ML18017A897

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SER Accepting Licensee Responses to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves
ML18017A897
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 10/04/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML18017A896 List:
References
GL-96-05, NUDOCS 9910070138
Download: ML18017A897 (15)


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+)t **W UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATIONBYTHE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE RESPONSE TO GENERIC LETTER 96-05 "PERIODIC VERIFICATIONOF DESIGN-BASIS CAPABILITYOF SAFETY-RELATEDMOTOR-OPERATED VALVES "

SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NUMBER 50-400

1.0 INTRODUCTION

Many fluid systems at nuclear power plants depend on the successful operation of motor-operated valves (MOVs) in performing their safety functions.

Several years ago, MOV operating experience and testing, and research programs sponsored by the nuclear industry and the U. S. Nuclear Regulatory Commission (NRC), revealed weaknesses in a wide range of activities (including design, qualification, testing, and maintenance) associated with the performance of MOVs in nuclear power plants.

For example, some engineering analyses used in sizing and setting MOVs did not adequately predict the thrust and torque required to operate valves under their design-basis conditions.

In addition, inservice tests of valve stroke time under zero differential pressure and flow conditions did not ensure that MOVs could perform their safety functions under design-basis conditions.

Upon identification of the weaknesses in MOV performance, significant industry and regulatory activities were initiated to verify the design-basis capability of safety-related MOVs in nuclear power plants. After completion of these activities, nuclear power plant licensees began establishing long-term programs to maintain the design-basis capability of their safety-related MOVs. This safety evaluation (SE) addresses the program developed by Carolina Power 8 Light Company (licensee) to verify periodically the design-basis capability of safety-related MOVs at the Sh~aron Harris Nuclear Power Plant (SHNPP).

2.0 REGULATORY RE UIREMENTS The NRC regulations require that MOVs important to safety be treated in a manner that provides assurance of their intended performance.

Criterion 1 to Appendix A, "General Design Criteria for Nuclear Power Plants," to Part 50 of Title 10 of the Code ofFederal Regulations (10 CFR Part 50) states, in part, that structures, systems, and components important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed.

The quality assurance program to be applied to safety-related components is described in Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50.

In Section 50.55a of 10 CFR Part 50, the NRC requires licensees to establish inservice testing (IST) programs in accordance with Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code.

99i0070i38 99l004 PDR ADOCK 05000400 P 'DR In response to concerns regarding MOVperformance, NRC staff issued Generic Letter (GL) 89-10 (June 28, 1989), "Safety-Related Motor-Operated Valve Testing and Surveillance," which requested that nuclear power plant licensees and construction permit holders ensure the capability of MOVs in safety-related systems to perform their intended functions by reviewing MOVdesign bases, verifying MOVswitch settings initiallyand periodically, testing MOVs under design-basis conditions where practicable, improving evaluations of MOVfailures and necessary corrective action, and trending MOVproblems.

The staff requested that licensees complete the GL 89-10 program within approximately three refueling outages or 5 years from the issuance of the GL. Permit holders were requested to complete the GL 89-10 program before plant startup or in accordance with the above schedule, whichever was later.

The NRC staff issued seven supplements to GL 89-10 that provided additional guidance and information on MOVprogram scope, design-basis reviews, switch settings, testing, periodic verification, trending, and schedule extensions.

GL 89-10 and its supplements provided only limited guidance regarding MOVperiodic verification and the measures'appropriate to assure preservation of design-basis capability. Consequently, the staff determined that additional guidance on the periodic verification of MOVdesign-basis capability should be prepared.

On September 18, 1996, the NRC staff issued GL 96-05, "Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," requesting each licensee establish a program, or ensure the effectivenes of its cur;ent program, to verify on a periodic basis that safety-related MOVs continue to be capable of performing their safety functions within the current licensing bases of the facility. In GL 96-05, the NRC staff summarized several industry and regulatory activities and programs related to maintaining long-term capability of safety-related MOVs. For example, GL 96-05 discussed non-mandatory ASME Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor Operated Valve Assemblies in LWR Power Plants, OM Code 1995 Edition; Subsection ISTC,"

which allows the replacement of ASME Code requirements for MOVquarterly stroke-time testing with exercising of safety-related MOVs at least once per operating cycle and periodic MOVdiagnostic testing on a frequency to be determined on the basis of margin and degradation rate.

