ML20115J941
| ML20115J941 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/22/1985 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, NUDOCS 8504240168 | |
| Download: ML20115J941 (8) | |
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Milling Addrza Alabama Power Company 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6090 R. P. McDona!d Senior Vice President Flintndge Building AlabamaPower i., a:,
April 22,1985 Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 Additional Response to Generic Letter 83-28, Items 2.2.1, 2.2.2, 3.2.3, 4.2.1, 4.2.2 and 4.5.3 Gentlemen:
By letters dated February 13 and March 11, 1985, the NRC requested Alabama Power Company (APCo) to provide additional information regarding Generic Letter 83-28, Items 2.2.1, 2.2.2, 3.2.3, 4.2.1, 4.2.2 and 4.5.3.-
Attached for NRC review is the APCo response to this request for additional information.
If there are any questions, please advise.
Yours very truly, W
R. P. Mcdonald RPM /RGW:gri-D6 Attachment cc: Mr. L. B. Long Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford Q
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Attachment NRC Request - Item 2.2.1 Licensee needs to submit information on how equipment will be classified as safety-related and will be designated as such on plant documentation as requested in sub-items 2.2.1.1 to 2.2.1.6.
APCo Response - Item 2.2.1 JBy letter dated February 15, 1984, APCo submitted information describing the APCo program which ensures that all components of safety-related systems necessary for accomplishing required safety functions are identified. This program for identifying safety-related systems and components at Farley Nuclear Plant is embodied within plant procedures, design organization procedures, the APCo Operations Quality Assurance Manual, and Section 17.3 of the APCo FSAR.
The criteria used by APCo related to the classification of components as safety-related is detailed in the February 15, 1984 response to Sections 2.2.1.la through 2.2.1.1c.
Safety-related equipment is designated as such on plant documentation as described in the February 15r 1984 APCo response to Item 2.2.1.2.
NRC Request - Item 2.2.2 Licensee needs to present his evaluation of the NUTAC program and describe how it will be implemented at Farley 1 and 2.
The staff
' found the NUTAC program fails to address the concern about establishing and maintaining an. interface between all vendors of safety-related equipment and the utility. Accordingly, the licensee will need to supplement his response to address this concern. The additional information should describe how current procedures will be modified and new~ones initiated to meet each element of Item 2.2.2 concern.
APCo Response - Item 2.2.2 Based upon the meeting held with NRR on April 4, no further response from APCo is' required until further clarification of this request is issued by the NRC.
( Additionally, Mr. R. P. Mcdonald discussed the status of the NUTAC issue with Mr. H. L. Thompson of l
the NRC on April 22,1985.)
NRC Request - Item 3.2.3 i
' Results of test and maintenance programs shall identify any post-maintenance testing that may degrade rather than enhance
. safety and shall describe actions to be taken including submitting l
needed Technical Specification changes.
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Attachment Page 2 APCo Response - Item 3.2.3 As stated in the February 15, 1984 response, APCo has reviewed post-maintenance test requirements in existing Technical Specifications and has not identified any which are perceived to degrade rather than enhance safety.
NRC Request - Item 4.2.1 Criteria for Evaluating Compliance with Item 4.2.1 The Joseph M. Farley Nuclear Plant, Units 1 and 2, Reactor Trip Systems utilize Westinghouse DS-416 circuit breakers. The primary criteria for an acceptable maintenance program for the DS-416 Reactor Trip Breaker (RTD) are contained in Westinghouse Maintenance Manual for the DS-416 Reactor Trip Circuit Breaker, Revision 0, October 1984. The NRC staff, Equipment Qualification Branch, has reviewed this document and endorsed the maintenance-program described in it. More specifically, the criteria used to evaluate compliance include those items in this document that relate to the safety function of the breaker, supplemented by those measures that must be taken to accumulate data for trending.
Issues Relating to Item 4.2.1 The licensee response states that their " preventive maintenance program contained in FNP-0-MP-28.114 includes provisions for periodic maintenance including lubrication and housekeeping. This program is in accordance with vendor technical bulletin NSD-TB-75-2 and IEB 83.03."
The licensee document FNP-0-MP-28.114 is not included with the licensee response. The Westinghouse Maintenance Manual for the DS-416 breaker, October 1984, supersedes the above mentioned vendor documents.
a) The Joseph M. Farley Nuclear Plant, Units 1 and 2, Periodic Maintenance Program for the reactor trip breakers should include, on a six-month basis (or when 500 breaker operations have been counted, whichever comes first):
1.
