ML13323A487
| ML13323A487 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/06/1989 |
| From: | Rosenblum R Southern California Edison Co |
| To: | NRC/IRM |
| References | |
| IEB-88-010, IEB-88-10, NUDOCS 8909120227 | |
| Download: ML13323A487 (79) | |
Text
ENCLOSURE I
NRC BULLETIN 88-10 MOLDED CASE CIRCUIT BREAKERS RESPONSE REPORT SUPPLEMENT REPORT NO. 1
0NRC Bulletin 88-10 Response Supplement Molded Case Circuit Breakers (CBs)
San Onofre Nuclear Generating Station Units 1, 2 and 3 II.
SCOPE This Report is provided in accordance with the Reporting Requirements stated in NRC Bulletin 88-10 applicable to operating licenses for San Onofre Nuclear Generating Station (SONGS) Units 1, 2 and 3. This Supplement Report describes traceability actions for Items 1 and 4 CBs that cannot be traced. The results are contained in a supplement to Section IV. No additional information is provided for Sections III, V and VI.
Supplements or revisions to Appendixes A, B and C are included. Appendixes D and E have not been changed. Enclosure II provides the Justification for Continued Operation (JCO's) for San Onofre Units 1, 2, and 3.
III.
No change IV.
Supplement attached V.
No change No change NoIcang
IV:
SUMMARY
OF CBs THAT CANNOT BE TRACED Reporting Requirement 1.b
- ummarize the total number, manufacturer, model number and to the extent possible the procurement chain of those CBs that could not be traced to the CBM in Items 1 and 4 of the actions requested. For Installed CBs, also identify each system which they are/were installed. If item 4 of the actions requested has not been completed by April 1, 1989, due to the schedule for tests in item 3 of the actions requested, this information should be updated within 30 days of the completion of item 4 to address those additional CBs that could not be traced to the CBM.
Response
There were Eighty-seven spare MCCBs reported under investigation in Appendix A of the March 30, 1989 submittal.
Forty-four have been determined to be traceable. Twenty-six failed trace verification and are listed in attached Supplement Appendix A.
The procurement chain for these twenty-six breakers is provided in Supplement Appendix C. The remaining seventeen Westinghouse MCCBs are still under investigation. The presently known procurement chain for these seventeen breakers is also included in the supplement. Although these activities were not completed on June 1, 1989 as stated in the March 30, 1989 report, they were completed on July 31, 1989. These extra days allowed SCE to complete the-bulletin requirements for all identified breakers.
wenty-nine Additional MCCBs were identified in stock subsequent to our original report. Eleven passed trace verification.
Eighteen failed verification. The eighteen are included in Supplement Appendices A and C.
Revised Appendix B shows twenty-nine installed breakers that failed trace verification.
Their procurement chain is provided in Supplement Appendix C.
Supplement Appendix C includes QA Reports MCCB-23 through 32 and a listing of all MCCBs by manufacturer that still have an indeterminate status for traceability verification. The present procurement chain is listed showing the vendor these breakers were purchased from and the SCE purchase order number.
We do not expect any new information on traceability to surface upon completion of our review. Nor do we believe the data on the seventeen remaining breakers will have a statistical impact on any analysis performed using the information provided in our two reports. Therefore, we will document the results of our effort using the NCR process and retain the data in our files.
SUPPLEMENT APPENDIX A SPARE MOLDED CASE CIRCUIT BREAKERS 0
SUPPLEMENT APPENDIX A SPARE MOLDED CASE CIRCUIT BREAKERS RD*
WNCR MANUFACTURER MODEL TRACEABILITY FAILED UNDER INVESTIGATION 3
W-0020-89 WESTINGHOUSE FB30 0
1 4
W-0020-89 WESTINGHOUSE FB30 0
1 94 W-0022-89 WESTINGHOUSE EB20 0
12 156 W-0077-89 WESTINGHOUSE EF3A 1
0
^ 222 W-0029-89 WESTINGHOUSE FB31 4
0 230 W-0104-89 GENERAL ELECTRIC TEBI 4
0 232 W-0131-89 WESTINGHOUSE FA20 1
0 233 W-0131-89 WESTINGHOUSE FA20 5
0 234 W-0131-89 WESTINGHOUSE FA21 4
0 235 W-0132-89 WESTINGHOUSE EHB3 1
0 240 W-0132-89 WESTINGHOUSE EHB2 1
0 245 W-0131-89 WESTINGHOUSE FA21 1
0 250 W-0028-89 WESTINGHOUSE FB30 3
0 253 W-0149-89 GENERAL ELECTRIC TED1 1
0 254 W-0149-89 GENERAL ELECTRIC TED1 1
0 256 W-0150-89 WESTINGHOUSE EB21 1
0 260 W-0149-89 GENERAL ELECTRIC TED1 1
0 265 W-0026-89 WESTINGHOUSE FB30 0
1 266 W-0168-89 WESTINGHOUSE FB30 0
2 268 W-0131-89 WESTINGHOUSE FB30 1
0 A
269 W-0356-89 GENERAL ELECTRIC THJK 1
0 1
W-0027-89 WESTINGHOUSE FB30 1
0 2
W-0357689 AIRPAX 2091 10 0
75 W-0366-89 SQUARE-D QOB1 2
0 TOTAL ***
44 17
- NOTE:
The Record ID indicated in this appendix is a tracking designator which enables cross reference to the detailed Edison QA Report contained in Appendix C.
^NOTE:
These records pertain to MCCBs that were not reported in the origional publication of Appendix A.
They have since been identified, quarantined and subjected to the requirements of NRCB 88-10.
SUPPLEMENT APPENDIX B INSTALLED MOLDED CASE CIRCUIT BREAKERS AV
REVISED APPENDIX B INSTALLED MOLDED CASE CIRCUIT BREAKERS FAILED TRACE VERIFICATION
- RD ID NCR MNFR QTY MODEL UNIT SYSTEM 277 (2) 2-2653 SQUARE D 2 QOB1 2
DIESEL GENERATOR 280 (6) 3-2364 SQUARE D 1 QOB1 3
COND AIR EJECT MON 281 (7) 2-2654 SQUARE D 1 QOB1 2
DIESEL GENERATOR 283 (8) 3-2364 SQUARE D 1 QOB1 3
CONT SPRAY HT TRACE A284 (9) 2-2653 ITE 1 EE2B 2
AUX FEEDWATER 285 (10) 2-2653 ITE 1 EF2A 2
AUX FEEDWATER 288 (12)
P-7129 WESTINGH 1 FB30 1
FUEL HANDLING 289 (13) 2-2653 SQUARE D 2 QB12 2
DIESEL GENERATOR 291 (14) 2-2653 SQUARE D 1 QOB1 2
120V PANEL SPARE 294 (17) 3-2364 SQUARE D 1 QOB1 3
120V PANEL SPARE 296 (19)
P-7129 GEN ELEC 1 TEB1 1
VITAL BUS 301 (24)
P-7129 SIEMENS/
3 EH2-BO 1
DEDICATED SHUTDOWN ALLIS 303 (26) 2-2653 SQUARE D 3 QOBI 2
480V SWGR SPARE 311 (34)
P-7129 WESTINGH 1 FA31 1
COMP COOLING WATER 312 (35) 2-2653 GEN ELEC 4 THJK 2
125V PANEL SPARE 314 (37)
P-7129 WESTINGH 1 FB31 1
CONT BLDG VENT 315 (38)
P-7129 WESTINGH 1 FB31 1
SECURITY 318 (40) 3-2364 ITE 1 EF2A 3
AUX FEEDWATER 329 (49) 3-2364 GEN ELEC 1 THJK 3
125VDC PANEL SPARE 330 (50)
P-7129 WESTINGH 1 E2100 1
120V PANEL TOTAL 29 W
te The Record ID indicated in this appendix is a tracking designator or cross reference with Supplement Appendix C.