In GL 96-05, the NRC staff stated that the method in OMN-1 meets the intent of the GL with certain limitations. The NRC staff also noted in GL 96-05 that licensees remain bound by the requirements in their code of record regarding MOVstroke-time testing, as supplemented by relief requests approved by the NRC staff.

In GL 96-05, licensees were requested to submit the following information to the NRC:

a.

within 60 days from the date of GL 96-05, a written response indicating whether or not the licensee would implement the requested actions; and b.

within 180 days from the date of GL 96-05, or upon notification to the NRC of completion of GL 89-10 (whichever is later), a written summary description of the licensee's MOVperiodic verification program.

The NRC staff is preparing an SE on the response of each licensee to GL 96-05. The NRC staff intends to rely to a significant extent on an industry initiative to identify valve age-related degradation which could adversely affect the design-basis capability of safety-related MOVs

'(described in Section 3.0) where a licensee commits to.implement that industry program.

The NRC staff willconduct inspections to verify the implementation of GL 96-05 programs at nuclear power plants as necessary.

3.0 JOINT OWNERS GROUP PROGRAM ON MOV PERIODIC VERIFICATION In response to GL 96-05, the Boiling Water Reactor Owners Group (BWROG), Westinghouse Owners Group (WOG), and Combustion Engineering Owners Group (GEOG) jointly developed an MOV periodic verification program to obtain benefits from the sharing of information between licensees.

The Joint Owners Group (JOG) Program on MOV Periodic Verification is described by the BWROG in its Licensing Topical Report NEDC-32719, "BWR Owners'roup Program on Motor-Operated Valve (MOV) Periodic Verification," and described by the WOG and the GEOG in their separately submitted Topical Report MPR-1807, "Joint BWR, Westinghouse and Combustion Engineering Owners'roup Program on Motor-Operated Valve (MOV) Periodic Verification." The stated objectives of the JOG program on MOV Periodic Verification are (1) to provide an approach for licensees to use immediately in their GL 96-05 programs; (2) to develop a basis for addressing the potential age-related increase in required thrust or torque under dynamic conditions; and (3) to use the developed basis to confirm, or ifnecessary to modify, the applied approach.

The specific elements of the JOG program are (1) providing an "interim" MOVperiodic verification program for applicable licensees to use in response to GL 96-05; (2) conducting a dynamic testing program over the next 5 years to identify potential age-related increases in required thrust or torque to operate gate, globe, and butterfly valves under dynamic conditions; and (3) evaluating the information from the dynamic testing program to confirm or modify the interim program assumptions.

The JOG interim MOVperiodic verification program includes (1) continuation of MOV stroke-time testing required by the ASME Code IST program; and (2) performance of MOVstatic diagnostic testing on a frequency based on functional capability (age-related degradation margin over and above margin for GL 89-10 evaluated parameters) and safety significance.

In implementing the interim MOVstatic diagnostic test program, licensees willrank MOVs within the scope of the JOG program according to their safety significance.

The JOG program specifies that licensees need to justify their approach for risk ranking MOVs. In Topical Report NEDC 32264, "Application of Probabilistic Safety Assessment to Generic Letter 89-'iu Implementation," the BWROG described a methodology to rank MOVs in GL 89-10 programs with respect to their relative importance to core damage frequency and other considerations to be added by an expert panel.

In an SE dated February 27, 1996, the NRC staff accepted the BWROG methodology for risk ranking MOVs in boiling water reactor nuclear plants with certain conditions and limitations.

In the NRC SE (dated October 30, 1997) on the JOG Program on MOVPeriodic Verification, the NRC staff indicated its view that the BWROG methodology for MOV risk ranking is appropriate ',=;

",o in.esp'~e to GL 96-05. With respect to Westinghouse-designed pressurized water reactor nuclear plants, the WOG prepared Engineering Report V-EC-1658, "Risk Ranking Approach for Motor-Operated Valves in

Response

to Generic Letter 96-05." On April 14, 1998, the NRC staff issued an SE accepting with certain conditions and limitations the WOG approach for ranking MOVs based on their risk significance.

