ML20205F554

Responds to Generic Ltr 83-28,Items 4.2.1 & 4.2.2 Re Maint & Trending Programs,Respectively,Per 860610 Request. Westinghouse Design Verification Test Shows That Formal Trending Not Required

ML20205F554
Person / Time
Site:	Catawba
Issue date:	08/11/1986
From:	Tucker H DUKE POWER CO.
To:	Harold Denton, Youngblood B Office of Nuclear Reactor Regulation
References
GL-83-28, NUDOCS 8608190242
Download: ML20205F554 (6)

Text

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6 s DUKE POWER GOMPANY P.O. HOx 33100 citAHLOrn5, N.o. 28242 HALH. TUCKER TELEPHONE veomraremswT (704) ON531

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l August 11, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. B.J. Youngblood, Director PWR Directorate #4

Subject:

Catawba Nuclear Station Docket Nos. 50-413 und 50-414

Dear Mr. Denton:

In response to NRC letter dated June 10, 1986 concerning maintenance and trending for Reactor Trip Breakers (GL 83-28, Items 4.2.1 and 4.2.2), the following information is provided. For clarity, the NRC Staff concern is provided first followed by the Duke response.

1. The staff considers the licensee position on Item 4.2.1 to be unacceptable.

The licensee must specify the frequency with which he performs that maintenance recommended for six-month intervals, and provide justification if that interval is greater than six months. The licensee must also include pre- and post-cleaning insulation resistance measurements, RTB cleaning and dusting, and inspection of main and secondary contacts in his maintenance program. If the licensee declines to include these maintenance procedures in his program, he must provide written technical justification.

l Duke Response l

As stated in our response of June 24, 1985, those items that you require to be j done on a six-month basis are included in our RTB maintenance program. The manufacturer's recommended frequency is that this maintenance be done initially at six-months, or 500 cycles, whichever comes first, with subsequent maintenance performed at refueling outage intervals, or 500 cycles, whichever comes first. Our practice at Catawba has been to perform this maintenance at six-month intervals, which far exceeds the recommended frequency.

! We intend to follow the recommended frequency (i.e., refueling outage intervals) af ter the next six-month maintenance, because it is our position that the longer interval is sufficient to adequately assure breaker reliability. We suggest that the staff has misinterpreted the recommended frequency and we have requested Westinghouse to further clarify the wording in their next revised manual in order to resolve this concern.

We took exception in our June 24, 1985 letter, to certain items which we maintain are not related to the safety function of the breaker. We have likewise requested Westinghouse to delete the frequency requirement for these inspections from the next revised manual.

8608190242 860811 PDR I

P ADOCK 05000413 PDR

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s g Mr. Harold R. Denton August 11, 1986 Page 2 Since my letter of June 24, 1985, the Westinghouse Owners Group has funded an effort to revise the DS-416 RTB Maintenance Nknual. This program has been in progress over the past year and Westinghouse has committed to provide a draf t copy of the revised manual for final comment by November 3,1986 and to issue the final revised manual by December 5, 1986. In the interim, as shown in the attached letters, we have received Westinghouse's concurrence on our position with regard to these items and a commitment to revise the manual accordingly.

2. The staff finds the licensee position on Item 4.,2.2 to be unacceptable without additional justification. The licensee must implement a formal trending program as described in Section 2.2. of this SER and provide the staff with a description of his trending program. Alternatively, the licensee must demonstrate that a parametric trending program is of no value in predicting degradation or failure of RTBs due to both aspects of component life, cycling and aging.

Duke Response By letter dated December 9, 1985, the Chairman of the Westinghouse Owners Group provided a copy of WCAP-10835, " Rep' ort of the DS-416 Reactor Trip Breaker Undervoltage and Shunt Trip Attachments Life Cycle Tests" to Mr. R. J. Wright of NRC staff. -A copy of this letter is attached.. Duke is a member of the Owners Group and fully supports the additional program described in this letter. However, it should be noted that the completed tests performed for WCAP-10835 reaffirmed the original Westinghouse design verification test, showed no degradation, and gave no indication that trending is necessary to assure the capability of the breaker to perform its safety function. Duke maintains that the completed testing substantiates that formal trending is not required for the proven life cycles demonstrated. The additional testing will serve to further extend the proven life cycles. Westinghouse.has confirmed by letter that they are in agreement with the Duke position and that the revised DS-416 RTB maintenance manual will reflect this position.

If there are any questions regarding this please advise.

