ML20238A814

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Forwards Request for Addl Info Re Util 840316 Response to Generic Ltr 83-28,Item 4.2 Concerning Preventive Maint & Surveillance Program for Ensuring Reliable Reactor Trip Breaker Operation.Response Requested within 90 Days
ML20238A814
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 08/24/1987
From: Frank Akstulewicz
Office of Nuclear Reactor Regulation
To: Mroczka E
CONNECTICUT YANKEE ATOMIC POWER CO.
References
GL-83-28, NUDOCS 8709090437
Download: ML20238A814 (4)


Text

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Docket No.:

50-213 August 24, 1 987 Mr. Edward J. Mroczka, Senior Vice President

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Nuclear Engineering and Operations Connecticut Yankee Atomic Power Company Post Office Box 270 Hartford, Connecticut 06141-0270

Dear Mr. Mroczka:

SUBJECT:

REQUEST FOR INFORMATION CONCERNING ITEM 4.2 0F GENERIC LETTER 83-28 Re:

Haddam Neck Plant Generic Letter 83-28 was issued by the NRC on July 8, 1983 and indicated actions to be taken by applicants and licensees based on the generic implications of the Salem ATWS event.

Item 4.2 of Generic Letter 83-28 requires licensees or applicants to describe their preventive maintenance and surveillance program for ensuring reliable reactor trip breaker operation.'

Parts 3 and 4 of Item 4.2 pertains to life testing of an acceptable sample size of_the breakers, and periodic replacement of the breakers or components consistent with demonstrated life cycles.

The staff has completed its review of your response to this item, dated March 16, 1984, Land has concluded that additional information is required for us to complete-our review in this area.

Enclosure l identifies the areas where additional information is required.

In order to assure a timely resolution of this issue, the staff is willing to discuss these requests with Connecticut Yankee Atomic Power Company and would request that a written response be provided within 90 days of receipt of this request.

Should you not be able to satisfy the schedule request,

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your licensing department should contact me as soon as possible.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.I-.96-511.

Sincerely, original signed by 8709090437 870824 Francis M. Akstulewicz, Jr., Project Manager PDR ADOCK 050002.13 Integrated Safety Assessment Project Directorate P

PDR Division of Reactor Projects - III, IV, V and Special Projects

Enclosure:

DISTRIBUTION As stated (Docket File-NRC & Local PDR

'ISAPD RF DCrutchfield cc:

See next page CThomas FSchroeder FAkstulewicz MShuttleworth-OGC-Bethesda EJordan h(

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i. Mr. Edward J. Mroczka' C:nnecticut Yankee Atomic Power Company Haddam Neck Plant CC -

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Gerald Garfield, Esquire Kevin McCarthy, Director Day, Berry- & Howard.

Radiation Control Unit Department of Environmental Counselors at Law L City Place Protection Hartford, Connecticut 06103-3499

. State Office Building Hartford, Connecticut- 06106

. Superintendent-Haddam Neck Plant.

Richard M. Kacich, Manager RFD #1

-Generation Facilities Licensing

~ Post.0ffice Box 127E Northeast Utilities._ Service Company East Hampton, Connecticut 06424 Post Office Box 270 L

Hartford, Connecticut 06141-0270 Wayne.D. Romberg

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.Vice President, Nuclear Operations Donald 0. Nordquist, Director y Northeast Utilities Service Company.

Quality Services Department f Post Office Box 270 Northeast Utilities Service Department pf Hartford, Connecticut 06141-0270 Post Office Box 270 i

Hartford, Connecticut 06141-0270 h

Board of Selectmen

-Town Hall i

-Haddam, Connecticut' 06103 l

-I Bradford -S. Chase,- Under' Secretary i

Energy Division c

Office of Policy and Management

.80 Washington Street

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Hartford, Connecticut 06106 i

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- ' Resident InspectorL L Haddam Neck Nuclear Power Station 1 c/o U.S. NRC

.P. O. Box 116

' East Haddam Post Office

' East Haddam, Connecticut 06423 i

Regional' Administrator, Region I.