ID number in is from March 30, 1989 :report.
A Note This breaker was replaced by Record ID 285.
SUPPLEMENT APPENDIX C EDISON QA REPORT FOR TRACEABILITY VERIFICATION
SUPPLEMENT APPENDIX C pplement Appendix C provides the following information:
- 1.
A listing of the partially completed procurement chain for the 17 MCCB's that still have an indeterminate status for traceability verification.
The presently known procurement chain is provided showing the vendor from whom the breakers were purchased and the SCE purchase order number. None of the installed MCCB vendors in the list are identified in NRC Notice 88-46. This listing is provided below.
- 2. QA Reports MCCB-23 through MCCB-32 which provide the completed procurement chain for the 26 MCCB's that failed trace verification. These reports are provided as an attachment to this supplement.
SPARE AND INSTALLED MOLDED CASE CIRCUIT BREAKERS PROCUREMENT CHAIN FOR MCCBs UNDER REVIEW REC.
PURCHASE RECEIVING MATERIAL ID QTY iVENDOR MODEL ORDER #
DOCUMENT CODE MFR WESTINGHOUSE 3
1 WESTINGHOUSE FB30 S2L00017 RIP-F-38-80 025-24726 4
1
'WESTINGHOUSE FB30 S2L00017 RIP-F-38-80 025-24726 94 12 WESTINGHOUSE EB20 G8207361 MRR2604 024-04218 265 1
WESTINGHOUSE FB30 8A035901 RSO-4269-86 NONE 266 2
WESTINGHOUSE FB30 8K044010 RSO-1787-84 NONE
Report No. MCCB-23, Westinghouse Nuclear Service Division May 18, 1989 TRACEABILITY VERIFICATION REPORT-WESTINGHOUSE MOLDED CASE M
CIRCUIT BREAKERS M
Reference:
SUMMARY
In response to the above referenced NRC Bulletin, a QA audit was conducted on 5/11/89 by SCE QA at Westinghouse Nuclear Service Division (WNSD), Monroeville, PA. As a result of the audit, the Westinghouse Molded Case Circuit Breakers that are covered by the following SCE Purchase Orders, were found to be traceable to the Circuit Breaker Manufacturer (CBM) Warehouse.
o PO No. 6D127901, Release E712 o
PO No. 6DO35901, Release 0451 o
PO No. 6D035901, Release H233 DISCUSSION The audit was conducted by reviewing traceability documents that were researched and compiled by Mr. B. Barnett, WNSD QA, in accordance with SCE PO 6D029902, dated 2/16/89.
The following Westinghouse MCCBs were investigated:
Recqrd Qty Purchase Material Remarks ID No.
Order Code 12 9
6DO35901 024-29439 See Notes 1, 4 & 5 13 1
"t 14 1
231 1
6DO35901 024-29405 See Notes 2, 4 & 5 6D127901 See Notes 3, 4 & 5 NOTES ON PROCUREMENT CHAIN
- 1) The task to research and compile traceability documents for SCE is covered by PO No. 6DO29902,issued to WNSD, dated 2/16/89 and Release G285. The following records were presented for review during this audit:
o Engineering Work Order 871.755, Serial Nos. 1, 3, 4, 6, 7, 8, 9, 11, & 12 o Engineering Work Order 871.755, Serial Nos. 5 & 10 o Engineering Work Order 871.755, Serial No. 2
" WNSD PO No. MN97417, issued to Westinghouse Warehouse W-34, Spartansburg, SC Page 1 of 2
o Packing List issued by Warehouse W-34 Based on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 2) Change Order No. 1 of this PO required WNSD to provide traceability of the MCCBs to the CBM. The following documents were presented for review during this audit:
o Engineering Work Order 871.676, Serial No.
1 o Engineering Work Order 871.676, Serial No. 2 o Packing List issued by Warehouse W-34 A'
Based on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 3) The task to research and compile traceability records for SCE is covered by PO No. 6D029902, issued to WNSD, dated 2/16/89 and Release G285. The following records were presented for review during this audit:
o Engineering Work Order No. 890.094, Serial Nos.
1-5.
o Engineering Work Order No. 890.094, Serial No. 6 o WNSD PO No. MA13801, issued to WESCO o WESCO's PO No. WVW 23163, issued to Warehouse W-34 o W-34's Packing Lists Based on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 4) It was verified that Westinghouse have informed the NRC regarding the extent of the traceability of Westinghouse MCCBs that have been dedicated at its Monroeville, PA Assembly and Test facility. During the presentation to the NRC by Houston Lighting & Power/Westinghouse on May 8, 1989, Westinghouse stated its position that traceability of the MCCBs to the Westinghouse controlled warehouses, including Warehouse W-34, is being considered by WNSD to be "traceable to the CBM" per Bulletin 88-10. According to Westinghouse, NRC accepted this position.
- 5) See Telephone Notes between R. E. Berkshire, SCE and D. Keating, Houston Lighting & Power, attached.
Prepared Approved By:
Distribution R. M. Rosenblum K. L. Baldwin T. Herring III E. J. Trombley D. C. Stonecipher B. G. Mendoza S. S. Paranandi QA File H. W. Newton CDMC R. E. Berkshire Page 2 of 2
-Report No. MCCB-23 ATTACHMENT page 1 of 1 TELEPHONE NOTES DISTRIBUTION BY:RICE BERKSHIRE OF:SCE
- 1. NRCB 88-10 LIST WITH:DENNIS KEATING OF:HOUSTON LGT. & PWR DATE:5/17/89
SUBJECT:
NRC BULLETIN 88-10 TRACEABILITY -
WESTINGHOUSE MCCBs ACTION REQUIRED:
NONE DISCUSSION HIGHLIGHTS AND AGREEMENTS REACHED:
DENNIS CONFIRMED THAT HOUSTON LIGHTING AND POWER MET WITH THE NRC STAFF TO DISCUSS THE TRACEABILITY OF WESTINGHOUSE MCCBs. WESTINGHOUSE SUPPORTED AM&L&P AT THE MEETING. HL&P TOOK THE POSITION THAT IF A MCCB WAS TRACED TO WESTINGHOUSE FACTORY WAREHOUSE IT WOULD BE CONSIDERED TRACEABLE. THE LY WEAKNESS THAT WAS PERCEIVED WAS THE RESTOCKING OF MCCBs FROM THE WESTINGHOUSE DISTRIBUTION SYSTEM. IT WAS CONCLUDED THAT THIS WAS NOT SIGNIFICANT BASED ON THE NORMAL COMMERCIAL LEVEL SCREENING DONE AS PART OF THE RESTOCKING PROCESS. THE NRC STAFF ACCEPTED THIS POSISTION.
WESTINGHOUSE IS PROVIDING HL&P A LETTER STATING ON THIS APPROACH.
I ADVISED DENNIS THAT BERNIE MENDOZA HAD DONE AN AUDIT AT BOTH NSD AND THE BEAVER PLANT. HIS NSD CONTACT WAS WAITING FOR A LETTER FROM THE WESTINGHOUSE "HOME OFFICE" STATING THIS SAME POSITION. DENNIS INDICATED THAT HIS UNDERSTANDING IS THAT WESTINGHOUSE WAS CONSIDERING RELEASING AN INTERNAL LETTER OR ISSUING THE LETTER MENTIONED ABOVE. HE WAS TOLD BY WESTINGHOUSE NOT TO CONTACT THEIR FACTORIES CONCERNING TRACEABILITY, BUT TO WORK THROUGH NSD. I SHARED BERNIE'S SUCCESS STORY AT BEAVER WITH HIM.
