ML20236T394
| ML20236T394 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/20/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-REGGD-01.089, RTR-REGGD-1.089 1442, NUDOCS 8712010202 | |
| Download: ML20236T394 (2) | |
Text
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TOLEDO
%mmEDISON DONALO C SHELTON Vre Presdent-Nudear (419)249 2399 Docket No. 50-346
~ License No. NPF-3 Serial No. 1442 November 20, 1987 i
United States Nuclear Regulatory Commission Document-Control Desk Washington, D. C.
20555
Subject:
Draft Regulatory Guide On Qualification of Safety Related Lead.
' Storage Batteries Gentlemen:
Toledo Edison respectfully submits the following comments on the Draft Regulatory Guide on Qualification of Safety Related Lead Storage Batteries for Nuclear Power Plants.
Toledo Edison recommends that the following text be removed fr6m Section B paragraph 3:
"There are considerable uncertainties regarding'the processes and environmental factors that could result in such degradation. Because of these uncertainties,' state-of-the-art preconditioning techniques as outlined in IEEE Std 535-1986 are not capable of simulating all significant types of degradation. As the state of the art advances and uncertainties are resolved, artificial preconditioning techniques may-become more effective. Until such' time, the NRC staff prefers natural preaging of safety-related batteries".
Although natural aging is a preferred method, uncertainties regarding
. state-of-the-art aging techniques, as well as laboratory vs. installed natural aging, are addressed via periodic surveillance and testing programs. If the accelerated method were not allowed, any new and some existing products would be eliminated from the nuclear market. As qualified batteries become obsolete, the cost and time involved with natural aging may be enough to effectively eliminate the supply of qualified batteries from our Jimited market.
As an alternative, Toledo Edison recommends replacing the text with a statement similar to Section C.S.d of Regulatory Guide 1.89.
l 8712010202 871120 PDR ADOCK 05000346 P
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THE TOLEOO EDISON COMPANY EDISON PLAZA 300 MAOISON AVENUE TOLEDO, OHIO 43652 p
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'Dockst.No.:50-346 License No.'NPF-3' Serial:1442-Page 2
" Periodic surveillance and testing programs.are acceptable to account for uncertainties regarding age-related degradation that could affect the functional capability of equipment. Results of such programs will be acceptable as ongoing qualification.to modify designated life (or qualified life) of equipment and should-be incorporated into the maintenance and.' refurbishment / replacement schedules".
This would make the new Regulatory Guide consistent with Regulat'ory Guides 1.89 and with 10CFR50.49(d)(5).
In regard to the' comment on making this Regulatory Guide applicable to all operating nuclear power plants,_Teledo. Edison feels'that'.due to the limited market, battery manufacturers.will tend to qualify batteries-in accordance with IEEE 535-1986 (or future revisions) to remain competitive.
This is' demonstrated'by the'NRC in Section B paragraph 4:
"'..'all U.
S.-
battery manufacturers have already qualified their batteries to the provisions of:IEEE Std. 535-1986".'. Therefore, the inclusion or. admission of a requirement for all replacement batteries to comply with the new Regulatory Guide will not have any effect on the quality, operability or safety'of the storage batteries.
Creation of new regulatory requirements i
which would have no beneficial effect is counter-productive.
Very truly yours, y{
SJS:bam l
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