ML18087A834

Affidavit of DG Bridenbaugh Re Delay of Facility Restart. Full Review of safety-related Equipment Must Be Completed & Appropriate Changes Implemented.Prof Qualifications Encl

ML18087A834
Person / Time
Site:	Salem
Issue date:	04/11/1983
From:	Bridenbaugh D MHB TECHNICAL ASSOCIATES
To:
Shared Package
ML18087A832	List: ML18087A831 ML18087A833 ML18087A834
References
IEB-83-01, IEB-83-1, NUDOCS 8304140090
Download: ML18087A834 (21)

Text

ATTACHMENT A AFFIDAVIT OF DALE G. BRIDENBAUGH

,,--8io414oo9o 030412

• PDR ADOCK 05000272 G PDR.

01 AFFIDAVIT OF DALE G. BRIDENBAUGH 02 03 STATE OF CALIFORNIA ss.

04 COUNTY OF SANTA CLARA 05 06 DALE G. BRIDENBAUGH, being duly sworn, deposes and says 07 as follows:

08 *1. I am a Professional Nuclear Engineer, technical 09 consultant, and a founder and president of MHB Technical 10 Associates, technical consultants on energy and environment, 11 with offices at 1723 Hamilton Avenue, Suite K, San Jose, 12 California. I have participated as an expert witness in 1~ licensing proceedings before the U.S. Nuclear Regulatory 14 Commission (NRC)1 have served as a consultant to the NRC; 15 have testified at the request of the Advisory Committee on 16 Reactor Safeguards; have appeared before various committees 17 of the U.S. Congress and testified in various state 18 licensing and regulatory proceedings.

19 2. I am a graduate engineer thoroughly familiar with the 20 design, construction, and operation of nuclear generating 21 plants, including operational errors, equipment and system 22 failures, and other problems that ,could lead to adverse 23 safety and reliability consequences. I received a B.S. in 24 Mechanical Engineering from the South Dakota School of Mines 25 and Technology in 1953, and have since been registered in 26 the state of California as a Professional Nuclear Engineer.

27

0*1 Further details of my experience and qualifications are 02 contained in my resume, Attachment 1.

03 3. The purpose of this affidavit is to put f9rward the 04 preliminary conclusions resulting from my review of the 05 SCRAM breaker failure events which occurred at Public 06 Service Electric and Gas Company's (PSE&G) Salem Unit-1 on 07 February 22 and 25, 1983. These failures were first 08 publicly reported by NRC Bulletin 83-01, copy appended as 09 Attachment 2. These events appear to me to be of 10 extraordinary safety significance, both from a generic and 11 from a PSE&G unique standpoint. I urge serious 12 consideration and deliberation of these events to assure 13 that appropriate reviews and corrective actions have been 14 completed and taken before allowing the Salem units to be 15 returned to service. I am particularly concerned that the 16 decision to resume operations could be made before the full 17 review planned by the NRC is completed, reported, and 18 analyzed so as to permit timely implementation at Salem-1.

19 These concerns also extend to Salem-2, but are less critical 20 there from a schedule standpoint since Unit-2 is scheduled 21 out of service until the end of May.

22 4. The significance of these safety-related equipment 23 failures falls into two categories of Goncern. The first 24 and most obvious category of concern encompasses the 25 possibility of* increased risk at Salem that the operational, 26 engineering and maintenance errors that lead to the 27 28 29

01 unexpected multiple and repetitive breaker failures imply 02 may exist in other critical systems or component*s. The -

03 errors that were committed are indicative of serious 04 failures in the various plant operating and maintenance 05 procedures, in the Quality Assurance program, and in 06 the diligence and commitment of PSE&G management to operate 07 this plant with the necessary care and attention.

08 The second category of concern is th~ apparent failure 09 of the "lessons of TMI" to have penetr~ted the attitudinal 10 predisposition of the industry to believe that such serious 11 accidents will not happen. With all of the recommendations 12 emanating from the TMI review bodies, it is difficult to 13 see how the recommendations could be disregarded to the 14 extent necessary to cause this set of circumstances to come 15 together and cause this problem to occur. NRC's Information 16 Notice 83-18, issued on April 1, 1983, reports the results 17 of breaker testing at other plants. Some of the results, 18 for example seven of twenty-eight plants not using the 19 current maintenance recommendations, lend credence to the 20 belief that this attitude is still fairly widespread. A 21 copy of the Notice is appended as Attachment 3.

