fermi 2 from Maintenance Rule perspective. Data collected for annual report per Technical Sp+? -=I,n 6.9.1.f .c only.for outages during the time when the system required to be operable per Technical Specifications. ,

Monitoring of Maintenance Rule performance criteria at Fermi 2 is currently as seen in Table 1. The monitoring established is totally consistent with PSA assumptions.

For example, RPS requires an sw.dy high reliability. Since the reliability rmdt be very high, monitoring functional failures is sufBcient to determine if the system does not meet this performance criteria since one functional failure would cause the system

. not applies totoobtain other "high itsreliability" very high systems. reliability If there is one performance aquirement.

mehA failure, then T failed to meet its performance criteria. Kaapi-g track of dam-da will add no value.

Further, Core Spray is not risk significant and therefore does not merit detailed Maintenance Rule monit ? 3 performed for other more risk significant systems Therefore, for some basi :. stems increased monitoring burden would be necessary to aw.m..odate Data Rule .aonitoring.

l The basic systems listed in Table 1 are not sufEcient by themselves per the proposed i rule. Additional systems and equipment to be monitored will depend on plant-specific features. These additional systems would be selected based on plant-specific PM studies. Potential systems which may fall in the scope of the Data Rule are seen! in Table 2.

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[' FERMI 2 DET EDISON 313 566 4208 P.05 JUN-11-1996 17:27 USNRC

- June 11,1996 NRC-96-0068 Page 5 Table 2

~ TYPE: { SYSTEM AVAILABERY DATA DFMANBDATA(START /RUN)3  ;

Feedwater SBFW YES Functionalfailures coolant -

injection Reactmty SLCS YES YES l I

control Decay Heat RHR YES YES '

Removal Service Water GSW* NO* System functional faHures I

• For the GSW system, redundancy is qualitatively monitored in lieu of quantitative availability measures l As can be seen, substantial increases in monitoring requirements would be needE to accommodate the Data Rule. The Data Rule also requires plants to report reliability and availability for certain risk sahm systems and equipment This applies ty the event mitigating systems and equipment which could have significant effect on risk in tenns of avoiding core damage accidents or preserving containment integrity I

, Clarification regarding scoping of systems with "significant effect on risk" is required.

This is very subjective and would be left to the opinion of an W.or unless further definition is provided. In summary, the concern is that the smalllbt ofData Rule systems in Table 2 could be W through la=:* tion actions to include all !

potentially risk-significant systems due to an ambiguity in the Data Rule language.

Detroit Edison also has specific comments discussed below.

! (61FR5320 and 5326): This comment pertains to the foBowing excerpted statements ". . . licensee (s) might schedule train outages fbr m.um at certain times, such that risks are substantially increased over what would bi

- p t~J based on random outages. This situation would not be indicatedby current reporting requirements, or even by simply iWJig train unavadaMity, but it could be indicated by the concurrent unavailmhility of two or more trains as would be reported under the proposed rule." These statements imply th'a t the e

Data Rule is necessary to corm ol such occurrences, but in fact, describe ridt management efforts required to properly implement the Maintenance Rule. The

! PS A model already handles the effects of multiple systems out of service.

(61FR5321): With regard to the Mme. "For example, an individual plant may have an atypical reliability problem with a specific risk-significant system j

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Jlh il-1996 17:27 FEPJ112 DET ED150t1 313 586 4208 P.06 1

USNRC .

June 11,1996 lf NRC-96-0068 Page 6 and thereby warrant additional attention." This seems to duplicate the intent of l

the Maintenance Rule. Systems tnat do not meet their performance criteria would normally be classified as (a)(1) and an appropriate get well plan l estrblished.

(61FRS321): With regard to the statement "It is anticipated that licensees pil request a number of relaxations in survedlance intervals and allowed outage times... ." This example of benefit under Risk Based Technical Specificatic'ns implies allowances for relaxation of allowed outage times (AOT). It is %it .