THE NRC STAFF REQUESTED ADDITIONAL INFORMATION FROM HL&P ON TRACEABILITY OF MCCBs FROM A DISTRIBUTOR (SORENTO ?)
VIA WESCO VIA WESTINGHOUSE SALES.
DENNIS ALSO HAD HEARD-THAT THE STAFF WAS ISSUING A SUPPLEMENT TO THE BULLETIN, BUT DIDN'T KNOW ANY DETAILS.
I ADVISED HIM THAT NUMARC WAS MEETING WITH THE STAFF ON OUR RESPONSES AND WOULD HAVE MORE INFORMATION.
0II
Report No. MCCB-24, Westinghouse, Beaver, PA May 18, 1989 m
M-< 0 TRACEABILITY VERIFICATION REPORT-WESTINGHOUSE MOLDED CASE mM CIRCUIT BREAKERS
Reference:
SUMMARY
reWd
.In response to the above referenced NRC Bulletin, a QA audit was conducted on 5/12/89 by SCE QA at the Westinghouse circuit breaker manufacturing facility located in Beaver, PA. As a result of the audit, the Westinghouse Molded Case Circuit Breakers (MCCBs) covered by the following SCE Purchase Orders were verified to be traceable to the Circuit Breaker Manufacturer (CBM):
o PO No. 8D035426, issued to Westinghouse o
PO No. 8W104062, issued to Westinghouse o
PO No. 8W104155, issued to Westinghouse o
PO No. 8W104195, issued to Westinghouse o
PO No. 8N085423, issued to Associated of Los Angeles DISCUSSION The audit was conducted by reviewing records maintained at the Westinghouse facility and by interviewing Messrs. R.
Ringer,,Manager, Product Warranty, MCCBs and P. Mihalic, Managee; Quality Services, Components Division. The follow,g Westinghouse MCCBs were investigated and found to be traceable to the CBM:
Record Qty Purchase Material Remarks ID No.
Order Code 327 1
8D035426 024-29413 See Note 1 below 237 1
to it 295 1
8W104062 024-29439 See Note 2 below 299 1
i in 305 1
it In 169 1
8W104155 024-29389 See Note 3 below 287 1
024-29397 t
293 1
i It 279 1
i 024-29405 298 1
It it 213 1
024-29413 302 1
026-61262 221 1
026-73408 243 2
8W104195 024-29421 See Note 4 below 304 1
i n
n 11 1
024-29439 i
300 1
307 1
Page 1 of 3
309 1
8W104195 024-29439 See Note 4 below 321 1itf 336 1
n i
170 2
8NO85423 024-29389 See Note 5 below 216 1
of 024-29413 of 218 3
n 026-73408 219 1
n 024-29405 236-1 024-29413 306 1
n 024-29397 308 1
n 024-20405 322 1
n 323 1
n 024-29397 324 1
NOTES ON PROCUREMENT CHAIN
- 1) This PO was issued to Westinghouse, El Monte, CA (Sales Office). The order was processed by the Westinghouse Beaver, PA factory under Order No. LA 34781. The Certi ficates of Conformance and shipping documents for this order were reviewed during this audit.
- 2) This PO was issued to Westinghouse, El Monte, CA (Sales Office). The order was processed by the Westinghouse Beaver, PA factory under Order No. LA 34676. The Certi ficates of Conformance and shipping documents for this order were reviewed during this audit.
- 3) Ths.TPO was issued to Westinghouse, El Monte, CA (Sales Office). The order was processed by the Westinghouse Beaver, PA factory under Order No. LA 34713. The Certi ficates of Conformance and shipping documents for this order were reviewed during this audit.
- 4) This PO was issued to Westinghouse, El Monte, CA (Sales Office). The order was processed by the Westinghouse Beaver, PA factory under Order No. LA 34717. The Certi ficates of Conformance and shipping documents for this order were reviewed during this audit.
- 5) This P0 was issued to Associated of Los Angeles, who in turn issued PO No. 7855 to WESCO for the required MCCBs. WESCO, in turn issued Order No. DS6336-0108 4 3 to Westinghouse.
The order was processed by the Westinghouse Beaver, PA, factory under Order No. LA 52337.
The factory's shipping documents were reviewed during the audit.
Page 2 of 3
FOLLOW-UP ACTION No further follow-up action is required.
Prepared By:
Approved BY:
Distribution R. M. Rosenblum T. Herring III D. C. Stonecipher S. S. Paranandi H. W. Newton R. E. Berkshire K. L. Baldwin E. J. Trombley B. G. Mendoza QA File CDMC Page 3 of 3
Report No. MCCB-25, Warehouse Spare Circuit Breakers m
M C.
May 18, 1989 M
4 TRACEABILITY VERIFICATION REPORT-MOLDED CASE CIRCUIT BREAKERS SUPPLIED BY CYBEREX, MORRISON/KNUDSEN (POWER X
rn SYSTEMS), AND NUTHERM
Reference:
NRC Bulletin 88-10 SUMARY None of the eight (8) Molded Case Circuit Breakers (MCCBs) supplied to SONGS by Cyberex, Inc., Morrison-Knudsen Company, Inc., Power Systems Division, and Nutherm Inter national, Inc., were found to be traceable to the Circuit Breaker Manufacturer (CBM), as defined by the above referenced Bulletin.
DETAILS The eight (8) MCCBs covered by this report are as follows:
Warehouse Qty Purchase Material Supplier/Remarks Record ID No.
Order Code 256 1
8N065418 025-85883 Cyberex/See Note 1 230 4
8A085404 025-44484 MK,Power Systems/
See Note 2 253 1
Fluor PO None Nutherm/See Note 3 441207 254 1
None n
260 1
None NOTES ON PROCUREMENT-CHAIN
- 1) The SCE PO was issued to Cyberex, who in turn issued PO No. 17910, dated 9/16/85 to WESCO, Cleveland, OH. Mr.
Bill Tobias of WESCO stated that they maintain records for 2 years only, therefore the records for the above order no longer exist. Traceability to the CBM was not established.
- 2) The SCE PO was issued to Morrison Knudsen, Power Systems Division, who in turn issued PO No. 57448, dated 5/21/86 to GE Supply, Greenville, NC. The only document GE Supply was able to provide is their Invoice, dated 12/15/86 for the MCCbs. Traceability to the CBM was not established.
- 3) The MCCBs were purchased for SCE by Fluor Engineers, Inc., per its PO No. 441207-6-0002-01, dated 11/1/3/85, to Nutherm International, Inc. The MCCBs were ordered by Nutherm from GE Supply, Springfield, IL. The only documents available are Nutherm's PO and GE Supply's Page 1 of 2
Invoice 149496, dated 1/16/86. Traceability to the CBM was not established.
Prepared B:LC,,K Approved Distribution R. M. Rosenblum T. Herring III D. C. Stonecipher S. S. Paranandi H. W. Newton R. E. Berkshire K. L. Baldwin E. J. Trombley B. G. Mendoza QA File CDMC Page 2 of 2
Report No. MCCB-26, Square D (Installed)
May 18, 1989 TRACEABILITY VERIFICATION REPORT-SQUARE D MOLDED CASE M
f CIRCUIT BREAKERS SUPPLIED BY AMFAC AND SQUARE D CO.
a U
Reference:
SUMMARY
I c
Only six (6) of the seventeen (17) Square D Molded Case m
Circuit Breakers (MCCBs) supplied by Amfac, Orange Coast Electrical, and Square D that are covered by this report were verified to be traceable to the Circuit Breaker Manufacturer (CBM), as defined by the above referenced NRC Bulletin.
