View source for BECO-92-073, Comment Opposing Draft Rev 3 to Reg Guide 01.009

{{Adams
| number = ML20101T606
| issue date = 07/10/1992
| title = Comment Opposing Draft Rev 3 to Reg Guide 01.009
| author name = Anderson R
| author affiliation = BOSTON EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION (ADM)
| docket = 05000293
| license number = 
| contact person = 
| case reference number = FRN-57FR14593, RTR-REGGD-01.009, RTR-REGGD-1.009, TASK-DG-1021, TASK-RE
| document report number = 57FR14593, BECO-92-073, BECO-92-73, NUDOCS 9207210243
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 1
}}

=Text=
{{#Wiki_filter:- - . _ _ - _ _
(Y b b509                                                                                                   dTFO/tif3 BOSTON EDISON Pagom Nuclear Power Station            USNRC g/l Hocky Hal Road 0FFICE Of 40MtNISTRATico hyrnauth, Massachusetts 0230o 92 JUL 17 A8:48 Roy A. Anderson Senior Vice President - Nuclear July 10, 1992          )
BEco 92- 070 Regulatory Publications Branch, DFIPS Office of Administration U. S. Nuclear Regulatory Ccmmission Washington, DC 20555 Boston Edison Company Comments on P_rapased t                               Revision #3 to Recylatory Guide 1.9 xei m                raft Regulatory Guide, DG-1021, " Selection, Design, Qualification, Testing, and Reliability of Emergency Diesel Generator Units Used as Class IE Onsite Electric Power Systems at Nuclear Power Plants"
                         " n Company offers the following comments regarding proposed draft 3 to Regulatory Guide (R.G.) 1.9 (Reference).
The draft is intended to provide guidance on Emergency Diesel Generator (EDG) reliability programs and degradation of EDG performance supporting proposed revisions to the existing Station Blackout Rule that are yet to be promulgated. Licensees have implemented EDG reliability programs using the guidance of NUMARC 8700, " Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors". The NRC has andorsed the guidance of NUMARC 8700 as an acceptable methodology in safety evaluation reports governing Station Blackout Rule implementation. The proposed revision to R.G. 1.9 mostly tacludes the guidance from NUMARC 8700.
Boston Edison Company does not support the proposed revision, as the incorporation of detailed guidance from NUMARC 8700 into R.G, 1.9 does not add benefit or present substantive additional guidance for licensees.
4 kW          UIJ R. A. Anderson (
WGL/clc/rev3rgl9 9207210243 920710 PDR- REGGD 01.009 C                               PDR                                                                                   ,
_ _ _ _ _ _ _ _ _ _ _ _}}