ML20134N201

Comment Supporting Proposed Rev 2 to Regulatory Guide 1.160 Monitoring the Effectiveness of Maint at Npps

ML20134N201
Person / Time
Site:	Beaver Valley
Issue date:	11/11/1996
From:	Jain S DUQUESNE LIGHT CO.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-61FR47987, RTR-REGGD-01.160, RTR-REGGD-1.160, TASK-*****, TASK-RE 61FR47987-00002, 61FR47987-2, NUDOCS 9611260215
Download: ML20134N201 (2)

Text

- . - - ~ .. - - . . . . - , ~ _ . . . . ~ . - . . . . .. - , . . . _ _ -

G

/. A cy m n [

Duquesne Li@t Company gg e <s= , . , ' , \ ,, 7 4U Shippingport. PA 15077 0004 v e 2

, w U! l a ut 8: Sti SUSHtt C. JMN N l > i n ' R " ' * *" '

(412) 393 5512 DMsion Vice President .U$h8C Fax (412) 643-8069 Nucle r Po r DMalon

! Mr. David L. Meyer Chief, Rules Review and Directives Branch DFIPS Office of Administration

U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 St bject: Beaver Valley Power Station, Unit No.1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Draft Regulatory Guide DG-1051, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants"

Dear Mr. Meyer:

Duquesne Light Company (DLC) is responsible for the operation of Beaver Valley '

Power Station Units 1 and 2. DLC has reviewed draft Regulatory Guide DG-1051 which is proposed Revision 2 to Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 is being revised to endorse Revision 2 of NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of ?.kintenance at Nuclear Power Plants," which has been updated by the Nuclear Energy Insti tute. The regulatory guidance is intended to provide flexibility for a licensee to structure its maintenance program in accordance with the safety significance of those structures, systems, and components (SSCs) within the scope of the maintenance rule.

DLC believes the proposed revision represents an improvement to the current regulatory guide. DLC also submits the following specific comments:

\ O 200059 y 9611260215 961111 PDR ADOCK 05000334 Mpp.A i w %. 4/ f niinnins-Q II A L l.T Y y erg g3jh/,/)[Jw ~gggggy P PDR ,

{$20 f Ll{tOf~"ICh - ..

Beaver Valley Power Station, Unit No. I and No. 2 Draft Regulatory Guide DG-1051, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" Page 2

. Page 11, Item 1.2 - Systems with Multiple Design Functions The discussion presented in this section, and in particular the third sentence of ;

the section, could be misconstrued to imply scoping'at a component level within systems is expected or encouraged by the Nuclear Regulatory Commission (NRC) for systems with multiple design functions, some of which are not within the scope of the maintenance rule. DLC believes the guidance given by NUMARC 93-01, Revision 2, dated April 1996, discourages scoping at a component level because it leads to maintenance program complexity and unmanageability. The wording of this part of the draft guide should be revised to recognize that the scoping of SSCs may be at a system level. The evaluation of the impact of a component failure should look at the function of the system which is within the scope of the maintenance rule. This does not require the original scoping to be done at a component level.

• Page 12, Item 1.3 - Cause Determination The last sentence of this part of the draft guide ends with the wording "...would be required." DLC believes this wording should be "...should be considered."

NUMARC 93-01, Section 9.4.4, is written to indicate that a decision to ,

disposition the SSC from paragraph (a)(2) to paragraph (a)(1) is to be made based on the results of the cause determination. Thus, the move from paragraph (a)(2) to paragraph (a)(1) is not a requirement or foregone conclusion but a choice based on evaluation of the failure and the circumstances surrounding the failure. In some cases, the appropriate decision may be to keep the SSC in paragraph (a)(2) and provide documentation to support that choice. The wording of the regulatory guide should be changed to allow such an option.

Thank you for the opportunity to comment on this issue. If you have ar.y questions on this submittal, please contact Mr. Roy K. Brosi, Manager, Nuclear Safety Department, (412) 393-5210.

Sincerely, Sushil C. Jain l

1