ML20055F378

Submits Final Response to Generic Ltr 83-28,Items 4.2.3 & 4.2.4.Util Position That Procedures Currently Utilized by Plant Constitute Acceptable Ongoing Life Testing Program for Reactor Trip Breakers & Components

ML20055F378
Person / Time
Site:	Farley
Issue date:	07/10/1990
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-83-28, NUDOCS 9007160359
Download: ML20055F378 (2)

Text

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1. Alabama Power Company

, . 40 Inarness Cintit Parkway

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1 post Office Box 1295

. i Birminghar:i, Alabama 35201 Telephone 205 068-5581

' W. Q. Hairston, til '

serum vice President'  !

Nuclear Operations July 10.-1990 Alabama Pbwer  :

the 50tAhern eleClfic SySletn Docket Nos.'50-348.

50-364  !

i U. S. Nuclear Regulatory Commission ATTN: Document Control Desk ,

Washington, D. C. 20555 :l Gentlemen: l Joseph Mr Parley Nuclear Plant Generic Letter 83-28, Items 4.2.3 and 4.2.4  ;

Generic Letter 83-28, Items 4.2.3 and 4.2.4, required licensees to i

describe their preventive = maintenance and surveillance. programs to. ensure reliable reactor trip breaker operation and to include a program description for life testing of the breakers and periodic replacement consistent with demonstrated life cycles. By letter' dated November 4, 1983, Alabama Power Company responded to Items 4.2.3 and 4.2.4 stating 1 that Alabama Power Company was participating in the Westinghouse Owners l Group-(V0G) to develop a specific program for life testing of the reactor trip breakers and periodic maintenance and replacement of breakers and components consistent vith demonstrated life cycler, j By letter' dated August 4, 1987, the NRC informed Alabama Power Company ,1 that-the'ptogram developed by-the V0G,'VCAP-10835, was not an acceptable y response for meeting Items 4.2.3 and 4.2.4.. As a result.of this denial, '

LAlabama Power Company. informed the NRC, by letter dated October 9, 1987, j that the V0G vould further. evaluate these issues-and that Alabama Power Company would provide the NRC with a proposed schedule for responding.to a the-issues after the V0G schedule was finalized. j At this time, the WOG has deteamined that the issues delineated in Items 1

-4.2.3 and 4.2.4 of Generic Letter 83-28 vill.not be pursued by a V0G

-program. Alabama Power Company is therefore submitting a-final response' to Items 4.2.3 and 4.2.4'in order that the NRC may issue to Alabama Power .f Company a safety evaluation to close these issues.

Since the reactor' trip switchgear at Farley Nuclear Plant is located in a mild environment, the environmental qualification parameters defined by ,

10CFR50.49(d) and IEEE standard 323-1974, which includes aging and establishment of a qualified life, do not apply. The reactor trip breakers have extensive quality assurance, maintenance and surveillance ,

i programs which are sufficient for demonstrating qualification of equipment located in a mild-environment. The reactor trip switchgear,.with the exception of the STA and UVTA, does not experience degradation due to thermal aging based on the application and function of the breakers. For mechanical wear of the breakers, the Alabama Pcver Company maintenance 9007160359 900710 /

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.UT S. Nuclear Regulatory. commission July 10 1990

' ATTN - Document-Control busk fage 2 program consisting of' lubrication, inspection, trending and surveillance adequately eddresses mechanical year and alerts Alabama Power Company to

, any degraded condition of the breakers.

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It is the position of Alabama Power Company that procedures currently-utilized by Farley Nuclear Plant constitute an acceptable ongoing life testing program for the reactor trip breakers and components. These

-W procedures,: while not structured to specifically define component lifetime

.and replacement intervals,.are structured to ensure that the functional capability and reliability of the components are maintained.- It is

'further noted that the NRC issued to Alabama Power Company a safety evaluation report on October 24, 1985 stating that the procedures constituted an acceptable maintenance program for the Farley Nuclear Plant reactor trip breakers as required by Item 4.2.1 of Generic Letter 83-28.

The shunt trip attachment (STA) and undervoltage trip af>5-+ ment (UVTA) on the reactor trip breakers are also located in mild environments at Farley Nuclear Plant. Both the STA and UVTA vere tested by Vestinghouse and the results published in VCAP-10835. The results of the test show that both the STA and UVTA successfully withstood 2500 trip operations with no failures. In addition to the surveillance performed on these components,-

Farley Nuclear Plant procedures also specify that the UVTA and STA be replaced after 1250 cycles of operation. This procedural requirement is based upon Vestinghouse cecommendations resulting trom the testing

. presented in VCAP-10835.

In conclusion, it is the position of Alabama Power Company that a satisfactory ongoing life testing program is in place for-the Farley Nuclear Plant reactor' trip breakers. As stated previously, this position is based on the maintenance,. testing and surveillance of the breakers themselves in conjunction with the maintenance and' conservative replacement intervals for the STA and UVTA. It is therefore the position of Alabama Power Company that the requirements of Items 4.2.3 and 4.2.4 of Genetic Letter 83-28 have been: adequately addressed.

If there are any questions, please advise.

Respectfully submitted, ALABAMA POWER COMPANY W.) MXr V. G. Hairston, III VGH,III/RGVimV.754 cc: Mr. S. D. Ebneter Mr. S.-T. Hoffman Mr. G. F. Maxwell