DETAILS The following are the results of the traceability verifi cation activities for the seventeen (17) MCCBs:
Warehouse Qty Purchase Material Supplier/Remarks Record ID Order Code 277 2
8D045027 026-10053 Amfac/See Note 1 281 1
283 1"
289 1
291 1
"t 294 1
303 3
280 1
8W025102 None Orange Coast/See Note 2 278 1
S5903542 026-10061 Square D/See Note 3 292 1
8N084003 026-10087 Square D/See Note 3 320 1
026-10681 I
317 1
J4103542 025-51117 Square D/See Note 3 319 1
8E113064 024-10181 Square D/See Note 3 326 1
8W015038 026-10053 Square D/See Note 4 NOTES ON PROCUREMENT CHAIN
- 1) SCE PO 8D045027, dated 4/15/85, was issued to Amfac Electrical Supply Company. Mr. C. Myers of Amfac stated that the records for this PO are no longer available. The MCCBs are considered not traceable to the CBM.
- 2) SCE PO 8W025102 was issued to Orange Coast Electrical Company. Mr. C. Corneyea of Orange Coast stated that the records for this PO are no longer available. The MCCB covered by the PO is considered not traceable to the CBM.
- 3) The SCE Purchase Order covering this MCCB was issued to Square D Company, Peru, IN. The supplier obtained the MCCB, through an Interplant Purchase Order, from the Page 1 of 2
Square D manufacturing plant located in Cedar Rapids, 10.
Copies of the Peru, IN Interplant PO and Test Certificates issued by Cedar Rapids, 10 are included in SCE QA Report titled, "Traceability Investigation Report Molded Case Circuit Breakers Supplied By Square D Company", dated 1/27/89. This breaker was determined to be traceable to the CBM.
- 4) The SCE PO covering this MCCB was issued to Square D Company, Peru, IN. The supplier obtained the MCCB, through an Interplant PO, from the Square D manufacturing plant located in Lincoln, Nebraska. Copies of the Peru, IN purchase document and certification from the manufacturing plant are attached. This MCCB was determined to be traceable to the CBM.
FOLLOW-UP ACTION No further follow-up action is required.
Prepare Approv By:
Distribution R.
M. Rosenblum T. Herring III D. C. Stonecipher S. S. Paranandi H. W. N wton R. E. Berkshire K. L. Bildwin E. J. Trombley B. G. Mendoza QA File' CDMC Page 2 of 2
APR 18 '89 09:4 3 SOD PERU PLT 1 RTT.4 A24T SQURR30 COMPRNY L aTRIN AL a
beg gst 1'
Iit Lice*L an I henby eartify that a 3/20/85 the Square D afhpedtesplies called for by Oneract itsele
&1 6
"Via
_UPS o
1ecordance with all applicable qu uts fm shment.
I further certify that the supplies are of the quality specfuted nod are is all respects in con termance with the contract flquirements, including spect tistions and/or statLAgs preservation, packaging, packing an saIktng requireats.
MRo
/2m oft
-- 3XII 000.
71YI
APR 13 '39 09:42 SQD PERU PLT 1
^e=T P
4(L
% V~
~'
/ -
~ 5 PURCH A" LR EAiU ST'0N & CHAN E ]REQUEST 1/P//yy, -1 O3 NON PRODUCnvE Ol ORDERCHANGE,11PRHS RE o
IDPRICE C-HANGE d
a o
T i C R C H a ~ I RIMANA IV CATCOfto nig P~h MA~e fm A
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0eAK1TOA RC
Report No. MCCB-27, Miscellaneous MCCBs May 18, 1989 TRACEABILITY VERIFICATION REPORT-MOLDED CASE CIRCUIT BRERAKERS SUPPLIED BY ELECTRO COMPONENT, GENERAL m n~
rn ELECTRIC CO, GE SUPPLY CO., MAGTROL, SATIN AMERICAN AND WESCO
Reference:
SUMMARY
None of the eleven (11) Molded Case Circuit Breakers (MCCBs) supplied to SONGS by Electro Component, General Electric Co., GE Supply Co., Magtrol, Satin American, and WESCO were verified to be traceable to the Circuit Breaker Manufacturer (CEM), as defined by the above referenced Bulletin.
DETAILS The eleven (11) MCCBs covered by this report are as follows:
Warehouse Qty Purchase Material Supplier/Remarks Record ID Order Code 315 2
6A126069 026-73408 Electro Component/
See Note 1 below 329 1
8D08540l 024-40584 General Electric/
See Note 2 below 312 4
6AI16005 024-40584 GE Supply Co/See 296 1
8WO6501 6 026-76799 Note 3 below
.1 6A76021 (HFB3l25)
Magtrol/ See Note 4 below 330 1
6H078059 027-00813 Satin American/See 311 1
V8200657 (HFA2100)
WESCO/SebeNow 6 below NOTES ON PROCUREMENT CHAIN
- 1) The P was issued to Electro Component. Based on the documents obtained from the supplier, the MCCBs were found to be obtained from California Breakers and/or Rosen Electrical Equipment Co. The MCCBs are considered not traceable to the CBM.
- 2) The PO was issued to GE, Nuclear Div., San Jose, CA.
The supplier ordered the MCCB from GE Supply Co. with an instruction to ship from the GE MCCB factory located in Plainville, CT.
Page 1 of 2
MCCB-27 No documents were obtained by the supplier from GE Supply or the factory to establish traceability to the CBM.
- 3) The PO was issued to GE Supply Co. who obtained the MCCBs from General Electric,Plainville, Ct. The supplier was unable to obtain documentation from GE to to establish traceability of the MCCB to the CBM.
- 4) The PO was issued to Magtrol, who obtained the MCCB from Romac. The only documents available, invoices from Magtrol and Romac, do not establish traceability of the MCCBs to the CBM.
- 5) The PO was issued to Satin American. No traceability documents were provided by the supplier. The traceability to the CBM was not established.
- 6) The PO was issued to WESCO. No traceability documents were provided by the supplier. The traceability to the CBM was not established.
Prepared By:
Approved By:
Distribution R. M. Rosenblum T. Herring III D. C. Stonecipher S. S. P ranandi H. W. Iewton RE.
arkshire K. L..8Idwin E. J. -ombley B. G. Mndoza QA File CDMC Page 2 of 2
Report No. MCCB-28, Miscellaneous ITE-GOULD MCCBs May 18, 1989 TRACEABILITY VERIFICATION REPORT-ITE-GOULD MOLDED CASE CIRCUIT BRERAKERS SUPPLIED BY BBC BROWN BOVERI, CONSOLIDATED ELECTRIC, AND SAN DIEGO SUPPLY
Reference:
SUMMARY
None of the three (3) ITE-Gould Molded Case Circuit Breakers (MCCBs) supplied to SONGS by BBC Brown Boveri, Consolidated Electric and San Diego Supply were verified to be traceable to the Circuit Breaker Manufacturer (CBM), as defined by the above referenced Bulletin.
DETAILS The three (3) MCCBs covered by this report are as follows:
Warehouse Qty Purchase Material Supplier/Remarks Record ID Order Code 285 1
8W045030 None (Model BBC Brown Boveri/
EF2-AO30)
See Note 1 below 318 1
65900349 026-24955 Consolidated/See Note 2 below 284 1
8J045014 None (Model San Diego Supply/
EF2-AO20)
See Note 3 below NOTES ON PROCUREMENT CHAIN
- 1) The PO was issued to BBC Brown Boveri. This supplier was,,unable to provide documents required to establish traceability of the MCCB to the CBM.
- 2) The P0 was issued to Consolidated Electric. Mr. K. Van Doran of Consolidated Electric stated that the records for this P0 are no longer available. The MCCB is considered to be not traceable to the CBM.
- 3) The PO was issued to San Diego Supply. Mr. C. Clayton of San Diego Supply stated that the records for this PO are no longer available. The MCCB is considered to be not traceable to the CBM.