22 It is obvious that large quantities of technical 23 resources (manpower) are being applied to investigation of 24 this event, and it is to be expected that voluminous 25 documents will be (have been) produced. What is of greatest 26 concern is that this review will be another paper exercise, 27 and that the old management attitudes are permitted to 28 29 30

01 remain. For this reason, it is doubly important that the 02 Salem-1 restart not be permitted until the full review ls 03 complete and until appropriate changes are fully 04 implemented at the plant.

05 5. The specific problems highlighted by this event that are 06 of most concern and that by currently available documents 07 remain unresolved are as follows:

08

• Failure to develop and implement'acceptable 09 maintenance procedures (SEE SECY 83-98A, 3/14/83, page 9).

10

• Assurance that deficient procurement procedures have 11 not degraded other safety-related equipment (SECY-83-98A, 12 page 18).

13

• Failure to develop and fully implement an adequate 14 post trip review procedure (See SECY 83-98~, page 20). A 15 "commitment to develop" does not assure that it has been 16 developed nor that it is adequate.

17

• Failure to implement full corrective action for the 18 Quality Assurance Program. (See SECY 83-98A, page 21).

19 Again, a commitment to institute a new program does not 20 assure it has been done.

21

• Failure to update and review vendor documents (See 22 SECY 83-98A, pages 20-21).

23

• Failure to complete and document the failure mode 24 verification testing (See SECY 83-98A, pages 6 and 7).

25 A complete copy of the above referenced SECY 83-98A document 26 is appended as Attachment 4.

27 28 01 6. The NRC establishment of a top-priority task force to 02 investigate and report on this event is commendable. (See 03 the March 1, 1983 memo to Commissioners by Dircks, copy 04 appended as Attachment 5). However, the logic of sequencing 05 the restart decision as currently scheduled on April 14 06 while the Mattson report is directed to be completed some 07 four days later (April 18) does not seem sound.

08 Consideration of this important document should play a part 09 in the evaluation of whether PSE&G has implemented adequate 10 corrective action to support a restart decision.

11 7. Taking all of the above described concerns into account, 12 I conclude that completion of the following steps are the 13 minimum basis for a restart decision:

14

• All new procedures committed to by PSE&G should be 15 completed, approved, and in force.

16

• Completion of the review of maintenance activities 17 performed in the past on all safety-related equipment to 18 verify that appropriate quality and engineering reviews were 19 performed should be completed, and all discrepancies fully 20 evaluated.

21

• The updating and review of all safety-related vendor 22 documents should be completed if at all possible. Failing 23 that, a listing of all incomplete document packages should 24 25 26 01 be generated and justification for operation prior to 02 completing the assemblance of the specific documents should 03 be provided.

04

• Completion of the failure mode verification testing 05 should be accomplished with no unexplained anomalies.

06

• The "Mattson" task force report should be completed 07 and available for Commission and public review.

08

• PS&G's commitment to subject their organization to an 09 independent (management) review should be made more 10 explicit, the scope and timing of the review should be 11 provided, and a commitment made to appropriate public review 12 and corrective action.

13 If these actions are not completed, I conclude that the 14 NRC lacks the necessary assurance to find that the restart 15 of the Salem units will not pose an undue risk to public 16 health, safety and the environment and, therefore, should 17 not be permitted at this time.

18 19 20 DALE G. BRIDENBAUGH 21 22 23 Sworn and to before 24 me this 25 26 27 28 29

e TACH:MENT 1 PROFESSIONAL QUALIFICATIONS OF DALE G. BRIDENBAUGH DALE G. BRIDENBAUGH 1723 Hamilton Avenue Suite K San Jose, CA 95125 (408) 266-2716 EXPERIENCE:

19 76 - P RE S ENT President - MHB Technical Associates, s*an .Jose, *California.

