ML20072J833

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Forwards Surveillance & Maint Program Description & Sample Procedures,In Response to NRC 830203 Request.Description Addresses Qualified Life for Equipment in Nonharsh Environs & Is Consistent w/10CFR50.49
ML20072J833
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 03/17/1983
From: James Smith
LONG ISLAND LIGHTING CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20072J835 List:
References
SNRC-861, NUDOCS 8303300218
Download: ML20072J833 (11)
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_ LONG ISLAND LIGHTING COMPANY SHOREHAM NUCLEAR POWER STATION j[m.-. 3

< m.:m.3 P.O. BOX 618, NORTH COUNTRY ROAD + WADING RIVER. N.Y.11792 Direct Dial Number March 17, 1983 SNRC-861 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Seismic Qualification Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322

Dear Mr. Denton:

In SSER number 3, dated February 3, 1983, NRC Staff requested LILCO provide a sample of its surveillance and maintenance program, including qualified life, for such age sensitive equipment as electric motors and batteries. In subsequent conversations with members of your staff, LILCO reiterated its position relative to defining qualified life for equipment in non-harsh environments.

This position is consistent with the new rule, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," 10 CFR 50.49.

l Enclosed herewith are forty (40) copies of LILCO document,

" Surveillance and Maintenance Program Description," (Enclosure 1) and sample procedures (Enclosures 2 through 10).

LILCO believes this information sufficient to address NRC concerns in this area. Should you have further questions, feel free to contact this office.

Very truly yours, Y 1 Q ,/

Ji L. Smith Manager, Special Projects Shoreham Nuclear Power Station DWD:bc l f fnO cc: J. Higgins I g All Parties Listed in Attachment 1 d 'g p b

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d ATTACHMENT 1 Lawrence Brenner, Esq. Herbert H. Brown, Esq.

Administrative Judge Lawrence Coe Lanpher, Esq.

Atomic Safety and Licensing Karla J. Letsche, Esq.

Board Panel Kirkpatrick, Lockhart, Hill U.S. Nuclear Regulatory Commission Christopher & Phillips Washington, D.C. 20555 8th Floor 1900 M Street, N.W.

Washington, D.C. 20036 Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Mr. Marc W. Goldsmith Board Panel Energy Research Group U.S. Nuclear Regulatory Commission 4001 Totten Pond Road Washington, D.C. 20555 Waltham, Massachusetts 02154 Dr. James H. Carpenter MHB Technical Associates Administrative Judge 1723 Hamilton Avenue Atomic Safety and Licensing Suite K Board Panel San Jose, California 95125 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stephen B. Latham, Esq.

Twomey, Latham & Shea Daniel F. Brown, Esq. 33 West Second Street Attorney P.O. Box 398 Atomic Safety and Licensing Riverhead, New York 11901 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ralph Shapiro, Esq.

Cammer and Shapiro, P.C.

9 East 40th Street Bernard M. Bordenick, Esq. New York, New York 10016 David A. Repka, Esq.

U.S. Nuclear Regulatory Commission

State of New York James Dougherty Department of Public Service 3045 Porter Street Three Empire State Plaza Washington, D.C. 20008 Albany, New York 12223 i

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. SURVEILLANCE ~AND MAINTENANCE' PROGRAM DESCRIPTION-t

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Page # 1 As described in Section 5 of the Environmental Qualification Report-for Class lE equipment (EQR, ) Revision 4, _the Shoreham Nuclear. Power Station'has a surveillance and-maintenance program which includes documented program plans, procedures and-results which will insure that the identified safety-related equipment is maintained in a state of readiness. Section 5 of the EQR also describes how various-regulatory and industry programs will be monitored and evaluated for input to Shoreham's surveillance and maintenance program.

.The surveillance ' activities performed as part of the Shoreham surveillance and maintenance program are based in part, on the requirements stated in'the Shoreham Plant Technical Specification (Tech Specs) . The Tech Specs require periodic testing to demonstrate and assure continued operability of. essential safety systems. In addition.the the Tech Specs, pertinent industry codes and standards, and applicable regulatory documents are evaluated for- input 'into the Shoreham surveillance and maintenance program.

