ML20079J496

Brief on Regulations & Guidance Applicable to Issue 16 Re Reliability of Transamerica Delaval Diesel Generators.Util Must Prove Generator Compliance W/Nrc Regulations & Stds or Replace Generators.Certificate of Svc Encl

ML20079J496
Person / Time
Site:	Perry
Issue date:	01/16/1984
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8401240333
Download: ML20079J496 (16)

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January 16, 198 T 7

g UNITED STATES OF AMERICA 00CKETED USHRC NUCLEAR REGULATORY COMMISSION 3

'84 JAN 20 All:35 L . ,

. ./ Before the Atomic Safety and Licensing Board

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In the Matter of )

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CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 COMPANY, ej al. ) 50-441

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, (Perry Nuclear Power Plant, )

Units 1 and 2) )

OCRE BRIEF ON PSIEATIONS AND GUIDANCE APPLICABIE 'IO ISSUE #16

'Ihe Licensing Board, by Menorandum and Order dated December 23, 1983,

• . admitted the contention proffered by intervenor Ohio Citizens for I

Besponsible Energy ("OCRE") concerning the reliability of diesel g generators manufactured by Transamerica Delaval:

Issue #16: Applicant has not demonstrated that it can reliably generate emergency on-site power by relying on four Transamerica Delaval diesel generators, two for each of its Perry units

[sinplified from OCRE's original contention) .

'Ihe Board stated that Applicants, upon wham rests th'e burden of proof (10 CFR 2.732), "will be permitted to demonstrate the invalidity of the contention or that OCRE's concerns have been resolved by appropriate action, in compliance with 10 CPR Part 50, Appendix B, Generdl Design Criterion 17, and applicable guidance." Pamorandum 40E and Order at 2. 'lhe Board also ordered the parties to file briefs ae n.

&, on th'eapplicable guidance and reg 61ations, a move which OCRE considers o-t prudent, as early resolution of such questions will sinplify the 68 '

ae SE 1/ Although the Board's Order directed that briefs be filed by hC Tanuary 20 by express mail, service by 1st class mail 5 days earlier is acceptable, pursuant to a tel+ phone conversation between OCRE and p the Board Chairman on December 27, 1983.

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litigation of Issue #16. This is especially desirable in that the qualitstive term " reliability" seems open to subjective interpretation which might create conflict and comolications.

P OCRE files this brief in the hope that the Board will adopt the inter-pretations delineated below.

Specifically, OCRE has examined regulations, previous litigation, regulatory guidance and standards, and staff reports; these are discussed in detail belcw. OCRE also proffers a proposal concerning the standards which should govern the resolutien of this issue. .

I. Regulations

! While no regulations exist pertaining specifically to diesel generators ("DGs"), General Design Criterion 17 ("GDC 17") of Appendix A to 10 CFR Part 50 and the criteria of Appendix B to that section are 2/

certainly applicable.-~ It should be remembered that a nuclear facility must meet all of the Ccmmission's regulations; it cannot be argued that, even though the regulations are not met, the plant will be safe anyway.

See Vermont Yankee Nuclenr Power Corp. (Vernent Yankee Nuclear Power Station) , AIAB-138, 6 AEC 520, 528-29 (1973),

GDC 17 requires an onsite electric power system having " sufficient independence, redundancy, and testability to perform (its] safety functions assuming a single failure," CtRE believes that Issue #16 essentially questions whether an onsite AC power system relying on two Transamerica Delaval DGs per unit is truly independent and redundant, hen the un-reliability of the DGs is so great as to be a dcminant source of

_2/ hhile all 18 criteria of Appendix B are applicabIe, Criterion 3, Design Control, seems especially pertinent, since,.as the Board has pointed out, many of the troubles with Delaval DGs appear to be desien N ficienciec.

ccmon-mde failure. Tnis is considered further in the discussion 3/

of AIAS403, infra, which advanced sane interpretations of GDC 177 II. Previous Litigation