Co - f o u n d e r and

• p a r t n er o f t e c h n i c a 1 co n s u 1 t in g f i rm . Sp e ci at is ts*** - .

in energy consulting to governmental and other .~roups interested in evaluation of nuclear plant safety and licensing. Consultant in this capacity to state agencies in California, New York, Illi-nois, New Jersey, Pennsylvania, Oklahoma and Minnesota and to the Norwegian*. Nuclear Power Committee, Swedish Nuclear Inspectorate, and various other organizations and environmental groups. Per-formed extensive safety analysis for Swedish Energy Commission and contributed to the Union of Concerned Scientist's Review of WASH-1400. Consultant to the U.S. NRC - LWR Safety Improvement Program, performed Cost Analysis of Spent Fuel Disposal for the Natural Resources Defense Council, and contributed* to the Depart-ment of Energy LWR Safety Improvement Program for Sandia Labora-tories. Served as expert witness in NRC and state utility commission.hearings.

1976 - ( FEB RU A RY - AUG US T)

Consultant, Project Survival, Palo Alto, California . .

Volunteer work on Nuclear Safeguards Initiative campaigns in California, Oregon, Washington, Arizona, and Colorado. Numerous presentations on nuclear power and alternative energy options to civic, government, and college groups. Also resource person for public service presentations on radio and television.

1973 - 1976 Manager, Performance Evaluation and Improvement, General Electric Company - Nuclear Energy Division, San Jose, California.

Managed seventeen technical and seven clerical personnel with responsibility for establishment and management of systems to monitor and measure Boiling Water Reactor equipment and system operational performance. Integrated General Electric resources in customer plant modifications, coordinated correction of causes of forced outages* and of efforts to improve reliability and per-

_formanc.e of BWR systems.

1973 - 1976 (Contd)

Responsible for development of Division Master Performance Improvement Plan as well as for nurn~rous Staff special assign-ments on long-range studies. Was on s~ecial assignment for the management of two different*ad hoc projects formed to resolve unique technical problems.

1972 - 1973 Manager, .Product Service, General Electric Company - Nuclear Energy Division, San Jose, California.

Managed. group of twenty-one technical and four clerical personnel.

Prime responsibility was to direct interface and liaison personnel involved in corrective.actions required under contract warranties.

Also in charge of refueling and service planning, performance analysis, and service communication functions supporting all com-.

pleted commercial nuclear power reactors supplied by General Electric, both domestic and overseas (Spain, Germany, Italy, Japan, India, and Switzerland).

1968 - 1972 Manager, Product Service, General Electric Company - Nuclear Energy Division, San Jose, California.

Managed sixteen technical and six clerical personnel with the

~esponsibility for all customer contact, planning and execution of work required after the customer acc~ptance of department-supplied plants and/or equipment. This included quotation, sale and delivery of spare and renewal parts. Sales volume of parts increased from $1,000,000 in 1968 to over $3,000,000 in 1972.

1966 - 1968 Manager, Complaint and Warranty Service, General Electric Company -

Nuclear Energy Division, San Jose, California.

Managed group of six persons with the responsib~lity for customer contacts, planning and execution of work required after customer acceptance of department-supplied plants and/or equipment-~both domestic and overseas.

1963 - 1966 Field Engineering Supervisor, General Electric Company, Installation and Service Engineering Department, Los Angeles, California.

Supervised approximately eight field representatives with responsi-bility for General Electric steam and gas turbine installation and maintenance work in Southern*:California, Arizona, and Southern Nevada. During this period was responsible for the installation of eight different central station steam turbine generator units, plus much maintenance activity. Work included customer contact, prepa-ration of quotations, and contract negotiations.

1956 - 1963 Field Engineer, General Electric Company, Installation and Service Engineering Department, Chicago, Illinois. ~~~~

Supervised installation and maintenance of steam turbines of all sizes. Supervised crews of from ten to more than one *hundred men, depending on the job. Worked primarily with large utilities. but had significant work with steel, petroleum and other process industries.* ~ad four years of experience at construction, sta~tup, trouble-shooting and refueling ~f the fitst large-scale commerci~l nuclear power unit.

• 1955 - 1956 Engineering Training Program, General Electric Company~ Erie, Pennsylvania, and Schenectady, New York.

Train.ing assignments in plant facilities desi~n and in steam turbine testing at two General Electric Factory locations.

1953 - 1955 United States Army - Ordnance School, Aberdeen, Maryland.

Instructor - Heavy Artillery Repair. Taught classroom and shop disassembly of artillery pieces.

1953 Engineering Training Program, General Electric Company, EvMndale, Ohio.

Training assignment with Aircraft Gas Turbine Department.