The Surveillance Program outlines the methodology by which these requirements are fulfilled and is comprised of tests, test procedures, and schedules. Testing, inspections, and observations as required by the Tech Specs are performed in-accordance with outlined procedures. The schedules integrate all surveillance activities required for all sections and specify what test, when it was last performed, when it is to be performed, and the responsible section. Individual surveillance activities are shown on Scheduled Activity Worksheets ( SAWS) .

Enclosure 2.

The SAW provides surveillance test procedure number, responsible section, performance frequency, conditions under which the action can be performed (e.g. hot shutdown, cold shutdown, refueling etc.) and a completion section to insure the activity has been completed or if deferred, until what date..-A sign-off section is also provided to record appropriate signatures. Provisions are also included in the program to account for surveillance

. activities required during outages, startups/ shutdowns, after maintenance or repair, and how to deal with problems encountered

[ during surveillance testing. In the case where maintenance or repair has affected the component's operability, the appropriate surveillance test procedure or portion thereof will be performed

after the work is completed to verify that the component's
operability has been restored. As stated, the Tech Specs provide the foundation for the surveillance requirements. Demonstrating l

operability requirements of the Tech Specs via the Shoreham

. Surveillance Program will provide _ adequate assurance of the equipment's ability to perform its intended safety function.

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Page # 2 The Shoreham Preventive Maintenance program has established an efficient reliable system for scheduling, performing and reporting preventive maintenance in order to minimize equipment degradation or failure resulting from normal operation. Mainten-ance. activities for mechanical and electrical equipment will be routinely performed and will include lubrication, greasing, meggar testing, and operational performance testing in addition to test equipment calibration and general inspections.

Procedures and reports have been developed to assist in implementing the preventive maintenance program.

Preventive maintenance activities scheduled in the various reports are shown on Scheduled Activity Worksheets - SAWS (Enclosure 3). These worksheets contain designations for responsible section, activity and procedure number, activity description, references, frequency, and a completion section which includes sign-off by responsible individuals. The procedures referenced on the SAWS provide detailed instructions for performing maintenance activities and include any precautions and materials or test equipment required. The Reference section of the procedure provides additional information to aid in performing the required maintenance. This section would include applicable alternate procedures, ANSI standards or applicable vendor reference manuals.

Similar to the Surveillance Program, the Preventive Maintenance Program is adaptable to changes resulting from problems identified by the various industry and regulatory monitoring programs. It has provisions to perform maintenance activities during outages and updated information, e.g. new maintenance frequency, additional weekly checks etc., can be inserted into the program by revising the applicable SAW sheet.

Overall, the combination of surveillance and preventive maintenance provide adequate assurance that equipment is in an operable condition such that it will perform its intended safety function when required.

Sample Surveillance and Maintenance Activities Batteries Enclosure 4 provides the surveillance requirements for Electrical Power Systems - D.C. Sources. The applicable Technical Specifications section is provided and outlines the Limiting Condition for Operation (LCO), Action, and Surveillance Requirements. Enclosure 5 provides the preventive maintenance requirements for Battery 1R42*BA-A1. The SAWS associated with each maintenance activity for this particular battery as well as the referenced procedures and/or vendor manual are attached.

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Pag 3 # 3' Motors Enclosure ' 6 ~ provides 'the s u r v e i l l a n c e ' r e q u i r e'm e n t s for the service water system pump motor.- Section 3/4.7.1 of the Tech Specs states the.LCO, Action, and Surveillance requirements for the Service Water System. Although the motor"is not specifically addressed, Section 3/4.7.1.lC does state that, along with other surveillances,'once every 18 months, the Service Water system will be demonstrated operable by-verifying that each pump starts automatically.. Enclosure 7'. provides - Ethe associated SAWS, procedures and vendor manuals required for performance of maintenance activities. Enclosure 8'is selected pages of the "Shoreham Surveillance Activity List", By Activity _ Number 11 and the relevant Procedure Number is shown in the respective columns.

Also included are the-frequencies of the surveillance activities.

Enclosure 8 illustrates that a link between the surveillance requirements and preventive- maintenance ' activities exists Additional procedures 'will be utilized to perform required maintenance activities aside from those shown in Enclosure 8.