'Ihe only previous litigation which dealt with DG reliability is the Appeal Board's investigation of the adequacy of electric pcuer systems at St. Lucie Unit 2. See Florida Pcuer and Licht (St. Lucie Nuclear Power Plant, Unit 2), AIAB-603,12 NRC 30 (1980) . Although the Appeal Board's concern was prarpted by a suggestion (substantiated by the applicant's operating experience) that Florida'.s peninsular shape made Florida Power's grid less reliable than'those in other parts of the country, the Appeal Board stated that its finding (that station blackout be made a design basis event for St. Lucie Unit 2) could well be applicable "at nest power reactors." 12 NBC at 32.

The St. Lucie decision developed an important interpretation of GDC 17 specifically concerning the relevance of the " single failure" criterion to DGs. The Appeal Board held that "Ca)lthough the single failure concept;may well, provide adequate assurance of plant safety and public protection sten the spent in question has a very srall probability of failure, it beccmes increasingly suspect when the equipment can be expected to fail at a higher rate [Id. at 49) ...

the single failure standard appears in Ccmission criteria, which, according to their own introductory terms, (1) are inccmpletely developed, (21 establish only minimm require: rents, and (3) reflect the expectiation that ' additional or different criteria' will have to be ' identified 3/ In accordance with Vernent Yankee, sunra, it must be seen that Splicants cannot claim full ccmpliance with GDC 17 bv shcuing that offsite pcwer sources are reliable (i.e. , the probability of loss of offsite pcuer is lcu), sin GDC 17 clearly reauires onsita power sources to be reliable as well.

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and satified in the interest of public safety' in ' unusual' situations.

For the reasons cited above, we conclude that the circumstances present l

here call for such additional neasures. The diesel generators employed for emergency onsite power can only be characterized as relatively unreliable pieces of equiunent. Blind reliance on the single failure criterion (that is, sinple redundancy) does not provide an adegaate degree of plant safety and public protection in this state of affairs." (Id at 52, footnote omitted.]

m us, it is clear that Applicants cannot rely on the simole redundancy of AC onsite pwer systers to avoid the issue of Delaval DG reliability. It is of significance that the Appeal Board in St. Lucie regarded DGs 'iri general to be unreliabie. Wat Board was no't aviare of the problems and failures of DGs manufactured by Delaval. Because of the conmon < node failure potential of such deficiencies, OCRE regards this situation to be one of the " unusual" circumstan s requiring the abandonement of the single failure standard.

III. Pegulatory Guid6's and Associated Standards At the outset, it must be observed that regulatory guides are not

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regulations and thus need not be follw ed by licensees, and do not purport to represent the only satisfactory neans of meeting regulatory requirements.

Gulf States Utilitics (River Bend Station, Units 1 and 2), AIAB-444, 6 NRC 760 (1977).. Hwever, they are useful as guidance as to acceptable means of meeting regulatory requirenents [Id,], and conformance with the guides is likely to result in regulatory ccupliance. Petition for Emergency and Pe:n2 dial Action, CLI-78-6, 7 NRC 400, 406-7 (1978) .

Furthermore, regulatory guides are entitled to consi&rable prima facie weight. Vernent Yankee Nuclear P mer Coro. (Vermont Yankee thclear

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Pcuer Station), CLI-74-40, 8 AEC 809, 811 (1974) . l i

a Given this backgromd, it is obvious that, although Applicants are not requried to comply with the regulatory guides concerning DG relichilitv, Sey defia.itely bear the burden of p:rof should they choose another method of fulfilling the regulatory require:nents of GDC 17 and Appendix B. Indeed, in view of the unusual circumstances surrounding Delaval DGs, Applicants should have to show cause why ccmpliance with these regulatory guides (or even more stringent standards) is not mandatory.