EDUCATION & AFFILIATIONS:

BSME - 1953, South Dakota School of Mines and Technology, Rapid City, South Dakota, Upper~ of class.

Professional Nuclear Engineer - California. Certificate No; 0973.

Member - American Nuclear Society.

Various Company Training Courses during career including Profes-sional Business Management, Kepner Tregoe Decision Making, Effective Presentation, and numerous technical seminars.

HONORS & AWARDS:

Sigma Tau - Honorary Engineering Fraternity.

General Managers Award, General Electric Company.

PERSONAL DATA:

Born November 20, 1931, Miller, South Dakota.

Married, three children 6 1 2 11 , 190 lbs., health - excellent Honorable discharge from United States Army Hobbies: Skiiing, hiking, work with Cub.-and Boy Scout Groups.

PUBLICATIONS & TESTIMONY:

1. Operating and Maintenance Experience, presen~ed at Twelfth Annual Seminar for Electric Utility Executives, Pebble Beach, California, October 1972, published in General Electric NEDC-10697, December 1972.

2. Maintenance and In-Service Inspection, presented at IAEA Symposium on Experience From Operating and Fueling of Nuclear Power Plants, Bridenbaugh, Lloyd & Turner, Vienna, Austria, October, 1973.

3. Operating and Maintenance Experience, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, California, November, 1973, published in General Electric NED0-20222, January. 1974.

4. Improving Plant Availability, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, Cali-fornia, November 1973, published in General Electric NED0-20222, January, 1974.

5. Application of Plant Outage Experience to Improve Planb Per-formance, Bridenbaugh and Burdsall, American Power Conference, Chicago, Illinois, April 14, 1974.

6. Nuclear Valve Testing Cuts Cost, Time, Electrical World, October, 15, 1974.

7. The Risks of Nuclear Power Reactors: A Review of the NRC

• Reactor Safety Study WASH-1400, Kendall, Hubbard, Minor &

Bridenbaugh, et al, for the Union of Concerned Scientists, August, 1977.

8. Swedi"sh Reactor. Safety Study: Barseback Risk Assessment, MHB Technical Associates, January, 1978. (Published by the Swedish Department of Industry as Document DsI 1978:1)

9. Testimony of D.G. Bridenbaugh, R.B~ Hubbard, G.C. Minor to the California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.

10. Tes~imony of D.G. Bridenbaugh, R.B. Hubbard, and G.C. Minor before the *united States Congress~ Joint Committee on Atom~c Energy, February 18" 1976, Washington, DC (Published by the Union of Concerned Scientists, Cambridge, Massachusetts.)

11. Testimony by D.G. Bridenbaugh before the California Energy Commission, entitled, Initiation of Catastrophic Accidents at Diablo Canyon, Hearings on Emergency Planning, Avila Beach, California, November 4, 1976.

12. Testimony by D.G. Bridenbaugh before the u~s. Nuclear Regula-tory Commission, subject: Diablo Canyon Nuclear Plant Perfor-mance, Atomic Safety and Licensing Board Hearings, December, 197'6.

13. Testimony by D.G. iridenbaugh before the California Energy Commission, subject: Interim Spent Fuel Storage Considerations, March 10, 1977.

14. Testimony by D.G. Bridenbaugh before the New York State Public Service Commission Siting Board Hearings concerning the James-port N~clear Power Station, subject: Effect of Technical and Safety Deficiencies on Nuclear Plant Cost and Reliability, April, 1977.

15~ Testimony by D.G. Bridenbaugh before the California State Energy Commission, subject: Decommissioning of Pressurized Water Reactors, Sundesert Nuclear* Plant Hearing~, June 9, 1977.

16. Testimony by D.G. Bridenbaugh before the California State Energy Commission, subject: Economic Relationships of Decommissioning, Sundesert Nuclear Plant, for the Natural

'Resources Defense Council, July 15, 1977.

17. Testimony by D.G. Bridenbaugh before the Vermont State Baard of Health, subject: Operation of Vermont Yankee Nuclear Plant and Its limpact on Public Health and Safety, October 6, 1977.

18. Testimony by D.G. Bridenbaugh before the U.S. Nuclear Regula-tory Commission, Atomic Safety and Licensing Board, subject:

.Deficiencies in Safety Evaluation of Non-Seismic Issues,* Lack of a Definitive *Finding of Safety, Diablo Canyon NucleaF Units October 18, 1977, Avila Beach, California.