Prepared Distribution R. M. Rosenblum K. L. Baldwin T. Herring III E. J. Trombley D. C. Stonecipher B. G. Mendoza S. S. Paranandi QA File H. W. Newton CDMC R. E. Berkshire Page 1 of 1
Report No. MCCB-29, GE and Westinghouse MCCBs June 5, 1989 2m
()
TRACEABILITY VERIFICATION REPORT-GE AND WESTINGHOUSE MOLDED CASE CIRCUIT BREAKR Wj LL
Reference:
NRC Bulletin 88-10 This report is being issued to document the results of the a
traceability verification activities for seventeen (17) tE and Westinghoe Molded Case Circuit Breakers (MCCBs),
that were not addressed in Report Nos. MCCB-7, dated 2/13/89, MCCB-23, dated 5/18/89, MCCB-24, dated 5/18/89, and MCCB-27, dated 5/18/89. Three (3) of the seventeen MCCBs were verified to be traceable to the Circuit Breraker Manufacture (CBM), as defined by the above referenced Bulletin. Thirteen (13) of the seventeen (17) MCCBs were determined to be not traceable to the CBM and one (1) was determined to be traceable only to the CBM Warehouse.
The acceptability of the MCCB that is traceable to the CBM Warehouse is dependent upon NRC's acceptance of the Westinghouse position that traceability to the CBM Warehouse is considered "traceable to the CBM". A copy of the Telephone Notes documenting the discussions by SCE with NUMARC on the Westinghouse positionis attached.
DISCUSSIONS The foll ing MCCBs are covered by this report:
Record qty Purchase Material Remarks ID No.
Order Code 215 1
CA)50 0124-240 See Note 1, below 232 1
V82006.57 027-29432 See Note 2, below 233 6
t 027-29481 n
234 4
to 027-29457 1
245 1
n o
268 1
027-29432 247 2
8N085403 026-69935 See Note 3, below 251 1
8N085243 024-29413 See Note 4, below NOTES ON PROCUREMENT CHAIN
- 1) This MCCB was ordered by SCE from Westinghouse, Nuclear Service Division. The traceability of the MCCB to the controlled warehouse of the Circuit Breaker Manufacturer (CBM) was verified during the audit conducted at Westinghouseti on 5/11/89. Westinghouse has taken the position that traceability to the controlled.warehouse is considered "traceable to the CBM" as defined by NRC Bulletin 88-10.
The acceptability of the MCCB is dependent upon NRC's acceptance of the Westinghouse Pposition.
Page 1 of 2
Report No. MCCB-29 (See also Report No. MCCB-23, dated 5/18/89; this MCCB was supplied with MCCB ID 231, under the same PO)
- 2) These MCCBs were ordered by SCE from WESCO. As reported in MCCB-27, dated 5/18/89, WESCO was unable to provide traceability documents. These MCCBs are considered to be not traceable to the CBM.
- 3) These MCCBs were ordered by SCE from General Electric, San Jose, CA. Shipment from the CBM, GE, Plainville, CT was verified based on the review of invoices and shipping documents. These MCCBs are considered traceable to the CBM. (See also Report No. MCCB-7, dated 2/13/89 for other MCCBs covered by PO 8N085403.)
- 4) This MCCB was ordered by SCE from Associated of Los Angeles, who in turn ordered the MCCB from WESCO. The MCCB was manufactured by Westinghouse, Beaver, PA under Order No. LA 52337. (See also Report No. MCCB-24, dated 5/18/89 for other MCCBs covered by PO 8N085423)
Prepared By: _____________/_8 Approved By:
Distribution R. M. Rosenblum T. Herring III D. C. Stonecipher S. S. Paranandi H. W. Newton R. E. Berkshire K. L. Baldwin E. J. Trombley B. G. Mendoza QA File CDMC Page 2 of 2
Page 1 of 3 Report No. MCCB-30, Westinghouse Nuclear Service Division July 3, 1989 TRACEABILITY VERIFICATION REPORT-WESTINGHOUSE MOLDED CASE CIRCUIT BREAKERS
Reference:
SUMMARY
In response to the above referenced NRC Bulletin, a QA audit to verify the traceability of Westinghouse Molded Case Circuit Breakers (MCCBs), was conducted on 6/27/89 by SCE QA at Westinghouse, Monroeville, PA (Nuclear Service Division).
As a result of the audit, two (2) of the eighteen (18)
Westinghouse MCCBS that are covered by the following SCE Purchase Orders, were found to be traceable to the Circuit Breaker Manufacturer (CBM). The balance of sixteen (16)
MCCBs were found to be traceable to the CBM Warehouse.
o PO No. 6D127901, Release N671 -
Traceable to Warehouse o PO No. 6D127901, Release P535 -
Traceable to Warehouse o PO No. 8A035901, Release M087 -
Traceable to Warehouse o PO No.-6A116029, (No Release) -
Traceable to Warehouse o PO No.,8WO94999, Release A560 -
Traceable to CBM DISCUSSION The aud rwas conducted by reviewing traceability documents that were researched and compiled by WNSD Nuclear Products QA, in accordance with SCE PO 6D029902, dated 2/16/89.
The following Westinghouse MCCBs were investigated:
Record Qty Purchase Part No. Remarks ID No.
Order 154 2
6D127901, HFB3125 See Notes 1, 2 & 10 Rel N671 242 5
6A116029 FB3020PL See Notes 1, 3 & 10 261 1
8A035901, HFB2020 See Notes 1, 4 & 10 Rel M087 262 3
n HFB2030 See Notes 1, 5 & 10 263 2
n HFB2070 See Notes 1, 6 & 10 264 2
n HFB2100 See Notes 1, 7 & 10 310 1
8WO94999, FB3070PL See Notes 1 & 8 Rel A560 313 1
See Notes 1 & 8 331 1
6D127901, HFB3020 See Notes 1, 9 & 10 Rel P535 RECEIVED JUL 13 19.
-RICE BERKSHIRE
MCCB-30 Page 2 of 3 O
NOTES ON PROCUREMENT CHAIN
- 1) The task to research and compile traceability documents for SCE is covered by PO No. 6D029902, issued to WNSD, dated.2/16/89, and subsequent P0 Releases.
- 2) The following records were presented for review during this audit to verify the traceability of the MCCBs:
o Engineering Work Order 880.397, Rev. 0, 4976DO4G45 Serial Nos. 880.397-1 & -2 0
Engineering Work Order 880.397, Rev 1, 497DO4G45 Serial No. 880.397-3 o WNSD PO No. MA-07393, dated 7/14/88, issued to Westinghouse Electric Supply Company (WESCO) o WESCO's Master Verification List, dated 8/29/88 (This document shows that the MCCBs were procured by WESCO from the Westinghouse Warehouses)
Based on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 3) The following documents were reviewed for these MCCBs:
a'- Engineering Work Order 871.125, 178C7936G19 1Serial Nos. 871.125-1 through -5 WNSD PO No. MN87451-M, issued to Westinghouse Warehouse W-34 Packing List issued by Warehouse W-34 Based on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 4) The following documents were reviewed for this MCCB:
o Engineering Work Order No. 871.593, 4976D04G19 Serial No. 871.593-1 o WNSD PO No. MN94339-M, issued to WESCO (Item #1) o WESCO's PO to Westinghouse Warehouse W-34 o W-34's Packing List (direct shipment to WNSD)
Based.on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 5) The following documents were reviewed for these MCCBs:
o Engineering Work Order No. 871.593, 4976DO4G21 Serial Nos. 871.593-1, -2 and -3 o WNSD PO No. MN94339-M, issued to WESCO (Item #2) o WESCO's PO to Westinghouse Warehouse W-34 o W-34's Packing List (direct shipment to WNSD)
Based on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 6) The following documents were reviewed for these MCCBs:
MCCB-30 Page 3 of 3 o Engineering Work order No. 871.593, Rev. 0, 4976DO4G26, Serial Nos. 871.593-1 and -2 o WNSD PO No. MN94339-M, issued to WESCO (Item #3) o WESCO's PO to Westinghouse Warehouse W-34 o W-34's Packing List (direct shipment to WNSD)
Based on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 7) The following documents were reviewed for these MCCBs:
o Engineering Work Order No. 871.593, Rev. 0 4976DO4G28, Serial No. 871.593-1, -2 and -3 o WNSD PO No. MN94339-M, issued to WESCO (Item #5) o WESCO's PO to Westinghouse Warehouse W-34 o W-34's Packing List Based on the review of the above documents, the MCCBs are considered traceable to the CBM Warehouse.