Licensees not applicable to the BWROG or WOG methodologies need to justify their MOVrisk-ranking approach individually.

The objective" of the JOG dynamic test program are to determine degradation trends in dynamic thrust and torque,,and to use dynamic test results to adjust the test frequency and method specified in the interim program ifwarranted.

The JOG dynamic testing program includes (1) identification of conditions and features which could potentially lead to MOV degradation; (2) definition and assignment of valves for dynamic testing; (3) testing valves three times over a 5-year interval with at least a 1-year interval between valve-specific tests according to a standard test specification; (4) evaluation of results of each test; and (5) evaluation of collective test results.

In the last phase of its program, the JOG willevaluate the test results to validate the assumptions in the interim program to establish a long-term MOVperiodic verification program to be implemented by licensees.

A feedback mechanism willbe established to ensure timely sharing of MOVtest results among licensees and to prompt individual licensees to adjust their own MOVperiodic verification program, as appropriate.

Following consideration of NRC staff comments, the BWROG submitted Licensing Topical Report NEDC-32719 (Revision 2) describing the JOG program on July 30, 1997.

Similarly, the GEOG and the WOG submitted Topical Report MPR-1807 (Revision 2) describing the JOG program on August 6 and I2, 1997, respectively.

On October 30, 1997, the NRC staff issued an SE accepting the JOG program with certain conditions and limitations as an acceptable industry-wide response to GL 96-05 for valve age-related degradation.

4.0 SHEARON HARRIS GL 96-05 PROGRAM On November 18, 1996, Carolina Power 8 Light Company submitted a 60-day response to GL 96-05 notifying the NRC that it would implement the requested MOVperiodic verification program at the SHNPP.

On March 14, 1997, the licensee submitted a 180-day response to GL 96-05 providing a summary description of the MOVperiodic verification program planned to be implemented at SHNPP.

In a letter dated June 12, 1998, the licensee updated its commitment to GL 96-05.

On May 28, 1999, the licensee provided a response to a request for additional information regarding GL 96-05 forwarded by the NRC staff on March 9, 1999.

In its letter dated March 14, 1997, the licensee described its MOVperiodic verification program, including scope, existing and planned testing, and implementation of the JOG program at SHNPP.

For example, the licensee noted that its MOVperiodic verification program at SHNPP willperform dynamic tests on a representative population of MOVs over a period of 5 years.

The licensee stated that adjustments would be made to its GL 96-05 program based on the test results and recommendations from the JOG testing program.

In its letter dated June 12, 1998, the licensee committed to continue its participation in the JOG MOV Periodic Verification Program as a member of the WOG and to implement the program elements described in the Topical Report MPR-1807 (Revision 2), with one stated exception.

In the June 12, 1998, letter, the licensee described this exception as its plan to perform MOVstatic testing during the fall 1998 outage according to its original GL 89-10 commitment and MOVstatic testing according to the JOG program during the spring 2000 outage.

'.0 'RC STAFF EVALUATION The NRC staff has reviewed the information provided in the licensee's submittals describing the program to verify periodically the design-basis capability of safety-related MOVs at SHNPP in response to GL 96-05. The staff reviewed the GL 89-10 program at SHNPP based on inspection findings, a close-out package submitted by the licensee on February 28, 1995, and follow-up information provided by the licensee in a "HNP-95-077, Provides Addl Info Re Removal of Some MOVs from GL 89-10 Program & Provides Change in HNP [[generic letter" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Program Commitment Re Periodic Verification|letter dated December 7, 1995]].

In a letter to the licensee dated August 7, 1996, the staff closed its review of the program at SHNPP to verify the design-basis capability of safety-related MOVs in response to GL 89-10. The staff's evaluation of the licensee's response to GL 96-05 is described below.

5.1 MOV Program Scope In GL 96-05, the NRC staff indicated that all safety-related MOVs covered by the GL 89-10 program should be considered in the development of the MOVperiodic verification program.

The staff noted that the program should consider safety-related MOVs that are assumed to be capable of returning to their safety position when placed in a position that prevents their safety system (or train) from performing its safety function; and the system (or train) is not declared inoperable when the MOVs are in their nonsafety position.