-s-*

19. Testimony by D.G. Bridenbaugh before the Norwegian Commission on Nuclear Power, subject: Reactor Safety/Risk, October 26, 1977.

20. Testimony by D.G. Bridenbaugh before the Louisiana State ~*~~-

Legislature Committee on Natural Resources, subject: Nuclear

.Power Plant Defic{encies Impacting on Safety & R~liability, Baton Rouge, Louisiana, February 13, 1978.

21. Spent Fuel Disposal Costs, teport prepared by D.G. Bridenbaugh for the Natural Resources Defense Council (NRDC), August 31,.

1978.

22. Testimony by D.G. Bridenbaugh, G.C. Minor, and R.B. Hubbard before the Atomic Safety and Licensing Board, in the matter of the Black Fox Nuclear Power Sta~ion Construction Permit Hearings, September 25, 1978, Tulsa, Oklahoma.

23. Testimony of D.G. Bridenbaugh and R.B. Hubbard before the Louisiana Public Service Commission, Nucl~ar Plant and Power Generation Costs, November* 19, 1978, Baton Route, Louisiana.

24. Testimony by D.G. Bridenbaugh before the City Council arid Electric Utility Commission of Austin, Texas, Design, Con-struction, and Operating Experience of *Nuclear Generating Facilities, December 5, 1978, Austin, Texas.

25. Testimony by D.G. Bridenbaugh for the Commonwealth of Massachusetts, Department of Public Utilities, Impact of Unresolved Safety Issues, Generic Deficiencies, and Three Mile Island-Initiated Modifications on Power Generation Cost at the Proposed Pilgrim-2 Nuclear Plant, June 8, 1979.

26~ Improving the Safety of LWR Power Plants, MHB Technical Associates, prepared for U.S. Dept. of Energy, Sandia Laboratories, September 28, 1979.

27. BWR Pipe and Nozzle Cracks, MHB Technical Associates, for the Swedish Nuclear Power Inspectorate (SKI), October, 1979.

28. Uncertainty in Nuclear Risk Assessment Methodology. MHB Technical Associates, for the Swedish Nuclear Power Inspectorate (SKI), January, 1980.

29. Testimony of D.G. Bridenbaugh anq G.C. Minor before the*

Atomic Safety and Licensing Board, in the matter of Sacramento Municipal Utility District, Rancho Seco Nuclear Generating Station following TMI-2 accident, subject:

Operator Training and Human Factors Engineering, for the California Energy Commission, February 11, 1980.

30. Italian Reactor Safety Study: Caorso Risk Assessment, 'MHB Technical Associates, for Friends of the Earth, Italy, March , 198 0 .

I

31. Decontamination of ~rypton-85 from Three Mile Island Nuclear Plant, H. Kendall, R. Pollard, & D.G. Bridenbaugh, et al, The Union of Concerned Scientists, delivered to the Governor of Pennsylvania, May 15, 1980.

32. Testimony by D.G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Counsel, Analysis of 1979 Salem-1 Refueling Outage, August, 1980.

33. Minnesota Nuclear Plants Gaseous Emissions Study, MHB Technical Associates, for Minnesota Pollution Control Agency, Septemb~r, 1980.

34. Position Statement, Proposed Rulemaking on the Storage and Disposal of Nuclear Waste, Joint Cross-~tatement of Position of the New England Coalition on Nuclear Pollution and the Natural Resources Defense Council, September, 1980.

35. Testimony by D.G. Bridenbaugh and Gregory*.c. Minor, before the New York State Public Service Commission, In the Matter of Long Island Lighting Company Temporary Rate Case, prepared for the Shoreham Opponents Coalition, September 22, 1980, Shoreham Nuclear Plant Construction Schedule.

36. Supplemental Testimony by D.G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Counsel, Analysis of 1979 Salem-1 Refueling Outage, December, 1980.

37. Testimony by D.G. Bridenbaugh and Gregory C. Minor, before the New Jersey Board of Public Utilities, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, Oyster Creek 1980 Refueling Outage Investigation, February, 1981.

38. Economic Assessment: Ownership Interest in Palo Verde Nuclear Station, MHB Technical Associates, for The City of Riverside, September 11, 1981.