- 8) The following documents were reviewed for these MCCBs:
o Certificate of Compliance, Issued by W-Fayetteville, NC o Certificate of Conformance, issued by W-Beaver, PA o Packing List, issued by W-Beaver, PA (Manufacturer)
Based on the review of the above documents, the MCCBs considered to be traceable to the CBM.
- 9) The' following documents were reviewed for this MCCB:
o Engineering Work Order 880.488, Rev. 0, 4976DO4G35 Serial No. 880.488-1 o WNSD's PO No. MA13319-M, dated 9/27/88, issued to WESCO o WESCO's Master Breaker Verification List o WESCO's leter dated 8/29/88, K. A. Gordon to T. W. O'Toole, Manager, Procurement Services)
- 10) Note No. 1, Report No. MCCB-29, also applies to these MCCBs. A copy of Report No. MCCB-29 is attached.
Prepared By:
,e Approved By:
7--t Distribution D. E. Shull Jr.
K. L. Baldwin T. Herring III
.E. J. Trombley D. C. Stonecipher B. G. Mendoza S. S. Paranandi QA File H. W. Newton CDMC R. E. Berkshire
Attachmnt MCCB-30 Page 1 of 4 Report No. MCCB-29, GE and Westinghouse MCCBs June 5, 1989 TRACEABILITY VERIFICATION REPORT-GE AND WESTINGHOUSE MOLDED CASE CIRCUIT BREAKERS
Reference:
NRC Bulletin 88-10 This report is being issued to document the results of the traceability verification activities for seventeen (17)
GE and Westinghouse Molded Case Circuit Breakers (MCCBs),
that were not addressed in Report Nos. MCCB-7, dated 2/13/89, MCCB-23, dated 5/18/89, MCCB-24, dated 5/18/89, and MCCB-27, dated 5/18/89. Three (3) of the seventeen MCCBs were verified to be traceable to the Circuit Breraker Manufacture (CBM), as defined by the above referenced Bulletin. Thirteen (13) of the seventeen (17) MCCBs were determined to be not traceable to the CBM and one (1) was determined to be traceable only to the CBM Warehouse.
The acceptability of the MCCB that is traceable to the CBM Warehouse is dependent upon NRC's acceptance of the Westinghouse position that traceability to the CBM Warehouse is considered "traceable to the CBM". A copy of the Telephone Notes documenting the discussions by SCE with NUMARC on the Westinghouse position,is attached.
DISCUSSIONS The fo Alowing MCCBs are covered by this report:
Record Qty Purchase Material Remarks ID No.
Order Code 215 1
8A035901 024-29405 See Note 1, below 232 1
V8200657 027-29432 See Note 2, below 233 6
027-29481 234 4
027-29457 i
245 1
t" i
.268 1
027-29432 247 2
8NO85403 026-69935 See Note 3, below 251 1
8N085243 024-29413 See Note 4, below NOTES ON PROCUREMENT CHAIN
- 1) This MCCB was ordered by SCE from Westinghouse, Nuclear Service Division. The traceability of the MCCB to the controlled warehouse of the Circuit Breaker Manufacturer (CBM) was verified during the audit conducted at Westinghouse-NSD on 5/11/89. Westinghouse has taken the position that traceability to the controlled warehouse is considered "traceable to the CBM" as defined by NRC Bulletin 88-10.
The acceptability of the MCCB is dependent upon NRC's acceptance of the Westinghouse position.
Page 1 of 2
Attachmrent MCCB-30 Page 2 of.4 Report No. MCCB-29 (See also Report No. MCCB-23, dated 5/18/89; this MCCB was supplied with MCCB ID 231, under the same PO)
- 2) These MCCBs were ordered by SCE from WESCO. As reported in MCCB-27, dated 5/18/89, WESCO was unable to provide traceability documents. These MCCBs are considered to be not traceable to the CBM.
- 3) These MCCBs were ordered by SCE from General Electric, San Jose, CA. Shipment from the CBM, GE, Plainville, CT was verified based on the review of invoices and shipping documents. These MCCBs are considered traceable to the CBM. (See also Report No. MCCB-7, dated 2/13/89 for other MCCBs covered by PO 8N085403.)
- 4) This MCCB was ordered by SCE from Associated of Los Angeles, who in turn ordered the MCCB from WESCO. The MCCB was manufactured by Westinghouse, Beaver, PA under Order No. LA 52337. (See also Report No. MCCB-24, dated 5/18/89 for other MCCBs covered by PO 8N085423)
Prepared By:
Approved By:
Distribtion R. M. R;enblum T. Herrng III D. C. Stonecipher S. S. Paranandi H. W. Newton R. E. Berkshire K. L. Baldwin E. J. Trombley B. G. Mendoza QA File CDMC Page 2 of 2
Attachlrent MCCB-30 Page 3 of 4 Attachment Report No. MCCB-29 TELEPHONE NOTES DISTRIBUTION BY:RICE BERKSHIRE-OF:SCE
- 1. C.K.BALOG
- 2. A.J.BROUGH WITH:RUSSEL BELL OF:NUMARC
- 3. T.HERRING
- 4. B.G.MENDOZA DATE:5/23/89
- 5. H.W.NEWTON
- 6. C.E.WILLIAMS
SUBJECT:
NRC BULLETIN 88-10
- 7. D.G.STICKNEY NUMARC MEETING WITH NRC STAFF DISCUSSION HIGHLIGHTS AND AGREEMENTS REACHED:
RUSS CONFIRMED THAT NUMARC MET WITH THE NRC STAFF LAST WEEK TO DISCUSS THE DRAFT SUPPLEMENT TO BULLETIN 88-10 AND THE.UTILITIES RESPONSES. THE STAFF HAD INDICATED THEIR DISAPPOINTMENT IN THE RESPONSES AS DOCUMENTED IN MEDIA REPORT (INSIDE N.R.C.-APRIL 24,1989).
THE STAFF PORTRAYS THE SUPPLEMENT AS CLARIFYING THE ORIGINAL INTENT OF THE BULLETIN; HOWEVER NUMARC SEES IT AS ADDING SCOPE TO THE BULLETIN AND TOOK STRONG EXCEPTION TO THE WORDING IN IT'S PRESENT FORM. TWO KEY ITEMS ARE:
- 1.
ANY SPARE ORIGINIAL CONSTRUCTION MCCBs LOCATED IN THE WAREHOUSE REQUIRE TRACEABILITY VERIFICATION.
(We included all warehouse stock in trace veiification effort.)
2 NY SOURCES :THAT WERE DETERMINED TO BE NOT TRACEABLE IN THE '83-'88 GROUP WILL NEED TRACEABILITY VERIFICATION OF ALL PREVIOUS SUPPLIED MCCBs.
(Maifor impact on Unit 1, significiamt impact on Units 2/3)
NUMARC POINTED OUT TO THE STAFF THAT THE SYNERGISTIC EFFECT OF THESE TWO ITEMS WILL BE EXTENDING TRACE VERIFICATION TO ALL INSTALLED MCCBs. THE STAFF HAS TAKEN'THIS COMMENT UNDER ADVISEMENT BUT HASN'T STATED WHICH WAY THEY WILL GO.