Also note that the number of surveillance activities does not correspond to the Technical Specifications requirements. This is due to restructuring the . Surveillance program requirements to accommodate' plant procedures and station operations and does not infer an omission of Tech Spec surveillance requirements.

General Notes:

1). Although they are marked " Draft", the Technical Specifications provided in Enclosure 4 and 6 are the latest revision. All Technical Specifications will be finalized after a " Proof and Review" is performed by the Staff and will then be issued as a NUREG and attached to the plant operating license.

! 2). The numbers 110, 180, and 181 in the Activity Number on the i SAWS are file codes utilized in retrieving information from the computer listing.

3). The SAWS provided as Enclosures for the battery and motor differ from those shown in Enclosure 2 and 3 in that they do net contain the sign-off section. This is because these SAWS and motor were provided for informational purposes only. Those SAWS utilized with the various Surveillance or Maintenance reports will be working copies with the appropriate sign-off sections included.

4) . Enclosures 9 and 10 are the relevant sections from the Surveillance and Maintenance Procedures respectively and provide descriptions of the various entries on the SAW sheets.

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v Enclosure 1 SURVEILLANCE AND MAINTENANCE PROGRAM DESCRIPTION Shoreham Nuclear Power Station - Unit 1 LIC3

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As described in Section 5 of the Environmental Qualification Report for Class lE equipment . (EQR,) Revision 4, the Shoreham Nuclear-Power Station has a surveillance and maintenance program which includes documented program plans, procedures and results which will ins.ure that the identified safety-related equipment is maintained in a state of readiness. Section 5 of the EQR also describes how various regulatory and industry programs will be monitored and evaluated for input to Shoreham's surveillance and maintenance program.

The surveillance activities performed as part of the Shoreham surveillance and maintenance program are based in part, on the requirements stated in the Shoreham Plant Technical Specification (Tech Specs). The Tech . Specs require periodic testing to demonstrate and assure continued operability of essential safety systems. In addition the the Tech Specs, pertinent industry codes and standards, and applicable regulatory documents are evaluated for input into the Shoreham surveillance and maintenance program.

The Surveillance Program outlines the methodology by which these requirements are fulfilled and is comprised of tests, test procedures, and schedules. Testing, inspections, and observations as required by the Tech Specs are performed in accordance with outlined procedures. The schedules integrate all surveillance activitics required for all sections and specify what test, when it was last performed, when it is to be performed, and the responsibl'e section. Individual surveillance activities are shown on Scheduled Activity Worksheets (SAWS)

Enclosure 2.

The SAW provides surveillance test procedure number, responsible section, performance frequency, conditions under which the action

.can be performed (e.g. hot shutdown, cold shutdown, refueling etc.) and a completion section to insure the activity has been completed or if deferred, until what date. A sign-off section is also provided to record appropriate signatures. Provisions are also included in the program to account for surveillance activities required during outages, startups/ shutdowns, after maintenance or repair, and how to deal with problems encountered during surveillance testing. In the case where maintenance or repair has affected the component's operability, the appropriate surveillance test procedure or portion thereof will be performed after the work is completed to verify that the component's operability has been restored. As stated, the Tech Specs provide ,

the foundation for the surveillance requirements. Demonstrating operability requirements of the Tech Specs via the Shoreham Surveillance Program will provide adequate assurance of the equipment's ability to perform its intended safety function.

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The' Shoreham Preventive Maintenance program has -established an efficient reliable system for scheduling, performing and reporting preventive maintenance in order to minimize equipment degradation or failure resulting from normal operation. Mainten-ance activitics' for mechanical and electrical equipment will be routinely performed and will . include lubrication, greasing, meggar testing, and operational performance testing in addition to test equipment calibration and general' inspections.

~ Procedures and reports have been developed to assist in implementing the preventive maintenance program.