39. Testimony of D.G. Bridenbaugh before the Public Utilities Commission of Ohio, in the matter of the Regulation of the Electric Fuel Component Contained Within. the Rate Schedules of the Toledo Edison Company and Related Matters, subject:

Davis-Besse Nuclear Power Station 1980-81 Outage Review; October, 1981.

40. Supplemental Testimony of D.G. Bridenbaugh before the Public Utilities Commission of Ohio, in the matter of the Regulation of the Electric Fuel Component Contained within the Rate Schedules of the Toledo Edison Company and Related Matters, subject: Davis-Besse Nuclear Power Station 1980-81 Outage Review, November, 1981.

41. Systems Interaction and Single Failure Criterion, Phase 2 Report, MHB Technical Associates for the Swedish Nuclear Power Inspectorate (SKI), January, 1982.

42. Testimony of D. G. Bridenbaugh and Gregory C. Minor on behalf of Governor Edmund G. Brown Jr., before the Atomic Safety and Licensing *Board, regarding Contention 10, PressQrizer Heaters, January 11, 1982.

43. Testimony of D. G. Bridenbaugh and Gregory C, Minor on behalf of Governor Edmund G. Brown Jr., before the Atomic Safety and Licensing Board, regarding Contention 12, Block and

~ilot Operated Relief Valves, Janu~ry 11, 1982.

44. Testimony of D. G. Bridenbaugh before. the Commonwealth of Massachusetts, Department of Public Utilities, on behalf of the Massachusetts Attorney General, Pilgrim Nuclear Power Station, 1981-82 Outage Investigation, March 11, 1982.

45. Testimony of D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of th~ Pennsylvania Office of Consumer Advocate, Beaver Valley Outage, March , 198 2 .

46. Interim testimony of D. G. Bridenbaugh before the Illinois Commerce Commission, on behalf of the Illinois *Attorney General's Office, Expected Lifetimes and Performance of Nuclear Power Plants, March, 1982.

47. Testimony of D. G. Bridenbaugh and G. C. Minor before the Atomic Safety and Licensing Board, on behalf of Suffolk County, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 11, Passive Mechanical Valve Failures, April 13, 1982.

48, Testimony of D. G. Bridenbaugh and R. B. Hubbard, in the Matter of Jersey Central Power and Light Company For An Increase in Rates for Electrical Service, on behalf of New Jersey Department of the Public Advoc~te, Division of Rate Counsel, Three Mile Island Units 1 & 2, Cleanu~

and Modification Pro&rams, May, 1982.

49. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 22, SRV Test Program, May 25, 1982.

VI

50. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 28(a)(vi) and SOC Contention 7A(6),

Reduction of SRV Challenges, June 14, 1982.

51. Testimony of D. G. Bridenbaugh before the Illinois Commerce Commission, on behalf of the Illinois Attorney General's Office, Expected-Lifetimes and Performance of Nuclear Power Plants, June 18, 198~.

52. *Testimony of D. G: Bridenbaugh and R. B. Hubbard on behalf of the Ohio Consumers Counsel, bef9re the Public Utilities Commission of Ohio, regarding Construction of Perry Nuclear Generating Unit No. 1, October 7, 1982.

53. Testimony of D. G. Bridenbaugh on behalf of Rockford League of Women Voters, before the Atomic Safety ~nd Li~ensing Boaid, in the matter of Commonwealth Edison Company, Byron Station, Units 1 and 2, regarding Contention 22, Steam Generators, March 1, 1983.

e AT'l'ACHl'1ENT 2 SS INS *No. : 6820 MAR O3 1983 OMB No.: 3150-00012 Expiration Date: 04/30/85 IEB 83-01 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 February 25, 1983 IE BULLETIN NO. 83-01: FAILURE OF REACTOR TRIP BREAKERS (WESTINGHOUSE DB-50)

TO OPEN ON AUTOMATIC TRIP SIGNAL Addressees:

All pressurized water nuclear power reactor facilities holding an operating license (OL) for action and to other nuclear power re~ctor faciliti.es for information.

Purpose:

The purpose of this bulletin is to inform CP holder; ~nd l'icensees about

, recent failures of WDB type circuit breakers to trip.open on receipt of an

• automatic *trip signal from the reactor protection system (RPS) and to require action of all operating pressurized water reactors to assure proper operation of those breakers in the future.