THE STAFF IS AGREEABLE WITH THE APPROACH THAT TRACE VERIFICATION TO A CORPORATE CONTROLLED FACILITY (CORPORATE WAREHOUSE VS. DISTRIBUTOR WAREHOUSE) WOULD SATISFY TRACEABILITY REQUIREMENT. I ADVISED RUSS OF HOUSTON LIGHTING AND POWER'S PRESENTATION, WITH ASSISTANCE FROM WESTINGHOUSE, TO THE NRC STAFF TWO WEEKS AGO ADDRESSING THIS SAME ISSUE.
THE STAFF'S RESPONSE TO BOTH NUMARC AND HOUSTON IS CONSISTANT. RUSS WILL CONTACT THE HOUSTON REPRESENTATIVE AND DISCUSS THE DETAILS OF THEIR MEETING. THIS APPROACH WILL HELP SCE VERIFY MCCBs PURCHASED THROUGH WESTINGHOUSE NUCLEAR SERVICE DIVISION.
RUSS EXPECTS THAT THE NRC WILL DO SPOT INSPECTIONS ON THE RESOPONSES.
THEY WILL PROBABLY FOCUS ON UTILITIES THAT HAD RESPONSES FITTING IN THE FOLLOWING CATAGORIES:
1.GLARING DIFFERENCE FROM REQUESTED RESPONSE (EXAMPLE -
TRACE SAMPLE OF WAREHOUSE MCCBs) 2.NO DETAILS PROVIDED IN RESPONSE (EXAMPLE -
FULL COMPLIANCE, ALL MCCBs TRACEABLE,.
BUT NO BACKUP IN SUBMITTAL) 3.DETAILS THAT SHOW LACK OF UNDERSTANDING OF Page 1 of 2
Attacoment MCCB-30 Pace 4 of 4 Attacnment.
Report No. MCCB-29 BULLETIN IN RESPONSE TO MY QUESTION, RUSS COMMENTE THAT SCE'S RESPONSE WAS CONSIDERED A GOOD-PACKAGE.
OUR TEST PROCEDURE WAS THE BEST HE HAD SEEN AND OUR DESCRIPTION OF EFFORT WILL HEAD OFF QUESTIONS RAISED WITH OTHER RESPONSES.
Page 2 of 2
Page 1 of 2 Report No. MCCB-31, Miscellaneous Molded Case Circuit Breakers July 5, 1989 TRACEABILITY VERIFICATION REPORT-MOLDED CASE CIRCUIT BREAKERS SUPPLIED BY AIRPAX, AMFAC, ELECTRO-COMPONENTS, GENERAL ELECTRIC, SQUARE D, AND WESTINGHOUSE
Reference:
SUMMARY
This report documents the results of activities performed by SCE QA to verify the traceability of twenty nine (29) miscellaneous Molded Case Circuit Breyakers (MCCBs), in response to the above referenced NRC Bulletin.
Eleven (11) of the twenty nine (29) MCCBs were verified to be traceable to the Circuit Breaker Manufacturer. The traceability to the CBM of the remaining eighteen (18) could not be established.
DETAILS The twenty nine (29) MCCBs covered by this report are as follows:
Warehouse Qty Purchase Material Remarks Record D Order Code 222 4
6A126069 026-73408 Not Traceable, See Note #1 below 269 1
6D085401 024-40584 Not Traceable, See Note #2 below 270 3
64132136 023-04178 Traceable, See Note
- 3 below 271 1
6DO35901, 024-29439 Not Traceable, See Rel 0451 Note #4 below 272 10 8B112067 024-93310 Not Traceable, See Note #5 below 273 4
6WO29005 026-10715 Traceable, See Note
- 6 below 274 4
G8203541 026-10053 Traceable, See Note
- 6 below 275 2
8D045027 026-10053 Not Traceable, See Note #7 below NOTES ON PROCUREMENT CHAIN
- 1) The SCE Purchase Order (PO) for these MCCBs was issued to Electro-Component Distributor. Based on the review of the documents furnished by the supplier, it was determined that the MCCBs were supplied by California Breakers and/or Rosen Electrical Equipment Co. The, MCCBs are considered to be not traceable to the CBM, per NRC Bulletin 88-10.
RECEIVED JUL 3 1CJ RICE BERKSHIRE
MCCB-31 Page 2 of 2
- 2) The SCE PO was issued to General Electric, San Jose, CA.
The supplier ordered the MCCBs supplied to SCE from General Electric Supply. No documents are available from General Electric Supply to establish traceability to the General Electric manufcturing plant. The MCCBs are considered to be not traceable to the CBM.
- 3) The traceability of the MCCBs was verified by reviewing documents obtained from AMF, Potter & Brumfield Division, including the supplier's Certificate of Compliance and SCE's Receiving documents. The MCCBs are considered traceable to the CBM.
- 4) The task to research and compile traceability documents for SCE is covered by PO No. 6D029902, issued Westing house, Nuclear Service Division WNSD. The following records were reviewed by SCE QA, on 5/11/89:
o Engineering Work Order 871.755 o
WNSD PO No. MN97417 issued to Westinghouse Warehouse W-34, o
Packing List furnished by Warehouse W-34 Based on the review of the above documents, the MCCB was considered to be traceable to the CBM Warehouse.
- 5) The.MCCBs were purchased from Airpax. Ms. J. Phillips, Airpax, Marketing, stated that records to establish traceability of the MCCBs to Airpax are no longer maintained by Airpax.
- 6) The SCE PO was issued to Square D Company, Peru, IN. The MCCBs were supplied by the Square D manufacturing plant located in Cedar Rapids, 10. The MCCBs are considered to be traceable to the CBM.
- 7) The SCE PO was issued to Amfac Electrical Supply Company.
Mr. C. Myers of Amfac stated that records for the PO are no longer available. The MCCBs are considered to be not traceable to the CBM.
Prepared By:,
27 Approved By:
Distribution D. E. Shull Jr.
K. L. Baldwin T. Herring III E. J. Trombley D. C. Stonecipher B. G. Mendoza S. S. Paranandi QA File H. W. Newton CDM Center R.
E. Berkshire
Page 1 of 2 Report No. MCCB-32, Miscellaneous Molded Case Circuit Breakers July 26, 1989 TRACEABILITY VERIFICATION REPORT-MOLDED CASE CIRCUIT
- BREAKERS SUPPLIED BY BROWN BOVERI INC. AND WESTINGHOUSE
Reference:
SUMMARY
This report documents the results of adtivities performed by SCE QA to verify the traceability of eight (8) Molded Case Circuit Breakers (MCCBs) supplied by Brown Boveri, Inc.
and Westinghouse, in response to the above referenced NRC Bulletin.
Five (5) of the eight (8) MCCBs were verified to be traceable to the Circuit Breaker Manufacturer (CBM). The traceability to the CBM of the remaining three (3) MCCBs could not be established.
DETAILS The eight (8) MCCBs covered by this report are as follows:
Warehous&
Qty Purchase Material Remarks Record ZD Order Code 257 1
8B042026 024-29439 Traceable, See Note #1 below 82 2
8AO35901, 027-29507 Traceable, See Rel. A069 Note #2 below 332 1
8D108043 OBO-14690 Traceable, See Note #3 below 297 1
8AO35901, Type HKA Traceable, See Rel. A029 3225T Note #4 :below 301 3
56D00037 027-38979 Not Traceable, See Note #5 below NOTES ON PROCUREMENT CHAIN
- 1) The SCE Purchase Order (PO) for this MCCB was issued to Westinghouse. The MCCB was supplied by the Westinghouse Beaver, PA plant (CBM) under Order No. LA32629.