Regulatory Guide 1.9, " Selection, Design, and Qualification of Diesel Generator Units Used as Standby (Onsite) Electric Power Systems l

at Nuclear Power Plants", Revision 2, December 1979, and Regulatory Guide 1.108, "Feriodic Testing of Diesel Generator Units Used as Onsite Electrict Power Systems at Nuclear Power Plants", Revision 1, August 1977, are the only regulatory guides identified by OCRE which deal specifically with DGs-~4/

Regulatory Guide 1.9 advances the position that conformance with IEEE Standard 387-1977 is acceptable for meeting the requirments of 5/

the principal design criterTa and qualification testing of DGs (subject to several conditions and/or clarifications outlined in that s

' 4/ Additional or differing guidance may be forthcoming. See Attachment 1, Trcm NUREG-0933, "Prioritization of Generic Safety Issues," concerning Unresolved Safety Issue B-56, on DG reliability. Although this issue was

> given high priority in that NUREG, OCRE is not aware of any rurthei-develognents on its resolution since the issuance of NUREG-0933 in J

November 1982. Hence, it is prudent to proceed on the basis of existent

- regulatory guidance; OCRE would echo the Appeal Board in ALAB-603 that "our resolution of the issues now before us ca".not await ecmoletion of the Staff's generic review." 12 NRC at 46, fconnote 55.

J/ GDC 17 and Criterion III of Appeniix B are cited.

Guide). Although Revision 2 of Pegulatory Guide 1.9 is applicable to applications docketed after December 1979, use of the stringent requirements of Revision 2 seems appropriate in the unusual circurstances 6l of severe documented deficiencies in Delaval DGs-IEEE Standard 387-1977 is applicable to the diesel engine, including the flywheel, the ccrnbustion air system, the starting system, the starting system energy sources, the fuel oil system, the lubricating oil system, the cooling system, the exhaust system, and the governor system, the generator, the control, protection, and surveillance systems

. associated with the diesel engine, the AC and DC distribution systems associated with the diesel engine, and those elements of the system necessary for maintaining the DG is a warm standby condition. The Standard states that the DG shall conform to the applicable portions of the following standards: ANSI C50.5-1955, Rotating Exciters for Synchronous Machines; ANSI C50.10-1977, General Requirerents for Synchronous Machines; ANSI C50.12-1965, Requirements for Salient Pole Synchronous Generators and Condensers; API Std 650, Walded Steel Tarks for Oil Storage; DEt%, Standard Practices for Ia4 and Mediun Speed Stationary Diesel and Gas Engines; IEEE Std 115-1965, Test Procedures for Synchronous Machines; IEEE Std 308-1974, Standard Criteria for Class lE Power Systems for Nuclear Power Generating Stations; IEEE Std I

l 3?3-1974, Standard for Qualifying Class lE Equipraent for Nuclear Power Generating Stations; IDR FD-1-1972, Motors and Generators; MFPA No 37, Standard for the Installation and Use of Stationary Combustion Engines l

6/ "he foreword to T m Std 387-1977 even states that " adherence to Eese criteria ray not sufiice for ass"ri g -de p.ilic he:Li =d safety" due to the influence of the integrated perfor ance of plcnt systems. Obviously no exemptions from these requirements should be considered.

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and Gas Turbines; TEMA, Staridards of Tubular Exchanger Manufacturers' l Association; IEEE Std 344-1975, Reccnmended Practices for Seismic Qualifica-tion of Class lE Equignent for Nuclear Power Generating Stations. Of these, the DEMA standards seem especially applicable, as Irany of the documented deficiencies of Delaval DGs concern the design of the diesel 7/

engine'~~ Section 5.6 of IEEE Std 397-1977 sets standards for mechanical and electrical design features, including vibration, torsional vibratien, and overspeed. Section 6.3 requires type qualification testing of D3s of' types not previously qualified as standby power sources.for nuclear power plants. Section 6.3 requires "a total of 300 valid start and loading tests" to be performed "with no more than 3 failures allowed.