Description of Circumstances:

On February 25, 1983, during startup of the Salem Unit 1 plant, both DB.-50 RPS breakers failed to open automatically upon receipt of a valid trip signal on low-low steam generator level. * *

• This failure to trip has been attributed to sticking of the undervoltage trip attachment. The reactor was tripped manually from the control -room abo~t 30 seconds after the automqtic trip signal was generated. The manually initiated trip was accomplished by the shunt relays installed in each*DB-50 breaker ..

Background:

In some reactor protection system designs, the automatic protection signals are fed only to the undervoltage (~V) trip attachment of the reacto~ trip' l\ breakers; the manual signals are fed both to the UV trip and to a shunt trip coil of each breaker.

• In the recent past, on two separate occasions, one RPS breaker* at the Salem*

facility failed to open automatically due to binding of the.UV trip attachment.

These events have been reported in LER's 82-072/03X-1 arid 83-001/03L .. In addition, on February 22, 1983, Salem Unit 1 tripped on low-low steam generator level; however, since. the operator manually tripped the reactor at a time almo~t coincidental with the automatic trip signal, 'the actual trip mecha~ism (manual*

or automatic) cannot be ascertained. * * -

-82ll060367

IEB 83-01 February 25, 1983 Page 2 of 3

~_:.,___'--'<pj:~

Similar failures involving the UV trip attachment to the RPS have been reported nc to the NRC. These failures only involved one of the two series breakers, de therefore they did not result in a failure to automatically trip the reactor.

Said failures have occurred at H. B. Robinson, Connecticut Yankee, Prairie Island T and St. Lucie in addition to those at Salem. As a result of these events, the A NRC issued IE Bulletin No. 71-02 and IE Circular No. 81-12, and Westinghouse A issued Technical Bulletin No. NSD-78-74-1 dated January 11, 1974 and NSD Data a Letter 74-2 dated February 14, 1974. (

(

Required Actions for All Holders of Operating Licenses for Pressurized Water Reactors: _

Licensees with WDB type breakers using undervoltage trip attachment in Reactor Protective ~ystem applications are requested to:

1. . Perform surveillance test of undervoltage trip function independent of the shunt trip within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of receipt of this Bulletin unless equivalent testing has been performed within 5 days. Th.ose plants for which on-line testability is not provided may complete this item before resuming operation or if currently operating, at the next plant shutdown.

2. *

• Review *the maintenance program -for conformance to recommended Wprogram * *

(attachment) including frequency and lubricant applied to trip~echanism.

Verify actual. implementation of the Wprogram.* If maintenance including lubrication does not conform, initiate such maintenance within 5 days of receipt of this bulletin or provide an alternate maintenance program.

Repeat the.testing required *in item 1 prior to declaring the breaker OPERABLE. . .

3. Notify all licensed operators of the failure-to-trip event which occurred at Salem. Review the approporiate emergency operating procedures for the event of failure-to-trip with each operator upon his arrival on-shift.

4. Provide written reply within 7 day~ of receipt of .this bulletin,

a. identifying results of testing performed in response to item 1,

b. identifying conformance of maintenance program to Wrecommendation and.describing results of maintenance performed directly as a result of this Bulletin in .response to item 2,

c. provide statement that provisions are in place to notify licensed operators of the Salem event and bring to their attention approprtate failure-to-trip emergency procedures upon their arrival on-shift.*

d. You are reminded of: the requirements for* prompt notification in accordance with 10 CFR 50.72 in the event of detecting an inoperable RPS breaker.

I I IEB 83-01 February 25, 1983.

Page 3 of 3

d PWR Licensees not using the subject undervoltage trip attachment a~d therefore not affected by this bulletin shall submit a negative declaration within 7

• days of the receipt of this bulletin.

and The written report required shall be submitted to the appropriate Regional Administrator under oath or affirmation under provisions of Section 182a, Atomic Energy Act of 1954, as amended. The original copy of the cover letters and a copy of the reports shall be transmitted to the U. S. Nuclear Regulato~y Commission, Document Control Desk, Washington, D.C. 20555 for reproduction and distribution.

This request for information was approved by the Office of Management and r Budget under a blanket clearance number 3150-00012 which expires April 30, 1985. Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, D.C. 20503.