Preventive maintenance activities scheduled in the various reports are shown on Scheduled Activity Worksheets -

SAWS (Enclosure 3). These worksheets contain designations for responsible section, activity and procedure number, activity description, references, frequency, and a completion section which includes sign-off by responsible individuals. The procedures referenced on the SAWS provide detailed instructions for performing maintenance activities and include any precautions and materials or test equipment required. The Reference section of the procedure provides additional information to aid in performing the required maintenance. This section would include

-applicable alternate procedures, ANSI standards or applicable vendor reference manuals.

Similar to the Surveillance Program, the Preventive Maintenance Program is adaptable to changes resulting from problems identified by the various industry and regulatory monitoring programs. It has provisions to perform maintenance activities during outages and updated information, e.g. new maintenance frequency, additional weekly checks etc., can be inserted into the program by revising the applicable SAW sheet.

Overall, the combination of surveillance and preventive maintenance provide adequate assurance that equipment is in an operable condition such that it will perform its intended safety function when required.

Sample Surveillance and Maintenance Activities Batteries Enclosure 4 provides the surveillance requirements for Electrical .

Power Systems -

D.C. Sources. The applicable Technical Specifications section is provided and outlines the Limiting Condition for Operation (LCO), Action, and Surveillance Requirements. Enclosure 5 provides the preventive maintenance requirements for Battery 1R42*BA-A1. The SAWS associated with each maintenance activity for this particular battery as well as the referenced procedures and/or vendor manual are attached.

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e ..h Motors ,

Enclosure 6 provides the surveillance requirements for the service water system pump motor. Section 3/4.7.1 of the_-_ Tech Specs states the LCO, Action, and Surveillance requirements.for the. Service Wster System. Although the motor is not specifically

. addressed,.Section 3/4.7.1.1C does. state that, along with other surveillances, once every 18 months, the Service Water system will be demonutrated operable by verifying that each pump starts automatically. Enclosure 7 provides the -associated SAWS, procedures and vendor manuals - required for performance of

. maintenance activities.. Enclosure 8 is selected pages of the "Shoreham Surveillance Activity List",-By Activity Number 11 and

_the relevant Procedure liumber is shown in the respective columns. -

~Also. included are the frequencies of the surveillance activities.

Enclosure 8 illustrates thaty link between the surveillance requirements and preventive maintenance activities exists Additional procedures will be . utilized to perform required-maintenance activities aside from those shown in Enclosure 8.

Also note that the number of surveillance activities does not correspond to the Technical Specifications requirements. This is due to restructuring the Surveillance program requirements to accommodate plant procedures and station operations and does not infer an omission of Tech Spec surveillance requirements.

General Notes:

1). Although they are marked." Draft", the Technical Specifications.provided in Enclosure 4 and 6 are the latest revision. All Technical Specifications will be finalized after a " Proof and Review" is performed by the Staff and will then be issued as a NUREG and attached to the plant operating license.

2). The numbers 110, 180, and 181 in the Activity Number on the SAWS are file codes utilized in retrieving information from the computer listing.

3). The SAWS provided as Enclosures for the battery and motor differ from those shown in Enclosure 2 and 3 in that they do not contain the sign-off section. This is because these SAWS and motor were provided for informational purposes ,

only. Those SAWS utilized with the various Surveillance or Maintenance reports will be working copies with the appropriate sign-off sections included.

4). Enclosures 9 and 10 are the relevant sections from the Surveillance and Maintenance Procedures respectively and provide descriptions of the various entries on the SAW '

sheets.

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INSTRUCTIO:I F%NUAL .-

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60 CELLS MCX-2 350 BATTERY ASSEMBLED ON .2 -5U7-,074710-006 ,

i i 125V CONTROL STORAGE BATTERY

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' IDMG ISLAND LIGHTRIG CO:! PAN'l

  • HICKSVILLE, KDi YORK

. ENGINEER: STONE & W.lDST1:R ENGIt??.ERIEG CCRP.

, BOSTON, IMSSACHUCETTS FOR SEOT.!IIIl EUCr,E;sR POh5R STATION UI!IT #1 DROOKJIAVEN .TWP. , L .-I . , N.Y .

P .O . # 310510

"'" 3-(3~ SPEC. #S!II-ll6 SER'.AL #KIIA-087E; KIII-033C; K!!A-OS9A & EllA-090E

['- GOULD ORDER irP-12574 (DATT.)

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