In a letter dated November 18, 1996, the licensee committed to implement the requested MOV periodic verification program at SHNPP in response to GL 96-05 and did not take exception to the scope of the GL. In its letter dated March 14, 1997, the licensee indicated that the MOV periodic verification program included all MOVs within the scope of its GL 89-10 program.

In the letter dated August 7, 1996, the NRC staff discussed proposed changes to the licensee's MOV program scope at SHNPP and found that the reduction in scope was consistent with GL 89-10 and its supplements, with the exception of the containment fan cooler service water supply and outlet isolation valves.

In a letter dated May 28, 1999, the licensee stated that the containment fan cooler service water supply and outlet isolation valves have been included in the GL 89-10 program at SHNPP.

The staff considers the licensee to have made adequate commitments regarding the scope of its MOVprogram.

5.2 MOVAssumptions and Methodologies Licensees maintain their assumptions and methodologies used in the development of MOV programs consistent with the plant configuration throughout the life of the plant (a concept commonly described as a "living program"). For example, the design basis of safety-related MOVs is maintained up to date, including consideration of any plant modifications or power uprate conditions.

In its letter dated August 7, 1996, the NRC staf.'losed its review of the licensee's justification for the assumptions and methodologies used in the MOVprogram at SHNPP that were described in the licensee's GL 89-10 close-out package and follow-up information. The staff determined that the licensee had adequately justified the assumptions and methodologies used in its MOV program with the long-term aspect discussed in the following section.

The licensee's letter

\\

dated May 28, 1999, indicated ongoing activities, such as review of motor actuator 'tput, to update its MOVprogram assumptions and methodologies.

The staff considers the licensee to have adequate processes in place to maintain the assumptions and methodologies used in its MOV program, including the design basis of its safety-related MOVs.

5.3 GL 89-1 0 Long-Term Items I

In its letter dated August 7, 1996, the NRC staff identified one aspect of the licensee's MOV program at SHNPP to be addressed over the long term. The staff found that the licensee's request to remove the containment fan cooler service water supply and outlet isolation valves from the GL 89-10 MOV program scope had not been adequately justified. In its letter dated May 28,1999, the licensee reported that these service water valves have been retained in the GL 89-10 MOVprogram scope at SHNPP. Also in GL 89-10, the NRC staff identified pressure locking and thermal binding as potential performance concerns for safety-related MOVs. The NRC staff is reviewing the licensee's actions in response to GL 95-07, "Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves," and will issue an SE at the completion of the review.

NRC Inspection Report 50-400/93-13 (IR 93-13) provided the results of the inspection to evaluate the SHNPP MOV program in response to GL 89-10.

In IR 93-13, the NRC staff reported that the licensee's program to address MOVfailures, corrective actions, and trending-met the intent of GL 89-10.

In its letter dated May 28, 1999, the licensee indicated that the results of periodic static diagnostic testing are used to confirm MOVcapability and proper switch settings, and to detect potential degradation in actuator output. The licensee also noted that measurements of stem coefficient of friction and rate of loading are used to trend MOV performance.

With the licensee's ongoing MOVactivities and trending program, no outstanding issues regarding the licensee's GL 89-10 program remain at SHNPP.

5.4 JOG Program on MOV Periodic Verification In its letter dated June 12, 1998, the licensee updated its commitment to implement the JOG Program on MOV Periodic Verification as described in Topical Report MPR-1807 (Revision 2) with one exception.

The licensee described that exception as relating to its plan to perform MOV static testing during the fall 1998 outage according to its original GL 89-10 commitment and MOVstatic testing according to the JOG program during the spring 2000 outage.

The NRC staff views this schedule adjustment to be a clarification of the licensee's implementation of the JOG program rather than an exception to the program.

The staff considers this clarification to be acceptable.

In an SE dated October 30, 1997, the NRC staff accepted the JOG program as an industry-wide response to GL 96-05 with certain conditions and limitations.

The JOG program consists of the following thiee phases:

(1) the JOG interim static diagnostic test program; (2) the JOG 5-year dynamic test program; and (3) the JOG long-term periodic test program.