If you have any questions regarding this matter, please contact the Regional Administrator of the NRC Regional Office or the technica] contact listed*

below.

.:z_-(, ~ ** .

fL~cha~~DeYoung,

'-'Office Director Inspection and Enforcement Technical

Contact:

I. Villalva, IE 301-492-9635 V. Thomas , I E 301-492-4755 J. T. Beard, NRR 301-492-7465

Attachment:

1. Transcription of Westinghouse NSD Ltr. 74-2

2. List of Recently Issued IE Bulletins

ATTACHMENT 1

!EB 83-01 February 25, 1983 Verbatim transcription of Westinghouse NSD letter 74-2. Original signed by W. H. Furfari and Sydney G. Caslake.

NSD DATA LETTER 74~2 FROM Nuclear Service Division WIN 236-4744 DATE  : Februa*ry 19, 1974

SUBJECT:

Reactor Trip Breaker Maintenance . -.

NUCLEAR ENERGY SYSTEMS TO: Distribution Technical Bulletin NSD-TB-74-1 (issued 1/11/74) described a reactor tri~

breaker malfunction which occurred at H. B. Robinson station in December of 1973, and recommended certain additional periodic maintenance measures-to improve the reliability of these breakers.

The malfunction (failure to trip during a regularly scheduled periodic test) was attributed to excessive friction in the linkage of the Under-voltage Trip Attachment, which is the device that initiates the breaker drop-open action by elevating the trip bar. The problem was corrected by cleaning and lightly lubricating certain portions of the linkage.

To preclude the possibility of reoccurrence of this malfunction, Westing-house recommends that the reactor trip breakers be gi~en regularly scheduled periodic inspection/maintenance as described in the Instruction Manual and in line with the following guidelines.

1. Scope. These recommendations are intended to apply to Westinghouse 08-50 (or DB-25) breakers in Reactor Trip applications. Some future WNES p1ants vii 11 be. supp 1i ed with Westinghouse Type OS (stored energy) breakers, which should be maintained in accordance with their instruction manual. *

2. Related Operations. It is expected that these inspection and main-tenance measures would normally be carried out in conjunction with breaker periodic operational testing or during plant shutdowns.

However, these recommendations in no way are intended to supersede breaker operational testing commitments and requirements. .

3. Frequency. Intervals between maintenance will be influenced by operating and atmospheric conditions,* but we would recommend that initially it be performed* on a semi-annual basis. The period might then be extended to 9 or 12 months if exoerience shows this to be

• 9 NSD DATA LETTER 74-2 February 19, 1974

4. Cleaning. Clean the entire unit by blowing with dry instrument air (or a hand bellows), followed by vacuum cleaning. Particular attention should be paid to the cleanness of the undervoltage trip device, which can be inspected without component disassembly . .

5. Solvents. In general, the use of a cleaning solvent is not en- I couraged since some can be damaging to electrical components. If there is a particularly heavy deposit of contaminants, an inert or - Ii mild solvent such as Stoddard solvent coultj be used if applied I sparingly.  !

6. Lubricants.. Although the Instruction Ma nu a1 (page 5) cautions against any re-lubrication in the field, the manufacturers have agreed that the reliability of the breaker is impro*ved by lightly lubricating the linkage of the undervoltage device occasionally.

However, the lubricant should be applied only s~aringly to the front and back faces of the vertical-travelingatch (interfacing with the flat copper-alloy spring).

A'dry or near-dry molybdenum disulfide lubricant should be used.

Technical Bulletin NSD-TB-74-1 indicated Molykote Gas a possible choice. That information is incorrect and is hereby rescinded Molykote G uses a thickened mineral oil as a vehicle, which would tend to collect foreign material. A better choice would be Molykote M-88, or Spray-kote. Both are commercially available Dow Corning products.

7. Inspection. Following the above cleaning and lubrication the entire breaker should be operationally checked and inspected for broken parts, loose bolts or excessive wear.

This Date Letter and the above information supersedes Technical Bulletin NSD-TB-74-1, which is hereby cancelled ..

W. H. Furfar.i Electric Technology TECHNICAL OPERATIONS APPROVED: Syndey G. Caslake, Manager Electric Technology TECHNICAL OPERATIONS

~JHF /nev Attachment