U.S. Nuclear. Regulatory Commission

-631 Park Avenue King of Prussia,' Pennsylvania 19406 1

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Enclosure i s

REQUEST FOR ADDITIONAL INFORMATION ITEM 4.2 (PARTS 354) DF GENERIC LtiltR 83-28 HADDAM NECK PLANT

~ Item 4.2 of_ Generic Letter 83-28 requires licensees or. applicants to describe their preventive maintenance and surveillance program for ensuring reliable reactor trip breaker. operation. Parts 3 and 4 of Item 4.2 pertains to life testing..of an. acceptable sample. size of the breakers, and periodic replacement of the breakers or components consistent with. demonstrated life cycles. The licenseesubmittedaresponsetoItem4.2(Parts 3&4)byletterdatedMarch16,

, 1984.

In that response the licensee referred to.the life cycle testing program hing conducted by Westinghouse for the Westinghouse Owners Group.

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Westinghouse has presented the results of cyclic testing on the DB-50 RTB in

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" Report of the DB-50 Reactor Trip Breaker Shunt and Undervoltage Trip Attachments

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Life Cycle Tests." WCAP-10852 addresses only cyclic testing on RTB trip attach-f ments.. It neither addresses life qualification of the RTBs nor noneyclic life-

).

Iimitingorperformance-degradingphenomena(e.g., aging)forthetripattach-O ments. Therefore WCAP-10852 does not constitute an acceptable response to the concern of the generic letter.

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If it can be demonstrated that the qualified life of the RTB exceeds the life of'the plant, then the specific qualified life need not be identified.

In a practical sense, the intent of the life testing requirement of the generic letter would be satisfied by demonstrating that the qualified life of the breaker (for I

R the tripping function) exceeds'the expected use projected to the next refueling.

k Cycle testing by the various owners groups, although it does not consider the e' fects of aging, may provide evidence to support continued use of the RTBs for f

one additional refueling cycle, provided that the individual breaker has not shown a sign of degradation based on the licensee's Parametric Trend Monitoring Program.

In this approach, the actual qualified life is not specifically identi-fied, but is only demonstrated to be adequate.

Ongoing life testing is an acceptable alternative to formal life testing for the purpose of establishing a specific qualified life for RTBs. Ongoing life testing

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ys will demonstra kt that tne quaiified life, though not specifically known, is longer (in terms of e cles and time) then the inte. grated service that will be accumulated g

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othrough fne neyt refueling interval. 'The description of an ongoing qualification W

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t (1) drestimate b the number of demands'between refueling outages to.dich yte, R1d inst respond, and the basis for the estimate.

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h (2).a cefinition of relevant, end-ef-life related failures (Note that randoat i-failuredescurring durfng' the constant hazard rato portina of the " bathtub n

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T curve" (pict of failure rat.e ys. time) are not elevant to a life teit).

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~fhe licensee should (a) identify the possible failure nodes, (b) categorize hk ea.-h failure mde as an s.nd-ef life type er not, and (c) present a general

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methhdoiogy for categorizing future failwe rodes that rey not be included M

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A uThe staff finds that the Sicensee has not comitted to a life testing program.

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] The licensee should qualify their breakers by (a) ectual life testing of the

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breake s, including aging, on an acceptable sample size or (b) establishing an n'

N nngoii.3' life testing orogram.

If the f4.rst alternative is selected, the licensee hh h dioul[present the results of ths life testing to the staff for review If the

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'secondialternative is selected, the licensee should describe their ongoing life I

tg' ting program, including the three items identified above.

the kicensta 'should also present for staff reviev a replacement program for the MeSer and' breaker components bl. sed ch the rasults of their life qualification

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For ongoing qualification, the licensee should describe hrw the ongoing

%ual)fication rbsultz, sill be used to establish replacement cycles and times.

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