ML20154H697
| ML20154H697 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/1986 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Vollmer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20154H686 | List: |
| References | |
| NUDOCS 8603100355 | |
| Download: ML20154H697 (2) | |
Text
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MEMORANDUM FOR:
Richard H. Vollmer, Deputy Director Office of Inspection and Enforcement FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
EQUIPMENT QUALIFICATION ISSUES We have reviewed the January 17, 1986 memorandum from Robert D. Martin which was enclosed with your January 22, 1986 memorandum to Darrell G. Eisenhut that requested our assistance on several issues raised by Mr. Martin. Our views follow.
We agree that the relationship between the environmental qualification status of equipment, the technical specification operability requirements, and the action period of the LCO, should be c1carly presented. We believe that when qualified equipment is being identified in the technical specification, the first requirement should be that the equipment is qualified. Then and only then, are checks for functional operability appropriate. Qualification of equipment is a conservative inviolate cornerstone of equipment operability.
It is true that the increase in risk caused by a failure of a ifcensee to demonstrate environmental qualification is related to the probability of a harsh environment and the probability that the equipment will be required to operate. However, to preclude an endless debate about the degree of inoperability and when the inoperability commences should a harsh environment occur, we have taken the position that only qualified equipment may have an operability greater than zero in a harsh environment. This is an accepted conservatism.
From the previously stated philosophy, it is clear that we do not agree that it would be appropriate to permit a longer grace period (action period) under the LCO if equipment were declared inoperable because of a lack of prior environmental qualification.
I hope the above discussion of our views on your comments is helpful. Should you desire any additional perspective, please contact Martin Virgilio of Operating Reactors Assessment Staff.
Harold R. Denton, Director Office of Nuc1 car Reactor Regulation DISTRIBUTION YELLOW TICKET 869031 Central File w/ incoming NSIC w/ incoming HRC PDR w/ incoming Denton/Eisenhut PPAS DHossburg w/ yellow folder JCarter MVirgilio CHolahan gg.
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