Edison's concern that if the NRC judges individual changes on a " risk-neutral" basis, that any relief of this nature will be precluded, eliminating any value of the rule for such applications. l l l

I (61FR5322): With regard to the statement, "The NRC would use the hours when any two or more trains from the same or different systems are concurrently unavailable to monitor how well licensees are managing the risk associated with such maintenance" the NRC seems to be intruding into Maintenance Rule space This again is covered by the Maintenance Rule and on-line maintenance control which is under heavy scrutiny by the NRC without -

the Maintenance Rule The interplay between two rulesis cWag and co'u ld welllead to reporting difBculties.

(61FRS322): Under " Licensee Implesnantation" it is implied that plant specific data on reliability would play significant role in OOS decision making. The' major component for such decision making is to set up risk models and a -

framework for obtaining risk impact of OOS, independent of the Data Rule.

Better data would only reduce the uncrey in the quantified result, a j secondary benefit.  !

I (61FR5323): The task of data taking iwMag the setting of enteria such as what constitutes a failure as defined under the section " Failure" can be v complex. The proposed Fpemy Guide DG-1046 goes into this in some, detail. For example, note the statement under Section 5: " Degradation in j equipment performance that do not satisfy operability reqb A for demsn basis accidents but would not prevent the accomplishment of a risk-siyJodie function are generally not reportable as failures umler this rule." M each such detail can well be time-consuming and open to the threat ofNRO disagreement on the criteria chosen on the one hand or over conservative d'sta results on the other. This problem is always there, but now it will be under!the weight of a me. Specific examples of the cor.yley are actually cited in DG-1046 in Sections 5 and 5.3 when they discuss desired start times and recoveries.

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FERf112 DET Episori 313 566 4200 r.07 l JUh-11-t996 17:28

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- USNRC l

.- June 11,1996 l NRC-%-0068 i Page 7  !

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(61FR5324): The scope of the rule is very nebulous and could lead to a lot of effort in establishing and could result in a large number of systems / trains relative to say the systems ofinterest to INPO. Recall the effort that went into the Maintenance Rule scope. To minimize this effort, a conservative approach ,

would likely be taken (all iisk significant systems / trains) leadmg to a large number of systems (instead of the 7 to 10 aeiwad by DG-1046) and a corresponding large effort to collect the data. Moreover, when the rule talks of

" systems and equipment," DG-1046 implies that data at the component level is likely to be required, leading to signi5 cant increase in effort.- See Appendid E of DG-1046, including example 6. See also section (b)(3) of the rule on p.

5326FR. j (61FR5326); The requirements under section (b)(1)(iv) that include the cause and effect ofeach failure and the proposed form titled " Component Failure Records" (Appendix F to DG-1046) that specifies a description of the corrective actions appears to extend beyond reliab' d ity data and correspond'mgly adds to the effort. The rule appears to be codifying corrective action programs, which should not be the intent of the Data Rule.

4 Given the concems discussed above as well as several ambiguities in the information required by the rule versus current industry practice, we believe burden imposed by the rule would outweigh its potential benefits. The estimate ofburden provided in the supporting statement to OMB is fundamentally flawed and inaccurate. The burde'n of the record keeping and reporting imposed on licensees would be 2 to 7 times of that i estimated on an annual / recurring basis. - These estimates do not include any costs associated with the installation and maintenance of equipment such as total run-imur meters, building an infrastructure to archive and retrieve the data, training required for those obtaining the data, nor the cost of sending individuals to industry  !  !

conferences which are sure to come if this mle is promulgated.  ! ,

I In summary, we believe the proposed nde is tme=y and should not be promulgated by the NRC.

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313 5&5 4208 P.08 l jut 4-11-19% 17:28 FERtil 2 DET ED150t4 USNRC June 11,1996 NRC-%0068 Page 8  !

If you have questions on our comments, please contact Mr. Robert Newkirk at (313) i I

586-4211.

Sincerely, l I

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cc: H.J. Miller M.P. Phillips D. V. Pickett ~

A. Vegel Supervisor, Electric Operators, Michigan l Public Service Commission - J. R. Padgett i

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' TOTAL P.08