If the 300 tests are . spread over nere than one unit, each unit shall be started and loaded' at least 100 times. ' Failure of the unit or units to successfully ccmplete this series of tests, as prescribed, will require 4

a review of the system design adequacy, the cause of the failures to be corrected, and the tests continued until 300 valid tests are achieved without exceeding the 3 failures allowed." [Std at 14; the Std goes on to define the condition.s for testina.]

i Similarly, Regulatory Guide 1.108 states thht:

f High reliability must be designed into the diesel generator units and naintained throughout their service lifetime by appropriate testing, maintenance, and operating programs. Branch Technical Position EICSB 2, " Diesel Generator Reliability Qualification Testing,"

dated 11/24/75, of the Standard Paview Plan (Arpendix 7-A of NUREG-75/087) i establishes a reliability goal of 0.99 (at a nominal 50% confidence level) and an acceptable qualification testing program for diesel generator units I

'Ihe DEMA (Diesel Engine Manufacturers' Association) Standards l

J cover subjects such as engine construction, governors and speed l

regulation, torsional vibratiens and critical speeds, intake and i

exhaust systems, cooling water systems, lubricating oil systems, selection of engine sizes, erection of engines, etc. (Taken frcm l

' the Table of Contents of the 5th edition, 1958 standards; a 6th edition, 1972, is referenced in the enclosures to EN-83-160A.)

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of a type or size not previously used as standby emergency power sources in nuclear power plants, h e preoperational and periodic testing provisions set forth in this guide have been designed to provide a basis for taking those corrective actions needed to maintain high inservice reliability of installed diesel generator units. In addition, the data developed will provide an ongoing denenstration of performance and reliability for all diesel generator units after installation and in service. Reliability objectives concerning the entire onsite electric pcwer system's probability of failure depend on the interconnections among the system's ccmponents and are not within the scope of this guide,

" Failure" is taken here to mean the failrue to start, accelerate, and assume the design-rated load within and for the time prescribed during an emergency or a valid test. (Reg. Guide 1.108 at 1.]

m is regulatory guide a'dvances a testing program for individual DG units at nuclear power plants. Specifically, Applicants simuld demonstrate the required reliability by means et any 69 consecutive valid tests (per plant) with no failures, with a minimum of 23 or 69/n tests, whichever is the larger, per diesel generator unit (where n is equal to the ~ number of' diesel generator units of.the same design and size), [Id. at 3]

Further guidance defines " valid tests", " valid failures", " successful starts", etc., and sets forth testing intervals (dependent on the number of failures cbserved)' and 2.eporting requirements. The regulatory guide also states that " subsequent to any failure, the cause should be determined and corrective action taken in a timely manner, with enphasis on pre ~ venting reoccurrence of the failure." (Pegulatory Position C.l.d, p. 2] If many failures are observed (7 or more in the last 100 valid tests) . special actions and evaluationc nust be taken.

Both Pegulatory Guide 1.108 and IEEE Std 387-1977 establish a reliability goal of 0.99 for DGs. Clearly, the PNPP DGs must meet this goal. Strict ccmpliance with %gulatory Guides 1,9 and 1.108, Tm Std 387-1977, and all other applicable standards should be required.

OCRE would go even further: since the severe failures identified in Transamerica Delaval DGs place their reliability in grave doubt, the

_9-l DGs to be used at PNPP should undergo the type testing of IEEE Std i

387-1977, i.e., 300 start and load tests, of at least 100 per DG, in place of the less stringent preoperational testing of Pegulatory .

Guide 1.108.

IV. Staff and Contractor Reports Although Staff and mntractor repcrts have no legal significance for any regulatory purpose and.are entitled to less weight than an accepted regulatory guide (Southern California Edison (San Onofre Nuclear Generating Station, Units 2 and 3), AIAB-268,1 NBC 303 (1975)),

they may provide useful information helpful to the Board and parties

> on the issue of DG reliability. E.g,, the Appeal Board in St. Lucie used data in the Peactor Safety Study to help reach its conclusion that DGs are relatively unreliable. AIAB-603, 12 NRC at 49.

