ML20073R716

Forwards Rev 2 to 4160V Metal Encl Switchgear - General Maint, Providing Description of Inservice Insp & Testing Programs to Assure Seismic Integrity of Electrical & Mechanical Components (SER Issue 8)

ML20073R716
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/22/1983
From:	James Smith LONG ISLAND LIGHTING CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20073R718	List: ML20073R716 ML20073R727
References
SNRC-879, NUDOCS 8305040508
Download: ML20073R716 (9)

Text

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,wwww SHOREHAM NUCLEAR POWER STATION i- w wom u.#.~,wd P.O. BOX 618, NORTH COUNTRY ROAD + WADING RIVER, N.Y.19792 Direct Dial Number April 22, 1983 SNRC-879 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 SER Issue No. 8 Equipment Dynamic Qualification Program Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322

Reference:

LILCO letter SNRC-861 dated March 17, 1983, J. L. Smith (LILCO) to H. R. Denton (NRC) re: Sample Surveillance and Maintenance Program for Seismically Qualified Components.

Dear Mr. Denton:

i l In conversations with members of your staff, subsequent and related l to the above submittal, the need for LILCO to revise Enclosure 1 I of SNRC-861 was identified. The purpose of the revision is to provide a description of LILCO's Inservice Inspection and Inservice Testing programs and related surveillance and maintenance activities which provide assurance that the seismic integrity (i.e. mounting bolts, restraints, etc) of electrical and mechanical components will be maintained throughout the life of the plant.

In response to these concerns, please find enclosed forty (40) copies i of LILCO's revised document, " Surveillance and Maintenance Program I

Description", (Enclosure 1), and a sample Scheduled Activity Work-I sheet, including its referenced procedure, for switchgear maintenance activities (Enclosure ll) . Enclosures 2 through 10 were originally transmitted as part of SNRC-861 and are not included in this sub-mittal.

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i 8305040508 830422 PDR ADDCK 05000322 E PDR FC-8 935.1 i

April 22, 1983 SNRC-879 z Page 2 It is LILCO's understanding that this information is confirmatory in nature. If you should have any further questions relating to this matter, please feel free to contact this office.

Very-truly yours, r

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. L. Smith Manager, Special Projects i

Shoreham Nuclear Power Station DWD:bc Enclosure cc: J. Higgins l All Parties Listed in Attachment 1 I

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' ATTAC!!!1EMT 1

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Lawrence Brenner, Esq. .- IIcrbert H. B r o'.e n , Esq.

Administrative Judge Lawrence Coe Lanpher, Esq. -

. Atomic Safety and Licensing Karla J. Letsche, Esq.

Board Panel Kirkpatrick, Lockhart,' Hill U.S. Nac3 ear Regulatory Com:aission Christopher & Phillips Washington, D.C. 20555 8th Floor

, 1900 M Street, N.W.

Washington, D.C. 20036 Dr. Peter A. Morris -

Administrative Judce 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 !!. 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

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Stephen B. Latham, Esq.

Tuomey, Latham & Shea Daniel F. Brown, Esq. 33 West Second Street Attorney P.O. Box 393 Atomic Safety and Licensing Riverhead, New York 11901 Board Panel U.S. Nuclear Regulatory Commission '

Washington, D.C. ,

20555 Ralph Shapiro, Esq.

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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 Washington, D.C. 20555

, Matthou J. Kelly, Esq.

" State of New York James Dougherty .

Department of Public Service 3045 Porter Street Thrco Empire State Plaza Washington, D.C. 20003 Albtny, ::ew York 12223 x =

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Enclosure 1 P

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

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 to 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 surveillince 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 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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t 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 individualsi. 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 performine, 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.

To fulfill the requirements of 10CFR50.55a, subparagraph (g),

Shoreham has developed an Inservice Inspection (ISI) Program Plan and an Inservice Testing (IST) Program Plan. The specific guidelines given in Section XI of the ASME code, entitled " Rules for Inservice Inspection of Muclear Power Plant Components,"

provided a basis for the development of these programs. These programs were developed in order to assure operability of essential mechanical equipment (i.e. pumps and valves) throughout the design life of the plant. By virtue of performing the required tests and inspections, adequate assurance exists that the equipment seismic integrity is also maintained. A brief discussion of relative aspects of the ISI and IST programs is provided in the following paragraphs.

Examinations within the ISI Program Plan reflect those outlined in article IWA-2000 of the ASME. code and are of three types; visual, surface and volumetric. One of the four categories of visual examination, VT-3, provides that visual examination shall be conducted to deterrine the generic mechanical and structural conditions of components and their supports, such as the presence of loose parts, debris or abnormal corrosion products, wear, 2

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t erosion, corrosion and the loss of integrity at bolted or welded connections. The inspection may also require as applicable the measurement of clearances, detection of physical displacement, structural adequacy of supporting elements, connections.between load carrying structural members and tightness of bolts in order.

to determine structural integrity. Compliance with the examination frequencies specified in the ISI Program (which reflect

• the ASME Code requirements) in addition to Technical Specification surveillance requirements will assure that the equipments ability to function during and after a seismic event is maintained.

The Shoreham IST Program Plan fulfills the requirements of Section XI of the ASME code applicable to inservice testing of pumps and valves (Articles IWP and IWV). The program when implemented assures the operability of pumps and valves throughout their service life. This is generally accomplished by measuring various test parameters for pumps (i.e. inlet and differential _ pressure, flow rate, vibration velocity) and stroke testing or measuring seat leakage for valves as applicable.

Prior to implementation, a base set of reference values is established for all parameters to be measured. When testing is performed, measured values are compared to base line data for significant deviations and when necessary, corrective action is initiated. When significant deviations, from baseline data are identified, but corrective action (e.g. replacement) is not yet required, continued' operation may be based on any or all of the following; increased frequency of testing, further maintenance, or analysis to demonstrate operability. After maintenance is performed, baseline values are re-determined as required for future testing. By performing the tests in accordance with their outlined frequencies, operability during and after a seismic event will be assured.

Overall, the combination of surveillance and preventive maintenance performed in conjunction with the various programs I

described above provides 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

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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 l Requirements. Enclosure 5 provides the preventive maintenance requirements for Battery 1R42*BA-A1. The SAUS 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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Motors i

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 Water System. Although the motor is not specifically addressed, Section 3/4.7.1.1C does state that, along with other surveil' lances, once every 18 months, the Service Water system will be demonstrated 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 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.

Electrical Distribution Equipment In the case of electrical distribution equipment, LILCO has incorporated into its maintenance and surveillance program, periodic requirements to clean and inspect electrical equipment.

As an example, Enclosure 11 consists of the Scheduled Activity Worksheet.for 4160V switchgear 1R22*180SWG-102 and the referenced maintenance procedure SP32.050.02. Sections 8.1 and 8.2 of the procedure outline the necessary activities to verify the mechanical integrity of the switchgear and related components.

By virtue of performing the required maintenance on this and other electrical distribution equipment, the ability of the l

equipment to function as needed during and after a seismic event

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is assured.

l General Notes:

l 1). Although they are marked " Draft", the Technical i

Specifications provided in Enclosure 4 and 6 are the latest revision. All Technical Specifications will be finalized l after a " Proof and Review" is performed by the Staff and vill 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 SAUS are file codes utilized in retrieving iaformation from the computer listing.

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The SAWS provided as Enclosures for the battery and motor

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. differ from.those shown in Enclosure 2 and 3 in that they do

, not contain the sign-off section. This is because these SAWS were provided for information purposes only. Those SAWS utilized with the various Surveillance or Maintenance reports will be working copies with the appropriate sign-of,f 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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