ML20235Z414
| ML20235Z414 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/1989 |
| From: | Serkiz A NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Marion A NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| Shared Package | |
| ML20235S667 | List: |
| References | |
| RTR-NUREG-CR-5078, RTR-REGGD-01.009, RTR-REGGD-01.155, RTR-REGGD-1.009, RTR-REGGD-1.155 NUDOCS 8903150435 | |
| Download: ML20235Z414 (2) | |
Text
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0 2 MAR 1989
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Mr. Alexander Marion Nuclear Management and Resources Council
'. 1776 Eye Street, N.W.
Suite 300 Washington, D.C. 20006 i
Subject:
Comments on NUMARC 87-00, Appendix D dated January 3,1989
Dear Mr. Marion:
Enclosed are copies of comments received from the Electrical Systems Branch of NRR and E. V. Lofgren of SAIC based on their review of NUMARC's Appendix D dated Jan. 3, 1989. These comments reflect the need to further address many of the topics identified for follow-up in my meeting sunmary for meetings held l on January 25-26, 1989. We do not expect to transmit any further comments on this document at this time.
Since the March 13, 1989 closure date for comments on Regulatory Guide 1.9,
- Proposed Revision 3 is only a few days away, we would prefer that another meeting not be scheduled before receipt of NUMARC's comments on RG 1.9, Rev. 3 so that both Appendix D differing views and public comments on RG 1.9, Rev. 3 L
can be reviewed and then discussed in an integrated manner.
, We note that NUMARC 87-00, Appendix D dated November 20, 1987, states: "The
- reliable operation of on-site emergency AC power sources should be ensured by l a reliability program. For emergency diesel generators, such a program might be comprised of the following elements (or equivalent)
- .... " Also, Regulatory Guide 1.155, " Station Blackout," Section 1.2 states: "The reliable operation of onsite emergency ac power sources should be ensured by a j reliability program designed to maintain and monitor the reliability level of
, each power source over time for assurance that the selected reliability levels are being achieved. An EDG reliabilit the following elements or activitiesortheirequivalent): (y program would typically ....
be composed of It is clear from this nearly identical language, and the discussions held during the resolution of the Station Blackout safety issue, that both parties were committed to implementation of an adequate EDG reliability program.
However, use of language such as: "This appendix provides guidance on actions that may be implemented as appropriate to ensure..." in your opening paragraph in the Jan. 3, 1989, draft does not reflect previous understandings and commit-ments. He suggest that you reconsider continued pursuit of such language and guidance. For example, it would be more effective to define what the elements of an EDG reliability program should be comprised of, to identify surveillance and maintenance actions proven effective in achieving the industry-wide levels of EDG reliability achieved, and to provide guidance as to how such levels can be sustained, h
i h [)b r)' pud 8903150435 890302 A PDR REVGP ERGNUMRC / 'f PDC f
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t 0 2 MAR 1989 Please call me after you have reviewed the enclosures so that we can' mutually schedule a date for the next meeting.
Sincerely yours, ortsta l= p g a6 Aleck W. Serkiz, Senior Task Manager Reactor and Plant Safety Issues Branch Division of Safety Issue Resolution Office of Nuclear Regulatory Research
Enclosures:
As stated cc: w/ Enclosures T. Speis, RES J. Craig, NRR/SPLB R. W. Houston, RES E. Lofgren SAIC W. Minners, RES A. Payne, Jr. , SNL A. Thadani, NRR M. McGarry, BCP&R F. Gillespie, NRR J. Gaertner, EPRI S. Crockett, 0GC H. Wyckoff, EPRI F. Rosa, NRR/SELB DISTRIBUTION: RES Circ /Chron; NUDOCS; DSIR R/F; RPSIB R/F; ASerkiz; PNorian; KKniel; WMinners; WHouston; PDR; Central Filesi!
OA- it OFC: DSIR:RPSIB DfaIR:RPSIB DSI:RPSIB NAME: ASerkiz:jf PNorian KKniel DATE: 03/o1/89 03/02/89 03/02/89 "0FFICIAL RECORD COPY" I
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