OCRE has identified 4 Staff and contractor reports, NCREG-0873, NUREG/CR-0660, NUREG/CR-1362, and NUREG/CR-2099, pertairdng to DGs.

Abstracts of thase NUREGs, taken from NUREG-0304, "Ccmpilation of Regulatory and Technical Reports," are included in Attachment 2.

Apparently none of these reports pertains specifically to Delaval DGs (although OCRE has not analyzed these documents further to verify this) .

OCRE would propose that the parties be permitted to rely on such publications, if they are relevant to Issue #16, on Delaval DG reliability, and if they are supported by other evidence.

V. Conclusion For all the foregoing reasons, OCRE concludes that:

1. Applicants must demonstrate that their Transamerica Delaval DGs comply with CDC 17 and the criteria of Appendix B to 10 CFR 50, especially Criterion III. Applicants cannot tak'e credit for the

_lo-the reliability of offsite powe.t or for simple redundancy (single failure standard).

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2. Applicants nust denenstrate that their Delaval DGs ccrply with all l provisions of Regulatory Guide 1.9 (and associated IEEE and DII% standards) i and Regulatory Guide 1.108, and, in addition, Applicants must subject the

. PNPP DGs to type testing as in IEEE Std 387-1977, Section 6.3.2

3. Should empliance with the above not be possible, Applicants

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I nust show cause why they should be amnpt frcm these regairements.

If ccznpliance with a regulation is to be waived, Applicants nust meet the standards of 10 T R 2.758 for waiver of a Conmission rule. If ccrtpliance with a regulatory guide is questioned, a less stringent standard for exe:rption would be required. Clearly, Applicants nust always neet the burden of proving that t. heir facility is safe, in accordance with 10 T R 2.732. If exemption frcrn regulatory requirements is not granted, Applicants must take other action, e.g, replacing the Delaval DGs with DGs frczn another manufacturer, or adding a third DG, as proposed by OCRE, to neet said requirenents.

Pespectfully submitted, A ( M Susan L. Hiatt OCRE RepresentM;ive 8275 Munson Rd.

- Mentor, OH 44060 (216) 255-3158 D

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AWM-M n'EN 7 l ITEM B-56: DIESEL RELIABILITY DESCRIPTION Historical Backcround l

In the third quarter of 1977, 00R initiated General Safety Issue B-57, " Diesel l Generator Reliability," Clemenson 1977. This safety issue was promulgated by a review of LERs which indicated that emergency onsite diesel generators at oper-ating plants were demonstrating an average starting reliability of about 0.94 per demand. The NRC's goal for new plants as expressed in Regulatory Guide 1.1082as is a diesel generator starting reliability of 0.99 per demand. The NRC awarded a contract to the University of Dayton Research Institute to iden-tify the more significant causes of diesel generator unreliability. The Dayton University study is now complete and the significant causes and recommended corrective action are identified in NUREG/CR-0660.217 This issue was identified in NUREG-0471.3 Safety Significance -

Events (offsite and onsite) which result in a-loss-of-offsite power necessitate reliance on the onsite emergency diesel generators for successful accident mitigaticn. Improvement of the starting reliability of onsite emergency diesel generators will reduce the probability of events which could escalate into a core-melt accident and thus could effect an overall reduction in public risk.

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Possible Solution .._

DST has proposed a set of interim requirements to be backfit to operating ,

plants which encompasses elements of Regulatory Guide 1.108 and the Dayton University recommendations in NUREG/CR-6060. This set of requirements has received preliminary approval,by both DSI and DL. Technical resolution of Item 8-56 will not be complete until final DST, DSI, DL, and NRR agreement is reached.

The proposed program is described in a DST memorandum 21s issued on May 6, 1982.