Very truly yours, l

BD e Hal B. Tucker LTP/(RLG23)/slb

_ Attachments xc

Dr. J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission - Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Catawba Nuclear Station

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i CATAWBA-4256

. DAP 86-538 Nudear 0peratons Divison Westinghouse Water Reactor Electric Corporation Olvisions sex ass PittsDurgh Pennsytvania 15230 February 24, 1986 MPS #35924 Mr. T. C. McNeekin Ref: CATAWBA-4192, 3897, 4205 Chief Engineer 0AP-85-248, 255, DCP 85-512 Electrical Divisio'n CAT-85-E-8, MC-85-E-B Duke Power Company P.O. Box 33189 Charlotte, North Carolina 28242 Attn: D. M. Jenkins MCGUIRE/ CATAWBA NUCLEAR STATION UNIT NUMBERS 1 & 2 Reactor Trio-Breaker Maintenance Manual

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Dear Mr. McMeekin:

The purpose of this letter is to confirm that Westinghouse concurs with the Duke Power Company coments transmitted by letter CAT-85-E-8/MC-85-E-8 (Westinghouse Action Items 1 through 5) and will incorporate the coments in the WOG Reactor Trip Switchgear Maintenance Manual.

All additional comments should be coordinated through the Duke Power Company WOG members per CATAWBA-4192.

Very truly yours.

WESTINGHOUSE ELECTRIC CORPORATION wI C. D. Markham, Manager Duke Power Projects Q.

h L. L. Williams, Ma ager

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NSID Projects Mid-South Region VFLamb/JJ/cm/9394d:1 cc: T. F. Wyke 1L __

H. Purcell 1L T. C. McMeekin 6L J. W. Hampton il

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DUKE POWER COMI%NY reterH0=r, area P. O. B O X 33189 GENEllAL OFFIG'S 422 SOUTH CHURCH STRetT CHAllLOTTE. N. C. 28242 June 26, 1985 CAT-85-E-8 .-

MC-85-E-8 Mr. C. D. Markh'am Westinghouse Electric Corp.

P. O. Box 355 Pittsburgh, PA 15230

SUBJECT:

Catawba & McGuire Nuclear Stations NSSS - Reactor Trip Switchgear Manual Revision File: CN-1399.40, MC-1399.40 Re: 1) June 25, 1985 telecon between Vince Lamb, Joe Jelovich, and Chuck Geis of Westinghouse and Jim Thomas and Dan Jenkins of Duke.

2) Duke memo to files CN-1399.40 and MC-1399.40 by J. E. Thomas dated April 16, 1985.

Dear Mr. Markham:

In the referenced telecon, Westinghouse stated the approach to be taken in updating the RTS Manual. A generic revision of the RTS Manual is to be accomplished by Westinghouse for all members of the Westinghouse Owner's Group. To aid in this revision process, Westinghouse requested a copy of the referenced Duke Memo to File. A copy is attached for your use.

If there are any questions on this matter, please contact Jim Thomas at (704) 373-4612 or Dan Jenkins at (704) 373-6013.

Very truly yours, T. C. McMeekin, Chief Engineer l Electrical Division i

W Approved:

YY I. F. Moss Y

By: D. M. Jenkins Engineer Associate Supervising Design Engineer TCM/ c Attachment cc: w/ attachment:

J. E. Thomas P. J. Rapone J. M. Roth R. M. Sandifer I. C. Ratsep J. W._Keirnan I. F. Moss H. W. Purcell D. W. Murdock E. D. Lindsay E. M. Geddy V. F. Lamb p.. R. Herran L. E. Suther L. L. Williams Joe Jelovich Chuck Geis 6 % Modrak.

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'u9 April 16,1985 MEMO TO FILE: MC-1399.40 & CN-1399.40 -

SUBJECT:

McGuire Nuclear Station Catawba Nuclear Station NSSS Reactor Trip Switchgear ,

A meeting was held on April 6,1985, with Westinghouse representatives to discuss comments to the 05-416 RTB Maintenance Manual developed by Westinghouse WRD for the Westinghouse Owner's Group. Those in attendance were:

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Vince Lamb Reo Wo1fgang Jeff Ashe Charles S. Gregory Walter Wylie Dennis Adomaitis Keeth Wilkinson Chuck Geis Roger Bledsoe Robert Gill Jeff Freeze Jerry Day

. Greg Pollak Jim Thomas Wade H. Messer Clay A.Little O The following are the action items developed during the meeting:

Westinghouse Action Items: '

l. Westinghouse will clarify on page 24 of the manual that inspections subsequent to the first should be at 500 cycles or refueling for both group A and B activities.

2. On Page 28 of the manual, Westinghouse will clarify that the arc chutes and insulating barriers should be removed before lifting the breaker only if a problem has been encountered with the breaker. Otherwise, the breaker can be moved to a test bench prior to disassembly

3. Westinghouse will delete references to trending in the manual based on result of the generic cycle life testing.

4. Westinghouse will generate a new section addressing Group B Maintenance activities 15 thru 22 clarifying that those activities are not related to the safety function of the breaker and removing the requirement fon such activities to be performed as frequent as every refueling. Activi ties 23 thru 26 will be reclassified into Group A.