The staff considers the licensee's commitment in response to GL 96-05 to include implementation of all three phases of the JOG program at SHNPP.

The conditions and limitations discussed in the NRC SE dated

'ctober 30, 1997, apply to the JOG program at SHNPP.

The staff considers the commitments by the licensee to implement all three phases of the JOG program at SHNPP to be an acceptable response to GL 96-05 for valve age-related degradation.

In its letter dated June 12, 1998, the licensee noted that the interim MOVstatic diagnostic test program at SHNPP would use the same approach as described in Topical Report MPR-1807 (Revision 2). The licensee indicated that MOV risk ranking at Harris willbe assigned based on the approach and results presented in the WOG Engineering Report V-EC-1658-A. The WOG also provided an example list of risk-significant MOVs for consideration by each licensee in applying the owners group methodology.

The conditions and limitations discussed in the NRC SE dated April 14, 1998, on the WOG methodology for ranking MOVs by their safety significance apply to the JOG program at SHNPP.

Based on the licensee's commitment, the staff considers the licensee's approach to risk ranking MOVs at SHNPP to be acceptable.

The JOG program is intended "to address most gate, globe and butterfly valves used in safety-related applications in the nuclear power plants of participating licensees.

The JOG indicates that each licensee is responsible for addressing any MOVs outside the scope of applicability of the JOG program.

The NRC staff recognizes that the JOG has selected a broad range of MOVs and conditions for the dynamic testing program, and that significant information willbe obtained on the performance and potential degradation of safety-related MOVs during the interim static diagnostic test program and the JOG dynamic test program.

As the test results are evaluated, the JOG might include or exclude additional MOVs with respect to the scope of its program.

Although the test information from the MOVs in the JOG dynamic test program might not be adequate to establish a long-term periodic verification program for each MOVoutside the scope of the JOG program, sufficient information should be obtained from the JOG dynamic test program to identify any immediate safety concern for potential valve age-related degradation during the interim period of the JOG program.

Therefore, the NRC staff considers it acceptable for the licensee to apply its interim static diagnostic test program to GL 96-05 MOVs that currently might be outside the scope of the JOG program with the feedback of information from the JOG dynamic test program to those MOVs. In the NRC SE dated October 30, 1997, the NRC staff specifies that licensees implementing the JOG program must determine any MOVs outside the scope of the JOG program (including service conditions) and justify a separate program for periodic verification of the design-basis capability (including static and dynamic operating requirements) of those MOVs.

5.5 Motor Actuator Output The JOG program focuses on the potential age-related increase in the thrust or torque required to operate valves under their design-basis conditions.

In the NRC SE dated October 30, 1997, on the JOG program, the NRC staff specifies that licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation.

Although the JOG does not plan to evaluate degradation of motor actuator output, significant information on the output of motor actuators willbe obtained through the interim MOV static diagnostic test program and the JOG dynamic test program.

Several parameters obtained during MOVstatic and dynamic diagnostic testing help identify motor actuator output degradation when opening and closing the valve including, as applicable, capability margin, thrust and torque at control switch trip, stem friction coefficient, load sensitive behavior, and motor current.

In its letter dated May 28, 1999, the licensee indicated that, to address the potential degradation of thrust and torque delivered by MOVactuators, the SHNPP MOV program would include:

(1) the performance of periodic MOVstatic diagnostic testing to confirm MOVcapability and proper switch settings, and to detect potential degradation in actuator output; (2) the performance of preventive maintenance activities such as periodic stem lubrication, actuator grease case inspection, and actuator refurbishment to provide assurance of proper actuator operation; and (3) the application of allowances to account for actuator degradation mechanisms such as stem lubrication degradation and spring pack relaxation.

The licensee stated that its MOVprogram monitors stem friction coefficient under static and dynamic conditions, and rate-of-loading effects. The licensee makes adjustments, as necessary, to its program based on the test results to ensure that the MOVs remain capable of performing their design-basis functions.

In Technical Update 98-01 and its Supplement 1, Limitorque Corporation provided updated guidance for predicting the torque output of its ac-powered motor actuators.

