PLA-2153, Responds to IE Bulletin 84-02, Failures of GE Type Hfa Relays in Use in Class IE Safety Sys. Coils & Relays Replaced Prior to Fuel Load on Each Unit
| ML20084Q650 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/03/1984 |
| From: | Kenyon B PENNSYLVANIA POWER & LIGHT CO. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-84-02, IEB-84-2, PLA-2153, PLKA-2153, NUDOCS 8405210381 | |
| Download: ML20084Q650 (4) | |
Text
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$P&( Pennsylvania Power & Light Company Two North Ninth Street
- Allentown, PA 18101
- 2151770LS151 Bruce D. Kenyon Vice President-Nuclear Operations 215/770-7502 MAY 0 31984 Dr. Thomas E. Murley Regional Administrator, Region i U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 SUSQUEHANNA STEAM ELECTRIC STATION IE BULLETIN 84-02 RESPONSE ER 100450/100508 FILE 842-03 Docket Nos. 50-387 PLA-2153 50-388
Reference:
(1) PLA-708 dated April 3, 1981 (2) PLA-990 dated December 31, 1981
Dear Dr. Murley:
This letter is PP&L's complete response to IE Bulletin 84-02, " Failures of General Electric Type HFA Relays in Use in Class 1E Safety Systems."
The deficiency noted in the bulletin involving General Electric HFA relays was determined by PP&L to be reportable under 10CFR50.55(e). A report by telephone to Mr. R. T. Carlson of NRC Region I by Mr. A. R. Sabol of PP&L was made on February 6, 1981. Reports pursuant to 10CFR50.55(e) were submitted under References (1) and (2).
HFA relays are used at Susquehanna in safety related and non-safety related systems.
In 1981, PP&L commenced the replacement of all Class 1E HFA relays at Susquehanna. These replacements came in one of two forms:
1.
The Lexan coils were replaced with Tefzel coils.
2.
The HFA relay itself was replaced with the Century Series HFA relay which contains a Tefzel coil.
The replacements were completed prior to fuel load on each unit.
The replaced coils and relays were retained for spares for HFA relays in non-safety related systems. These spares are tagged for use in non-safety related systems only. The control of these parts is covered under PP&L's defective device program.
Our resolution of this issue on Unit 1 is covered in NRC Inspection Report 387/82-19. Unit 2 is covered in NRC Inspection Report 388/84-13.
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ER 100450/100508 File 842-03 Dr. Thomas E. Murley In response to the bulletin's request to review the general concerns expressed in the bulletin regarding service life of safety related relays for applicability at Susquehanna:
(1) PP&L receives information regarding defective devices through such sources as IE Information Notices, IE Bulletins, CE Service Advice Letters, CE Service Information Letters, Bechtel Problem Investigation Requests, etc.
The information passed on to PP&L from these sources is evaluated and action is taken accordingly.
(2) PP&L has c~nducted an extensive preoperational test program. This program o
cannot by itself identify end-of-service life failures, but it can identify contributors to the reduction of useful service life.
(3) PP&L's Equipment Qualification Program is designed to insure that all Class 1E equipment is capable of operating under normal, accident, and post-accident conditions. One of the results of the analysis and testing of a Class IE component under this program is determination of the useful service life of that component in a particular environment. The minimum environment for which each component has to be qualified is the worst case (or combination of worst case) design basis event environment (s) for which the equipment is required to perform a safety function. Aging was considered in all cases and is included in the qualification where it has a detrimental effect on the equipment's ability to fun'etion.
If the useful service life is deemed to be less than the 40 year life of the plant, the PP&L computerized preventative maintenance program is used to
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insure replacement of components and subcomponents prior to the end of their qualified service life.
.(4) PP&L maintains an on-going surveillance program which monitors the performance of safety related components and systems. This program can detect component degradation while in service and will help to reveal any useful life deterioration over and above the deterioration expected.
(5) In conclusion, PP&L feels confident that the combination of the activities discussed in items (1) through (4) above should assure the proper operation of Class IE components or detect the deterioration of the useful service life in these components before a safety concern develops.
This letter completes our actions on IE Bulletin 84-02.
IZ_trul yours,
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n B. D. Kenyon Vice President-Nuclear Operations Affidavit
r Page 3 SSES PLA-2153 kWV( 0 31384 ER 100450/100508 File 842-03 Dr. Thomas E. Murley Copy to:
Mr. Richard C. DeYoung Director-Office of Inspection &. Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. R. H. Jacobs U.S. Nuclear Regulatory Commission P.O. Box 52 Shickshinny, PA 18655
'U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555
o, AFFIDAVIT
-COMMONWEALTH OF PENNSYLVANIA)
- SS COUNTY OF LEHIGH
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I, BRUCE D. KENYON, being duly sworn according to law, state that I am
__ Vice P*esident, Nuclear Operations of Pennsylvania Power & Light Company and that the facts set forth on the attached response by Applicants to IE Bulletin 84-02 are true and correct to the best of my knowledge, information and belief.
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VicePresident-NuclearOperati(ons Bruce D. Kenyon Sworn to and subs bed be methis3 day of f
1984.
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