5. Westinghouse will include applicability statement in revised manual to clarify that the maintenance manual requirements take precedence over the RTB general instruction manual .

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MEMO TO FILE: MC-1399.40 April 16,1985

[] Page 2

6. Westinghouse will investigate and expedite spare parts orders for McGuire and Catawba RTB's - P.O. #'s K35803 and K50722 for McGuire '

and K51520 for Catawba.

Duke Power Action Items: -

1. C.A. Little will coordinate ordering DS Lifting Yokes, Part #S/N 9562043G01, for each site.

2. Duke will provide Westinghouse details on any experience with Group 8 type activities for circuit breakers.

g. f, .%. .o. d J.E. Thomas Sen,ior Engineer .

JET /kkm cc: I.F. Moss C.A. Little R.L. Gill O

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4, Commonwealth Edison 72 West Adams Street. CNcago, litinoes Address Reply to: Post Office Box 767 Chicago, lilinois 60000 0G-187 December 9, 1985 Mr. Robert J. Wright Equipment Qualification Branch, P-234 Nuclear Regulatory Commission l 7920 Norfolk Avenue Bethesda, le 20014

Subject:

Westinghouse Owners Group (WOG)

Reactor Trip Breaker Programs Description and Submittal of RTS Trip Attachment Life Cycle Test Reports

Dear Mr. Wright:

In response to your request for information to aid in your review of

, Generic Letter 83-28 submittals from licensees who are members of the Westinghouse owners Group, we are forwarding one copy each of the following topical reports covering recent reactor trip switchgear component testing conducted by the WOG:

WCAP-10835, " Report of the DS-416 Reactor Trip Breaker Undervoltage and Shunt Trip Attachments Life Cycle Tests" (Proprietary)

WCAP-10852, " Report of the DS-50 Reactor Trip Breaker Shunt and Under-voltage Trip Attachments Life Cycle Tests" (Proprietary)

Please note that these WCAP reports contain Westinghouse proprietary information - commercial and financial information which we consider privileged or confidential. It is of a type customarily held in confidence by Westinghouse and is customarily not disclosed to the general public.

This information is being furnished in accordance with your request and pursuant to the Commission's general powers under Section 161 of the Atomic Energy Act of 1954, as amended. Accordingly, it is requested that this Westinghouse proprietary information be handled on a confidential basis and be withheld from public disclosure.

This material is for your internal use only and may be

'used only for the purpose for which it is submitted. It i

should not be otherwise used, disclosed, duplicated or disseminated, in whole or in part, to any other person or organization outside the NRC without the prior written approval of Westinghouse and the Westinghouse Owners Group.

NdlMb1N p s..a s s u

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- 0G-167 Mr. Robert J. Wright December 9,1985 Correspondence with respect to the application for withholding should reference AW-85-083, and should be addressed to R. A. Wiesemann, Manager of Regulatory and Legislative Affairs. Westinghouse Electric Corporation, P.

O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

As we have discussed previously with the Staff, it was intended, in undertaking the reactor trip breaker life cycle test program, to go beyond addressing the immediate issues of Generic Letter 83-28. At the same time, the WOG's Technical Specification Optimization Program (WOG-TOPS),

WCAP-10271, included a treatment of unavailability of the reactor trip breakers as a basis for proposed technical specification changes.

However, as was agreed in our meeting of January 9,1985 (Refer: OG-146, ,

Feb. 27,1985) the reactor trip breakers were omitted from the SER for WOG-TOPS (Thomas to Sheppard, February 21, 1985) because of questions stessiing from the Sales incident.

Further work on the reactor trip breakers in regard to WOG-TOPS was deferred until the W0G could undertake a comprehensive program for that purpose. Such a program was mentioned ~in our letter of June 25, 1985, 0G-153, written in response to Generic Letter 85-09. Therein the WOG expressed the intention to develop a rigorous basis for reactor trip breaker technical specifications incorporating the Iife cycle test data, i

past reliability studies, and the WOG RTB maintenance programs.

The WOG elected to undertake such a program at their September -1985 meeting. The program that was approved will determine a basis for optimal reactor trip and bypass breaker test and maintenance intervals. The objectives of this program are to establish a reactor trip circuit breaker database and to develop a reliability model of the trip breaker which can be used to determine reliability-centered test and maintenance intervals.

This info would be used to support appropriate plant tech spec and maintenance program changes. It is scheduled to be completed by September of 1986, and will be submitted to NRC for review and approval at that time.

If you have any questions regarding this material please contact Mr. Tom Lordi on 412/236-6665, or Mr. Mark Burzynski 615/365-8863, who is Chairman of the Technical Specifications Subcommittee of the WOG. Thank you.

Very truly yours,

. L. D. Butterfield, Chairman '

i Westinghouse Owners Group cc: WOG Rep Tech Spec S/C i H. Thompson T. Spels l

I assess u

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