ML20073B114

Responds to IE Bulletin 83-04 & Amplifies Response to IE Bulletin 83-01.Action Taken in Areas of Testing,Maint, Performance History,Mgt Controls & Licensed Operator Notification Re Reactor Trip Breakers

ML20073B114
Person / Time
Site:	Farley
Issue date:	03/25/1983
From:	Clayton F ALABAMA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
REF-SSINS-6820 IEB-83-01, IEB-83-04, NUDOCS 8304110950
Download: ML20073B114 (4)

Text

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<- . Alabama Power Company

. 600 North 18th Street Post Office Box 2ti41 Birminghom. Alabama 35291 . 1 t i P O P *._ ,

Telephone 205 783-6081

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F. L. Clayton, Jr. b Senior V6ce President Flintndge Building AlabamaPower g p., y ,

March 25,1983 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Ma rietta St reet, N. W.

Atlanta, Georgia 30303 Attention: Mr. J . P. O 'Reilly Joseph M. Farley Nuclear Plant - Units 1 and 2 I . E. Bulleti n No. 83-04 Gentlemen:

In response to I. E. Bulletin No. 83-04 dated March 11, 1983 and to clarify and amplify the Alabama Power Company March 4,1983 response to I. E.Bulletin 83-01, herein is a reply regarding specific action taken at the Farley Nuclear Plant - Units 1 and 2 associated with the reactor t rip breakers. The action includes testing, maintenance, performance history, management controls, and licensed operator notification i nvol v,i ng the reactor trip breakers. The Joseph M. Farley Nuclear Plant, Units 1 and 2, utilizes Westinghouse DS-416 type breaker 3 in the Reactor Protection System.

Alabama Power Company's responses to each of the requi red action items are as follows:

a. Surveillance Testing Alabama Power Company has verified by testing that the reactor trip breaker undervoltage trip function is operable independent of the shunt trip function.

This testing was performed in accordance with Farley Nur. lear Plant Surveillance Test Procedures. The testing was completed

&s follows:

Unit 1 "A" Train on March 19, 1983 "B" Train on March 19, 1983 Unit 2 "A" Train on March 15, 1983 -

"B" Trai n on March 9,1983 No problems with the reactor trip breakers were identified as a result of this surveillance testing. All acceptance criteria were satisfied.

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Mr. J. P. O'Reilly ' March 25, 1983 U. S. Nuclear Regulatory Commission Page 2

b. Mai ntenance Program - Complete p reventive mai ntenance (i .e. ,

inspection, cleaning, lubrication, contact checks, timing checks, etc.) on relays and breakers at the Farley Nuclear-Plant is performed by a dedicated onsite group specializing in such 'acti vities. This group has developed considerable expertise and knowledge related to relay and circuit breaker maintenance and operation. The current and past maintenance activities associated with the reactor trip breaker Model DS-416 have been compared with the vendor technical manual recommendations. As a result of this comparison, a determination has been made that the Farley program is more extensive in many areas of _ preventive maintenance than that recommended by the vendor technical manual. This is due in part to the vast experience accumulated by similar work throughout the company system and implemented via the onsite group of specialists. The results of the comparison also identified areas in whiuh specific compliance with vendor recommendations were not being met.- Justifiable exceptions include tne following:

1) In lieu of the recommended use of alcohol and molybdenum disulphide as a lubricant, Alabama Power Company is cur-rently using WD-40 (a silicone, petroleum distillate base penet rati ng lubricant). Alabama Power Company has experi-enced better performance f rom the use of WD-40 than alcohol and molybdenum disulphide at other generating plants; however, an evaluation is continuing on both lubricants for-use in conjunction with the Farley Nuclear Plant reactor t rip breakers.

2) Alabama Power Company has concluded that preventive maintenance should be conducted at ' refueling outage intervals in lieu of the vendor recommendation of maintenance at annual inspection periods or af ter-500

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operating cycles for purpose of lubrication. Since'the Farley Nuclear Plant refueling cycles -are being changed to 18 months beginning in late 1983, the annual inspection schedule is not feasible nor is it deemed necessary. In addition, the performance of. complete preventive mai ntenance at refueling intervals will be more f requent than the 500 operating cycle lubrication schedule.

Applicable changes to maintenance procedures' will be made by April 15,1983 to document the program revisions described above.

c. Licensed Operator Notification In response .to 'I. E.Bulletin 83-01 dated February 25,.1983, Farley Nuclear Plant licensed operators were1 notified of -the f ailure to trip incident at Salem and were required to perform a ref resher review of the Farley emergency operating procedure related to Anticipated.

Transients Without Trip prior to relieving first- shift after

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Mr. J. P. O'Reilly March 25, 1983 U. S. Nuclear Regulatory Commission Page 3 mid-day on February 26, 1983. In response to I. E.Bulletin 83-04, Farley Nuclear Plant licensed operators were notified upon thei r arri val on-shif t, prior to relieving the evening shif t commencing on March 15, 1983, of the testing failures at San Onof re Units 2 and 3, were reminded of the Salem incident, and were required to perform an additional ref resher review of the Farley emergency operating procedures related to Anticipated Trarisients Without Trip.

d. Previous Malfunctions Alabama Power Company has performed a review of previous reactor trip breaker surveillance records and maintenance reports and conducted interviews with appropriate plant personnel. There have been no identified f ailures of the reactor trip breakers to "open" at Farley Nuclear Plant. There have been cases of failure of the reactor trip breakers to "close" but none that have been deemed to af fect the reliability to "open".

e. Verify Safety Related Activities Testi ng and maintenance activities associated with the reactor trip breakers and under-voltage trip coils are treated as safety related. It should be noted that undervoltage trip coils are not specifically addressed in the maintenance procedures nor in the vendor technical manual section related to inspection or maintenance.

When maintenance has been performed on the reactor trip breakers, the undervoltage relay dropout and pickup voltages have been measured but not always recorded. Fu rther, each month the reactor trip breakers have been verified to open when the undervoltage coil receives a simulated trip signal during the perf ormance of a su rveillance test p rocedu re. The results of this test have been appropriately documented. The mai nte-nance procedures, which will be revised by April 15,1983, will include specific maintenance, testing and documentation provi-sions associated with the undervoltage trip coil.

The procurement activities associated with reactor trip breaker assemblies and subcomponents are handled in accordance with the provisions of the Farley Nuclear Plant Operations Quality Assurance Program (0QAP) described in FSAR Sectior.17.2 This program ensures that adequate provisions associated with codes, standards, design, testing, inspection, etc. _ are requi red for each reactor trip breaker assembly and subcomponent. These breakers. are procured in accordance with safety related quality requi rements of the 0QAP. Individual breaker subcomponent p rocu rement requi rements va ry based on the subcomponent 's function.

m Mr. J. P. O'Reilly March 25, 1983 U. S. Nuclear Regulatory Commission Page 4 Alabama Power Company will ~ continue to evaluate failure data resulting f rom the f ailure to trip incident described in I. E. Bulletin No. 83-04. Appropriate. follow-up action will be taken at the Farley

-Nuclear Plant should the need arise.

If you have any questions, please advise.

You rs ve ry t ru ly ,

F. L. Claytond J r.

FLCJ r/GGY: Is h-D41 cc: Mr. R. A. Thomas Mr. G. F. Trowbridge SWORN TO AND SUBSCRIBED BEFORE ME M r. S . A . Va rga THIS z.s e DAY OF A sg , 1983 Mr. E. A. Reeves M r. W. H. Bradf ord Mr. R. C. DeYoung i lAfc f' ' 7 N'ot ~

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