ML20134P068

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Comment on Draft Rg DG-1051, Monitoring Effectiveness of Maint at Npp
ML20134P068
Person / Time
Site: Millstone, Haddam Neck  File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 11/14/1996
From: Feigenbaum T
NORTHEAST NUCLEAR ENERGY CO.
To:
NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-61FR47987, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 61FR47987-00003, 61FR47987-3, NUDOCS 9611270222
Download: ML20134P068 (2)


Text

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S!AY' # l Eld j . '"\ NortheastTe &# i *d* 8"*"' * "' 37 l Utilities System wthe..t utue. service cey 3 i

P.O.Ikn 270

. ~.*, ', *; Q llartford, CT 06141-0270 (860) 665-5000 7M KGV 26 Py 7. y OULES Lib , November 14,1996 [

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Docket Nos. 50-213 l 50-245- l 50-336  !

50-423 B15997 1

l Rules Review and Directives Branch, DFIPS Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555 Millstone Nuclear Power Station, Unit Nos.1,2 and 3 Haddam Neck Plant Comments on Draft Regulatory Guide DG-1051, i Monitorina the Effectiveness of Maintenance at Nuclear Power Plants l

The Nuclear Regulatory Commission (NRC) issued Draft Regulatory Guide DG-1051,

" Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," for review and l comment in August,1996. Draft Regulatory Guide DG-1051 is a proposed Revision 2 to Regulatory Guide 1.160. This letter transmits comments on Draft Regulatory Guide DG-1051 on behalf of Northeast Nuclear Energy Company (NNECO) and Connecticut Yankee Atomic Power Company (CYAPCO) for Mi'Istone Unit Nos.1, 2 and 3, and i Haddam Neck Plant, respectively. l Millstone Unit Nos.1,2 and 3, and Haddam Neck Plant agree with the general intent of

! the draft Regulatory Guide to endorse Revision 2 to NUMARC 93-01. In addition, the 4 following two specific comments are provided: I I

1. The wording in the last paragraph in the " Emergency Diesel Generators" section  !

conflicts with that provided in NUMARC 93-01. Specifically, Draft Regulatory Guide i DG-1051 states that "A_jl SSCs within the scope of the rule ..... are subject to the i requirements of 10CFR50.65(a)(3), including (1) periodic evaluation, (2) balancing reliability and unavailability, and (3) assessing the impact....." The conflict is with 4

item (2) of this statement. Section 12.2.4 of NUMARC 93-01 statet that the (a)(3) 1 j$A**188E nssyga J ho-/I6 4 / "* E i o

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,. ' U.S. NuclIar Regul: tory Commission B15997\Page 2 1

1 requirement for balancing reliability and unavailability gnly applies to risk significant Structures, Systems and Components (SSC) and not all in-scope SSCs as indicated in Draft Regulatory Guide. DG-1051. Unavailability is only monitored for risk significant systems.

2. It is not clear why this paragraph is provided in the " Emergency Diesel Generator"  !

(EDG) section as this discussion on the requirements of 10CFR50.65(a)(3) is a i generic issue and not specific to the EDGs.

Should you have any comments or questions regarding this matter, please feel free to i contact Mr. Kevin Hastings, Maintenance Rule Project Manager at (860) 447-1791, ext.

~

5204 or Mr. Steve Scace at ext. 5372.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY I CONNECTICUT YANKEE ATOMIC POWER COMPANY fM T. C. Feigenblium Executive Vice President and r Chief Nuclear Officer cc: U.S. Nuclear Regulatory Commission Attention: Document Control Desk ,

Washington, DC 20555 l

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