The proposed program establishes a graded set of requirement:5 based on the reliability actually exhibited by diesel generators. The proposed program adopts a diesel generator startup reliability of 0.95/ demand as the minimum desired reliability and 0.9/ demand as the minimum acceptabic level o# reliabi-lity. At or below tne minimum desired level, licensees would be required to improve their diesel generator reliability and document their program for doing so. Below the minimum acceptable level, licensee:; would be required to improve or repair diesel genercters with reliability below the minimum acceptable ' level and perform'a requalification program to demonstrate that the causes of the l failures have been corrected. The requalification program is intended to pass I

diesel generators only if the reliability has been increased to 0.95/ demand or greater.

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1 2.B.56-1 NUREG-0933 Rev. O

The proposed interim program imposes a normal surveillance. period of no more than one month. To increase assurance that a real change in reliability will be detected quickly, an increased test frequency would be required when two or more failures have been experienced on an individual diesel generator in the last 20 demands. However, the frequency of tests and the anticipa ed duration of the accelerated test frequency are not as restrictive as currently recom-monded by Agulatory Guide 1.108.

An extended out-of-service period may, in many cases, be necessary to allow sufficient time to correct the problems that are causing low reliabilities.

Therefore, the proposed program will allow out-of-service periods in excess of the current 72-hour limit, when necessary, while at the same time placing a yearly limit upon the cumulative time that a plant may operate in modes 1 through 4 with one of the diesel generators of the power systems inoperable. The cumulative limit would vary depending upon the reliability of the inservice diesel generator with the lowest reliability.

PRIORITY DETERMINATION Technical analysis of this issue was performed by PNL and documented in NUREG/CR-2800.G4 Since the issue is presumably generic, risk analysis was performed on both PWRs (using Oconee 3 as typical) and BWRs (using Grand Gulf Unit 1 as typical).

Since the proposed position is expected only to aff.ect those diesel generators which have demonstrated a reliability of less than 0.95 per den'and it was assumed that 25% of the diesel generator population undergoes a reliability improvement ,

from 0.93 to 0.97 per demand and 5% of the population undergoes a reliability i improvement from 0.9 to 0.97 per demand (requalification).

Frecuency/Consecuence Estimate When the frequency of all core-melt scenarios which include diesel generator failure was adjusted to include the above assumptions, it was found that the

• proposed solution would be expected to result in a significant core-melt fre-quency reduction for both the 25% diesel generator population and the 5% diesel generator population. The 25% diesel generator population which was assumed to improve from 0.93/demarid to 0.97/ demand would have core-melt frequency reduc-tions of 1.7 x 10 5/RY and 2.3 x 10 5/RY for BWRs and PWRs, respectively. The 5% diesel generator population which was assumed to improve from 0.9/ demand to 0.97/ demand would have core-melt frequency reductions of 3.7 x 10 5/RY and 705 x 10 5/RY for BWRs and PWRs, respectively.

Base Case Risk for both the PWR and the BWR plants was calculated by multiplying the expected frequency of each release cctegory by the dose equivalent value for the category. Adjusted case risk was determinec by the same technique using the core-melt frequency reduction calculated for the reliability improvement expected in the resoective die 3el generator populaticns (25% and 5%) for both the FWR and SWR plants. The adjusted risk was subtrac:cd from the basa case risk and the public risk reduction thus obtained was multiplied by the appro-priate number of PWRs and BWRs. The total public risk reduction thus deter-mined is 6.5 x 104 man-rem, with an average public risk reduction of about 1.5 x 103 man-rem / reactor.

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2.B.56-2 NUREG-0933 Rev. O

l Cost Estimate NRC Cost: $130,000 was estimated to complete resolution of the issue, review and approve new requirements, und issue implementation orders. Review of plant responses to orders and periodic reports expected from plants which must develop and initiate diesel generator reliabili.ty improvement programs, and long-term surveillance of the industry was estimated at $1M. Thus, total NRC cost is estimated as 51.1M.