General inspection to include checking of breaker's cleanliness, all bolts and nuts, pole bases, arc chutes, insulating link, wiring and auxiliary switches; 2.
The retaining rings inspection, including those on the undervoltage trip attachment (UVTA) and shunt trip attachment (STA);
P Attachment Page 3 3.
Arcing and main contacts inspection as specified by the Westinghouse Maintenance Manual; 4
UVTA check as specified by the Westinghouse Maintenance.
Manual, including replacement of UVTA if dropout voltage is greater than 60% or less than 30% of rated UVTA coil voltage; 5.
STA check as specified by the Westinghouse Maintenance Manual; 6.
Lubrication as specified by the Westinghouse Maintenance Manual; 7.
Functional check of the breaker's operation prior to returning it to service.
b) The Joseph M. Farley Nuclear Plant, Units 1 and 2, Periodic Maintenance Program for the reactor trip breakers should.
include, on a refueling interval basis (or when 500 breaker operations have been counted, whichever comes first):
.1.
Pre-cleaning insulation resistance measurement and recording; 2.
RTB dusting and cleaning; 3.
Post-cleaning insulation resistance measurements and recording, as specified by the Westinghouse Maintenance Manual; 4.
Inspection of main and secondary disconnecting contacts, bolt tightness, secondary wiring, mechanical parts, cell switches, instruments, relays and other panel mounted devices; 5.
UVTA trip force and breaker load check as specified by the Westinghouse Maintenance Manual; j-6 Measurement and recording RTB response time for the undervoltage trip; 7.
Functional test of the breaker prior to returning to service as specified by the Westinghouse Maintenance Manual.
r Attachment Page 4 The maintenance manual procedure should include a caution to the maintenance personnel against undocumented adjustments or modifications to RTBs.
The licensee is to confirm that the periodic maintenance program includes these fourteen itens at the specified intervals or commit to their inclusion.
APCo Response - Item 4.2.1 The Westinghouse Maintenance Manual for the DS-416 breakers, Revision 0, October 1984 was issued by the Westinghouse Owners Group as a reference manual for maintenance of the DS-416 breakers and was not issued to supersede maintenance manuals previously issued by Westinghouse. The preventive maintenance program currently followed by APCo for the DS-416 breakers is contained in FNP-0-MP-28.114, which includes provisions for periodic maintenance including lubrication and housekeeping for the DS-416 breakers.
APCo has reviewed the referenced manual for comparison to the current program contained in FNP-0-MP-28.114 and submits the following:
a)
Item 1-4:
General inspections of breaker cleanliness, all bolts and nuts, pole bases, arc chutes, insulating link, wiring and auxiliary switches, retaining ring inspection on the undervoltage trip attachment (UVTA), arcing and main contact inspection, and UVTA check including replacement of UVTA if dropout voltage is greater than 60% or less than 30% of rated UVTA coil voltage are currently performed by APCo in accordance with FNP-0-MP-28.114. The shunt trip attachment (STA) does not have retaining rings and consequently no inspection is requi red.
Item 5: The STA check as specified by the referenced manual specifies a test voltage of 70 VDC be applied to the shunt trip coil via secondary contact terminals. APCo currently perforns the STA check under FNP-0-MP-28,114 with a normal voltage test of 132 VDC and a low voltage test of 100 VDC. This low voltage test value of 100 VDC was selected as a conservative value far below the Farley Nuclear Plant Technical Specification battery limits which require plant shutdown if the total battery terminal voltage falls below 121.2 volts.
. Attachment' Page 5 Item 6: The lubrication for the Farley Nuclear Plant DS-416.
breakers has been changed from Molybdenum Disulphide Spray Lubrication to Molybdenum Disulphide in Lithium Grease "Molykote BR-2 Plus" by Dow Corning as recommended by the referenced manual. APCo has revised FNP-0-MP-28.114 to reflect this change.
Item.7: APCo currently performs a functional check of the breaker operation prior to returning the breaker to service.