In its letter dated May 28, 1999, the licensee reported that it had reviewed this information for incorporation into the MOVsizing calculations at SHNPP.

The licensee did not identify any deficiencies affecting MOVoperability during these evaluations.

Any MOVoperability concerns that might be identified in the future willbe processed in accordance with established regulatory requirements and plant-speciTic commitments.

In its letter dated July 17, 1998, forwarding Technical Update 98-01, Limitorque indicates that a future technical update willbe issued to address the application of dc-powered MOVs. In its letter dated February 28, 1995, the licensee identified five dc-powered MOVs in its GL 89-10 program.

In its letter dated May 28, 1999, the licensee reported that it is monitoring emerging industry issues concerning dc-powered MOVs, and is participating in an industry effort to develop a revised method for evaluating dc-powered MOV capability.

The NRC staff considers the licensee to be establishing sufficient means to monitor MOVmotor actuator output and its potential degradation.

6.0 CONCLUSION

The NRC staff finds that the licensee has established an acceptable program to verify periodically the design-basis capability of the safety-related MOVs at SHNPP through its commitment to all three phases of the JOG Program on MOV Periodic VeriTication and the additional actions described in its submittals.

Therefore, the staff concludes that the licensee is adequately addressing the actions requested in GL 96-05. The staff may conduct inspections at SHNPP to verify the implementation of the MOV periodic verification program is in accordance vNi the licensee's commitments; this NRC SE; the NRC SE dated October 30, 1997, on the JOG Program on MOVPeriodic Verification; and the NRC SE dated April 14, 1998, on the WOG methodology for ranking MOVs by their safety significance.

Principal Contributors:

T. Scarbrough S. Tingen Date:

October 4, 1999

Mr. James Scarola Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant Unit 1 CC:

Mr. William D. Johnson Vice President and Corporate Secretary Carolina Power 8 Light Company Post Office Box 1551 Raleigh, North Carolina 27602 Resident Inspector/Harris NPS c/o U.S. Nuclear Regulatory Commission 5421 Shearon Harris Road New Hill, North Carolina 27562-9998 Ms. Karen E. Long Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602 Public Service Commission State of South Carolina Post Office Drawer Columbia, South Carolina 29211 Mr. Mel Fry, Director Division of Radiation Protection N.C. Department of Environment and Natural Resources 3825 Barrett Dr.

Raleigh, North Carolina 27609-7721 Mr. Terry C. Morton Manager Performance Evaluation and Regulatory Affairs CPB 7 Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602-1551 Mr. Bo Clark Plant General Manager - Harris Plant Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant P.O. Box 165 New Hill, North Carolina 27562-0165 Mr. John H. O'eill, Jr.

Shaw, Pittman, Potts 8 Trowbridge 2300 N Street, NW.

Washington, DC 20037-1128 Mr. Chris L. Burton Director of Site Operations Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant Post Office Box 165, MC: Zone 1

New Hill, North Carolina 27562-0165 Mr. Robert P. Gruber Executive Director Public Staff NCUC Post Office Box 29520 Raleigh, North Carolina 27626 Chairman of the North Carolina Utilities Commission Post Office Box 29510 Raleigh, North Carolina 27626-0510 Mr. Vernon Malone, Chairman Board of County Commissioners of Wake County P.

O. Box 550 Raleigh, North Carolina 27602 Mr. Richard H. Givens, Chairman Board of County Commissioners of Chatham County P. O. Box 87 Pittsboro, North Carolina 27312 Ms. Donna B. Alexander, Manager Regulatory Affairs Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant P.O. Box 165, Mail Zone 1

New Hill, NC 27562-0165 Mr. Johnny H. Eads, Supervisor Licensing/Regulatory Programs Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant P. O. Box 165, Mail Zone 1

New Hill, NC 27562-0165

Mr. James Scarola tober 4, 1999 Verification and the additional actions described in your submittals.

As discussed in the enclosed Safety Evaluation (SE), the staff concludes that you are adequately addressing the actions requested in GL 96-05.

Sincerely, Docket No. 50-400

Enclosure:

Safety Evaluation cc w/encl: See next page Original signed by:

Richard J. Laufer, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Distribution

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