ML20235S663

Forwards Comments on NUMARC-8700,App D, Emergency Diesel Generator Program. Reliability Program Needs Addl Work Before Program Can Be Approved

ML20235S663
Person / Time
Issue date:	03/01/1989
From:	Rosa F Office of Nuclear Reactor Regulation
To:	Serkiz A NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20235S667	List: ML20235S663 ML20235Z414
References
RTR-REGGD-01.009, RTR-REGGD-01.155, RTR-REGGD-1.009, RTR-REGGD-1.155 NUDOCS 8903070214
Download: ML20235S663 (5)

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MEMORANDUM FOR: Aleck W. Serkiz, Senior Task Manager Reactor and Plant Safety Issue Branch l Division of Safety Issue Resolution, RES FROM: Faust Rosa, Chief Electrical Systems Branch Division of Engineering & Systems Technology SlJBJECT: COMMENTS ON NUMARC-8700 APPENDIX D "EDG RELIABILITY PROGRAM" The Electrical Systems Branch (SELB) has reviewed the subject report and our comments are enclosed for transmittal to NUMARC. We support the concepts upon which the EDG reliability program is based, however, we find that the reliability program needs additional work before it can be approved. The comments enclosed are intended to improve the_ proposed reliability program.

Our major comments should be resolved while our minor comments are for your consideration.

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D Faust Rosa, Chief Electrical. Systems Branch Division of Engineering & Systems Technology

Enclosure:

As stated cc: A. Thadani C. Kniel P. Norian J. Knight

Contact:

0. Chopra, SELB/ DEST X20835 s

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l COMMENTS ON NUMARC 8700 APPENDIX D: EDG RELIABILITY PROGRAM

GENERAL COMMENT

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The comments provided in this transmittal include both (a) major and (b) minor comments resulting from our review of Appendix D: EDG Reliability Program. We have also provided these comments based on the dialogue between NUMARC and the NRC in the meeting that took place on January 25-26, 1989.

Based on the dialogue with the industry group and on our review of their Appendix D document we believe that the industry is engaged in a good faith effort to ensure maintaining EDG reliabilities at their present levels. We also believe that the industry effort is being worked on by technically com-petent and qualified persons.

MAJOR COMMENTS:

1. We are not in agreement with the NUMARC stated industry posture that

$ utilities need not institute a formal " reliability program" if the existing EDG reliability levels are at or above the selected target level. The message from NUMARC was that the industry's objective I

is only to ensure that their target reliability level is satisfied, I

and that only after the reliability value dropped below a target value would a more concerted effort i.e., a " Reliability Program" be set in motion. This implication should be removed from the document.

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2. We find incenzistencies between the methodology defined in Regula-l tory Guide 1.155, position 1.1 and para. D.1.3 (pg. D-5) of Appendix 0 1.% and the failure to use information contained in the last 20 demand tests (i.e., Table 1.1-1,pg.D-5). Also, it is unclear why it is necessary to separately address f ailure experience of diverse EDGs (figure D 1.2-1, pg. D-5).

3. We do not find acceptable the graduated response (Fig. D.l.4-1, Pg.

l-D-9) by the licensee to the most recent EDG failures encountered (i.e. , the last 20 tests). Although a minimal amount of guidance is

provided in Fig. D.1.4-1 and para. D.1.4, pg. D-7, the thrust of this section focuses on actions derived from the 50 and/or 100 demand population. We feel that more forthright use should be made of information derived from the last 20 demands and appropriate guidance provided in this document. Any individual failure should not be 1

treated lightly.

4. Clarify what information and records should be maintained at the plant, and what information will be reported to INP0. NRC reporting require-ments will be defined in R.G. 1.9, Rev. 3 and the Standard Technical Specification.

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5. Section D.2.1, currently titled " Performance Monitoring" would benefit from addtional emphasis being placed in trending techniques and appli-cation thereof. We also suggest that this section be retitled to

" Performance Monitoring and Trending."

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6. No guidance has been provided with regard to the management review responsibilities in the EDG reliability program in accordance with R.G. )

1.155 position 1.2.5 to ensure that the program is functioning properly.

The document should define the management resources, controls, and  ;

describe the responsibilities and corresponding qualification of personnel.

7. We believe that each utility must test, monitor, collect data, trend data and interpret data and test results in such a way that the onset of failures can be detected (perhaps not in all cases) and that the operative " Reliability Program" not only maintair, an acceptable level y of reliability t>ut that at uay even result in improvement. The elements of a program as spelled out in the Rcgulatory Guide 1.155 and proposed Replatcry Guide 1.9, Revision 3 should be included in a reliability program. The document should be revised to include the above.

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8. 'The NUMARC document does not provide any guidance in diagnostic tech- j niques. We believe the document, 'and the reliability program would be enhanced by inclusion of diagnostic technique references.

MINOR COMMENTS:

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1. Figure D.1.4.2-1 on page D-12 provides a sample format for " corrective Maintenance Histories." This figure, however, does not show any dates i.e., time of failure, root cause determination established, and cor-rective action made and verified by test. Revise this figure to in-clude columns for time and date.

2. Page D-34, first para.:

Change section "D.2.1" to "D.2.2."

p 3. Page D-38, first para.:

Change "D.2.3 Data System" to D.2.6 "EDG Reliability Data System" and move this item at the very end of the report.

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4. Page D-43, first para.:

l Change "D-4" to "D.2.3".

l S. Page D-44, first para.:

g Change "D5" to "D.2.4".

6. Page D-46, 2nd para.:

Change "D.2.6.6 " Problem closeout" to "D.5 EDG Problem.

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T l-' 7. Page D-10, first para. :-

Change "... but who have experienced an, unsuccessful start should ..." to "... but who have experienced an unsuccessful start or load run should ..."

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