The NRC letter of February 15, 1985 recomends that Items 0
1-7 above be performed on a six month basis or whenever 500 breaker operations have occured. The Westinghouse Maintenance Manual for the DS-416 breakers, Revision 0, October 1984, recommends that the first inspection be performed at 500 i
breaker operations or six months, whichever comes first. The manual recommends that subsequent inspections be performed
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every 500 breaker operations or on a refueling basis, whichever comes first. For items 1-7 above, the Farley Nuclear Plant i
preventive maintenance program specifies that the referenced inspections be performed on a refueling basis. Since a minimum of two inspections have been performed on every reactor trip breaker at Farley Nuclear Plant since the breakers have been j
modified, APCo will continue to perform the inspections on a i
refueling basis as recomended by the manual. Significantly
'more frequent breaker disassembly and inspection (i.e., on a 4
6-month basis) is considered to be unnecessary and has the potential for degradation of safety due to additional breaker wear from cycling (as addressed in the November 4,1983 APCo response to Item 4.5).
b)
Item 1-4: APCo has reviewed ths requireme_nts for precleaning insulation resistance measurement and recording, breaker switchgear dusting and cleaning, post cleaning insulation resistance measurement and recording, and inspection of main and secondary disconnecting contacts. Current APCo procedures do not include these activities. A new procedure applicable to both units (identified as FNP-0-MP-28.193) will be written and performed on Unit 1 during the current Unit i refueling outage to cover the necessary components of these activities and on a refueling basis for both units thereafter. At present, APCo does not plan to remove the shunt trip panel to perform these inspections since removal of the panel could reduce reliability of the system by increasing the probability of wiring errors when reconnecting the panel.
I Item 5: A undervoltage trip force and breaker load check similar to that recommended by the Westinghouse Maintenance Manual is currently performed by Farley Nuclear Plant under MP-28.114.
Attachment Page 6 Item 6: Measurement and recording of reactor trip breaker response time for the undervoltage trip similar to that recommended by the Westinghouse Maintenance Manual is performed by Farley Nuclear Plant under MP-28.114 for each reactor trip breaker at Farley.
In addition, STP 256.12 measures overall response time from deenergization of the undervoltage output signal in the solid state protection system to decay of the control rod drive mechanism gripper coil voltage. This measurement is performed on one train every refueling outage as required by technical specifications.
Item 7: A functional test of the reactor trip breakers similar to that recommended by the Westinghouse Maintenance Manual is performed by APCo prior to returning the breaker (s) to service in accordance with STP 33.2 and 38.0 NRC Request - Item 4.2.2 Criteria for Evaluating Compliance with Item 4.2.2 Four parameters have been identified as trendable and are included in the criteria for evaluation. These are (a) undervoltage trip attachment dropout voltage, (b) trip force, (c) breaker response time for undervoltage trip, and (d) breaker insulation resistance.
Issues Relating to Item 4.2.2 The licensee states that "The preventive maintenance procedure contains acceptance criteria for initial parameters affecting operation and requires corrective action if these parameters fall outside the acceptance criteria. Repeated failures of the as-found condition will be indicative of trends. APCo has worked with the Westinghouse Owners Group to develop a specific program for life testing of the reactor trip breakers and periodic maintenance and replacement of breakers and coponents consistent with demonstrated life cycles. Based on the results of the Westinghouse testing, APCo will incorporate appropriate changes into its preventive maintenance and surveillance program for the reactor trip breaker."
The licensee is to commit to inclusion of trip force, breaker response time and dropout voltage for undervoltage trip and breaker insulation resistance as trending parameters. The licensee should also identify the organization which will perform the trend analysis, how often the analysis will be performed, and how the information derived from the analysis will be used to affect periodic maintenance.
Attachment Page-7' APCo Response - Item 4.2.2 APCo hereby commits, commencing with the next scheduled outage on each unit, to the inclusion of the "as-found" trip force, breaker response time and dropout voltage for undervoltage trip and breaker insulation resistance as trending parameters. The Farley Nuclear Plant Staff will perform the trend analyses on a refueling outage frequency. The information derived from the analyses will be utilized to modify, as appropriate, the frequency of periodic maintenance.
NRC Request - Item 4.5.3 Licensee needs to submit a description of the specific implementation plan for Farley 1 and 2 after NRC review of WCAP-10271 and Supplement 1.
APCo Response - Item 4.5.3 APCo will respond to this request after NRC review and approval of WCAP-10271, Supplement 1.
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