Industry Cost: It was assumed that 30% of the 143 expected plants will insti-tute a reliability improvement program. In addition, 5% of the plants were assumed to incur a major equipment (diesel generator) replacement and an asso-ciated loss of power production. Industry costs were estimated for revision of operating procedures and personnel training, installation of additional equip-ment (air dryers, dust-tight enclosures for electrical conta:.ts, diesel genera-tor room ventilation ducting, etc.) and ongoing increases in operation and main-tenance costs. Total Industry Cost is estimated at $46M.

Avoided Accident Cost: An unusually significant avoided accident cost was calculated for the resolution of this issue. The avoided accident cost repre-s.ents the expected savings to the industry in total due to lowering the expected core-melt frequer:y by implementation of a specific improvement. It is calcu-lated by multiplying the expected costs of the loss of a plant (s $38) by the expected total core-melt frequency reduction. In this instance the avoided accident cost (actually a savings to the industry) is estimated to be $30M.

Value/ Impact Assessment Based on a total, risk reduction reduction of 6.5 x 104 man-rem, the value/ impact score is given by man-rem 3 = 6.5 x 104 .

$(1.13 + 46)M

= 1380 man-rem /$M. ,.

CONCLU3 ION The calculated value/ impact score is indicative of a medium priority assignment.

However, other factors prevail in the case of this issue. The very large expected total public risk reduction (6.5 x 104 man-rem) and the high expected core-melt frequency reduction (greater than 10 5/RY), would elevate the priority of this issue. In addition, if the averted accident cost (industry savings) is sub-tracted from the total cost in the denominator of the above equation, a value/

impact score of 3800 man rem /SM is calculated. This score is also indicative of a high priority assignment. Therefore, we recommend that Item B-56 be. con-sidered a HIGH priority issue.

REFERENCES

3. NUREG-0471, " Generic Task Problem Descriptions (Categories B, C, and D),"

U. S. Nuclear Regulatory Commission, June 1978.

2.B.56-3 NUREG-0933 Rev. O

64. NUREG/CR-2800, " Guidelines for Nuclear Power Plant Safety Issue Prioritization Information Development," U. S. Nuclear Regulatory Commission.

216. Regulatory Guide 1.108, " Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," U. S. Nuclear Regulatory Cobmission, August 1977.

. 217. NUREG/CR-0660, " Enhancement of On-Site Emergency Diesel Generator Reliability,"

U. S. Nuclear Regulatory Commission, February 1979.

218. Memoiand"m for D. Eisenhut, et. al from S. Hanauer, " Diesel Generator

. Reliabi'ity of Operating Plants," May 6, 1982.

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2.B.56-4 NUREG-0933 Rev. 0

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ffKdtiinAlf X NUREG-0873: A D AYESIAN ANALYSIS OF DIESEL GENERATOR DivisionFAILURE of Risk DATA.

VESELY,W.E.i NIYOGI,P.K.s GOLDDERG,F.F.s et al.11659:140.

Analysis. January 1982. 48pp. 8201220034.

A vimple Bayesian approach has been developed to evaluate failure

{ rate implications from the number of For in a given number of diesel tests.

failures and number of successes the Bayesian approach, the diesel is modeled as having a constant probability of failure per trial are describable by a which is unknown and whose possible values probability d istrib ution. The approach utilizes discrete probability distributions (probability mass functions) f or ease of implementation.

As a potential tool for the analyst, a computer code has been written to efficiently calculate the diesel posterior failure rate dist'ibutions for any input diesel test data and assumed prior distribution. The code can be used toIn monitor addition, diesela widetestsvarietg f or of up-to-date failure rate implications.

sensitivity analysis can be performed using the code.

Enhancement of On-Site Emergency Diesel Generator Reliability.

NUREG/CR-0660 February 1979.

University of Dayton Research Institute UDR-TF-79-07

• CNRR NTIS The University of Dayton Research Institute has concluded a program designed to provide NRC/ DOR with technical s'ssistance in evaluating the factors Theleading program to

• improved reliability of onsite emergency dieselThis generator information (DG) units. c comparative evaluation of the DG manufacturer's recommendations.

