ML18004A599
| ML18004A599 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/06/1986 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NLS-86-386, NUDOCS 8610210017 | |
| Download: ML18004A599 (4) | |
Text
ACCESS(ON 4BR FAC IL: 50-400 AUTH. NANE CUTTER> A. B.
REC IP. NAi'lE DENTON, H. R.
REQUL RY INFORMATION DIBTRIBUTI SYSTEN (RIDB) 8610210017 DOC. DATE: 86/10/06 NOTARIZED:
NO DOCKET Shearon Harris Nuclear Power Plant>
Unit 1> Carolina 05000400 AUTHOR AFFILIATION Carolina Power 8c Light Co.
RECIPIENT AFFILIATION Office of Nuclear Reactor Regulation>
Director (post 851125
SUBJECT:
Responds to NRC concern re replacement criteria for limited life components 8r equipment in safety-related applications located in plant non-harsh environs. Commitments addressing NRC c onc em listed.
DIBTR IBUT ION CODE:
A048D COP IEB RECEIVED: LTR ENCL BI ZE:
TITLE: QR/Licensing Submittal:
Equipment Qual ification NOTES: Application for permit renewal filed.
05000400 REC IP IENT ID CODE/NANE PNR-A ADTB PNR-A PD2 LA BUCKLEY>B 01 COPIEB LTTR ENCL RECIPIENT ID CODE/NANE PNR-A EB PNR-A PD2 PD 12 COPIES LTTR ENCL INTERNAL
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REG FIL 12 13 04 EXTERNAL: LPDR NSIC 03 05 NRC PDR 02 TOTAL NUNBER OF COPTER RERUTRED:
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SERIAL: NLS-86-386 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO. I DOCKET NO.50-000 SEISMIC QUALIFICATIONOF SAFETY-RELATED EQUIPMENT
Dear Mr. Denton:
Carolina Power &. Light Company has given due consideration for the staff concern regarding the replacement criteria for limited life components and equipment in safety-related applications throughout the plant located in non-harsh environments.
We have a comprehensive maintenance and surveillance program with an emphasis on preventive maintenance.
However, we understand that the staff concern stems from the concept of qualified life defined in IEEE Standard 323-1970 and endorsed by the Standard Review Plan, Section 3.10.
In order to address the staff concern for safety-related equipment located in non-harsh environments, we commit to the following:
I.
A periodic maintenance, inspection, and replacement program based on sound engineering practice and recommendations of the equipment manufacturer which is updated as required by the results of an equipment surveillance program.
2.
A periodic testing program to verify operability of safety-related equipment within its performance specification requirements (system level testing of the type typically required by the plant technical specifications may be used).
3.
An equipment surveillance program which includes periodic inspections, analysis of equipment and component failures, and a review of the results of preventive maintenance and periodic testing programs.
In addition, we have reviewed the procurement specifications for the station batteries and have determined that the battery is specified for 20 years of normal plant operation plus I year of post-accident operation.
This information willbe incorporated into our maintenance program listed in Nos. I, 2, and 3 above.
Similarly, procurement specifications of safety equipment such as remote panels, valves, and valve operators willbe reviewed to determine if procured equipment was specified by the vendor as less than 00-year life. If so, this information willalso be incorporated into our maintenance program listed'n Nos. I, 2, and 3 above.
If the life of the equipment is not specified in the procurement specification, action willbe taken to elicit information from the appropriate vendor or other suitable sources; and in those cases that the limited life is shorter than the life of the plant, appropriate replacement frequencies willbe incorporated in our maintenance and surveillance program.
8610210017 86100b 0~000400 Ie street
~ P. o, ao~ ass A
P.DR
Mr. Harold Denton
.Page 2, NLS-86-386 The results of our review pursuant to the commitment above willbe fullydocumented and available for audit by the NRC staff prior to startup following the first refueling outage.
If you have any questions, please contact Mr. Pedro Salas at (919) 836-8015.
Yours ery trul PS/bmc (5020PSA) cc:
Mr. B. C. Buckley (NRC)
Mr. G. F. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC-RII)
A. B. Cutter - Vice Pre ident Nuclear Engineering R Licensing