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The will enable the NRC to improve the basis on which it makes regulatory decisions.

/ primary goal of the program is, to better identify the main problem Theareas which report has j decrease the reliability of the DG units and make recommendations.

attained the program objectives by identifying and discussingThe the identified more significant problems problema and presenting the recommended corrective actions.

categorized into three groups as a function of their significance.

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have be Data Summaries of Licensee Event Reports of Diesel Generators of U.S. Commercial AIC/CR-1362 Fuelear Power Plants from January 1,1976, to December 31, 1978.

tiarch 1980.

EG&G Idaho f '

EGG-EA-5092 ONRR GPO. NTIS.

This report describes the results of an analysis of nuclear plant Diesel Generator failures. The data used for this analysis were the Licensee Event Reports (LERs).

The LERs are written reports filed with the NRC whenever certain failures or incidents occur concerning nuclear plant safety systems. The Diesel General failures or inci-dents contained in the LERs were evaluated and categorized as to type of failure or problem and were used to calculate sumary In addition Diesel to the Generator fa quantitative important failure modes or other fail'ure information. failure rate information, there to allow the user to make additional Diesel Generator (ailure rate calculations or inferences. _ - -

NURE G/CR-2099: COMMON CAUSE FAULT RATES FOR DIESEL GENERATORS: ESTIMATES COMMERCIAL NUCLEAR POWER BASED ON LICENSEE EVENT REPORTS AT U. S. EG&O, Inc. June 1992.

PLANTS, 1976-1978. ATWOOD.C.L.s STEVENSON,J.A.

87pp. 820706,0337. 13744:106.

This rep ort presents estimates of common cause f ault rat es and r e l a t.e d quantities, based on Licensee The Event Reports Licensee Event for diesel-Report da ta base generators in nuclear reactors.

For estimating rates, the binomial f ailure rate model is described.

is used, extending to allow for the substantial observed p lant-to-plan t variability, and for shocis that by their nature make all the diesel generators in a plant inoperable. Every quantity All rates are is estimated by both a point estimate and a 90% interval. {

expressed per calendar hour.

CERTIFICATE OF SERVICE ,. .j 00gEif p

This is-to certi'fy that copies of the foregoing were served by depogs'tintheU.S. Mail, first class, postage day of CCimou ,

prepa'84, JAlh28 A11:35

,1984 to those on the

/6 service list b,elow. Q' . c.pp,j, 3 g ,, .

. 00CELTit,G & SEby i

. ,.,..  : BRANCH

,W &

Susan L. Elatt I LERVICE. LIST -

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- Peter B. Bloch, Chairman Terry Lodge, Esq.

Atomic Safety &' Licensing Board 618 N. Michigan St.

U;S. Nuclear Regulatory Comm.

i Suite 105 Washington,'D.C. 20555 .,, Toledo, OH 43624 Dr. Jerry R..Kline Atomic Safety.& Licen. sing Board.

U.S. Nuclear. Regulatory Commission i

' Washington,-D.C. 20555 ,

Mr..Glenn O. Bright Atomic, Safety &. Licensing Board U.S. Nuclear Regula.ory t Commission Washington, D.C. 20555

.- Colleen P. Woodhead, Esq. ,

' Office of the~ Executive Legal Director U.S. Nuclear Regulatory Commission .

Washington,.D.C. 20555 Jay.Silberg, Esq. .

Shaw, Pittman; Potts, & Trowbridge 1800 M Street, NW

• . Washington, D.C. 20036 Docketing & Service Branch i

.Offi~ce of'the Secretary U.S.. Nuclear Regulatory.. Commission Washington, D.C. 20555 Atomic. Safety.&. Licensing Appeal. Board Panel U.S. Nuclear", Regulatory Commission

. . Washington, D.C. 20555

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