An audit at the CBM's plant by SCE QA on 5/12/89 indi cated that traceability records are maintained.
- 2) The SCE PO was issued to Westinghouse. The MCCBs were supplied by Westinghouse, NSID, under Order No. LA39513.
During an audit conducted at the supplier's facility by SCE QA on 5/11/89, the MCCBs supplied by NSID were verified to be traceable to the CBM Warehouse.
Report No. MCCB-32 Page 2 of 2
- 3) The SCE PO was issued to Westinghouse. The MCCB was supplied by Westinghouse, NSID, under Order No. LA39908.
During an audit conducted at the supplier's facility by SCE QA on 5/11/89, the MCCBs supplied by NSID were verified to be traceable to the CBM Warehouse.
- 4) The task to research and compile traceability documents for SCE is covered by.PO No. 6D029902, issued Westing house, Nuclear Service Division, WNSD. The supplier confirmed that the MCCB covered by SCE PO 8A035901, Release A029 was supplied by Westinghouse under Order No.
LA34974. During an audit conducted at the supplier's facility by SCE QA on 5/11/89, the MCCBs supplied by NSID were verified to be traceable to the CBM Warehouse.
- 5) The SCE PO was issued to Brown Boveri, Inc. The supplier's records to establish traceability to the CBM, ITE-Siemens Allis, are not available. The MCCBs are considered not traceable to the CBM.
Prepared By:
Approved By:
3 Distribu ion D. E.
Shb'1l Jr.
K.
L. Baldwin T. Herring III E. J. Trombley D. C. Stonecipher B. G. Mendoza S. S. Paranandi QA File H. W. Newton CDM Center R. E. Berkshire
ENCLOSURE II
UNIT 1 EVALUATION JUSTIFYING CONTINUED OPERATION (JCO)
Rev. 1 TABLE OF CONTENTS I.
INTRODUCTION II.
REFERENCES III. EXISTING CONDITION A.
BACKGROUND B.
EVENT and/or CONDITION IV. SCOPE OF MCCBs EVALUATION V.
DESIGN REQUIREMENTS and VERIFICATION ACTIVITIES A.j STATION APPLICAtION and FUNCTION B.-
PRESERVICE TEST and INSPECTIONS VI.
JUSTIFICATION FOR CONTINUED OPERATION A.
JUSTIFICATION B.
SAFETY EVALUATION VII. JCO DURATION and TEMPORARY CONTROLS EXHIBIT 1 SIMPLIFIED ONE LINE DIAGRAM
I.
INTRODUCTION This JCO is provided to address continued operation as a result of completing traceability investigations for five of the Molded Case Circuit Breakers (MCCBs), Record IDs 296, 301 and 330 identified in NCR-P-7129 for SONGS Unit 1.
These investigations are summarized in SCE QA Reports MCCB-27 and MCCB-32. MCCB Record ID 288 is included because the purchase order information can not be identifiedil.".
This JCO is provided as specified in the NCR Disposition under Block 21, Item II.C, which states that within 30 days of completing traceability investigation, perform an evaluation justifying continued operation based on the use of the existing MCCBs.
II.
REFERENCES Procedures Test Procedure, S0123-I-4.7, Molded Case Circuit Breakers Test Procedure, S0123-GT-400-07 Generic Test Procedure for Molded Case Circuit Breakers Te Procedure, S023-302-4-1-785-0 Wedeinghouse Molded Case Circuit Breakers Verification Test Procedure, VTP-E-067, Molded Case Circuit Breaker Verification Test Program Drawings M-89030, Unit 1 Safety Related Electrical Set Point List (ESL), REV. A.
90036AB, Appendix R Fire Analysis Coordination Calculation Equipment specifications Purchase Specification, Motor Control Centers Purchase Specification, DC Power Bus Breaker standards UL-489, Molded Case Circuit Breaker and Circuit Breaker Enclosures NEMA-AB1, Molded Case Circuit Breakers
III. EXISTING CONDITION A. BACKGROUND
- 1. On July 8, 1988, the Nuclear Regulatory Commission (NRC) issued Information Notice 88-46, to alert licensees that refurbished MCCBs may have been supplied to nuclear power plants. NRC Notice 88-46 stated that Pacific Gas and Electric had purchased MCCBs intended for non-safety related applications from a local distributor who in turn purchased the MCCBs from another supplier for drop shipment.
Square D questioned the delivery and requested an inspection. Their findings indicated that the breakers showed signs of reassembly and relabeling.
Square D reported that the breakers did not comply with manufacturing specifications.
In two supplements to NRC Notice 88-46, the NRC named 14 suppliers as suspects for supplying refurbished MCCBs.
Based on NRC Notice 88-46, SCE commenced a set of actions to identify and mitigate the supply of suspect MCCBs for station use.
NRC Bulletin 88-10 II The NRC issued Bulletin 88-10 on November 22, 1988, to request the addressees to provide reasonable assurances that MCCBs purchased for use in safety related applications without verifiable traceability perform their safety function.
The NRCs expressed concern is that MCCBs purchased as new may not conform to manufacturer's specifications. Unauthorized refurbishing could jeopardize design capability and reliability. MCCBs which cannot be traced to the manufacturer must be addressed for appropriate corrective action.
NEMA and UL have stated that fault protection capabilities are verified by destructive testing of selected breakers representing production under controlled conditions.
In Bulletin 88-10, the NRC prescribed actions, including implementation of a test and replacement program. The NRC considers these actions as reasonable assurance that MCCBs that cannot be traced will perform their safety function. NRC Bulletin 88-10 allows for continued use of installed MCCBs that cannot be traced until these actions can be implemented during the appropriate unit refuel.
2
The NRC also requested that a JCO be prepared for MCCBs that cannot be traced for the duration they remain in service.
- 3. SCE and Industry Findings The distribution of refurbished MCCBs has potentially reached significant proportions in the installed population within the nuclear power industry. The significance of these proportions warrants appropriate investigation and corrective action.
SCE specifications for power distribution panels and motor control center require that the vendor furnish evidence that endurance test, in accordance with NEMA AB-1-1969, have been completed on breakers of the same design.
MCCBs which are supplied outside the manufacturing controls or jurisdiction intended by these specifications, represent a potential deviation from equipment design and performance requirements.
B.,EVENT AND/OR CONDITION The event described in NRC Notice 88-46 and NRC Bulletin 8-10 does not identify a specific nonconforming
"'ondition present in SONGS operating equipment.
However, the generic concerns described do represent real and likely conditions which potentially could occur. This JCO considers the known procurement chain, testing and inspection, and station applications.
IV.
SCOPE OF MCCBs EVALUATED FOR CONTINUED OPERATION The MCCBs which are addressed by this JCO are identified in NCR P-7129 for SONGS Unit 1. These MCCBs were purchased and installed during the interval August 1, 1983, through August 1, 1988, as specified in NRC Bulletin 88-10.
The investigation to establish traceability for these MCCBs have been completed and have shown that these MCCBs represent the installed population which cannot be traced to the circuit breaker manufacturer.
3
MCCBs REFERENCED IN NCR P-7129 WHICH PERTAIN TO THIS JCO NCR MO BREAKER SERVICE MFG MODEL AMP ID ID 288 85060813001 8-1134 New Fuel West FB 30 Bridge Crane 296 86013409000 VTB INVTR3 Vital Bus GE TEB 100 Invertor #3 301 86040434000 152 1A403 125 VDC Control Siem-EH2-BO 30 Power to DSD Allis 4160 VAC Bus A4 152 1A404 152 1A405 330 88072099000 Y15-1500 Utility Bus Main West E2100 100 The Supplier of the MCCB for Record ID 288 is indeterminate.
The MCCB for Record ID 296 was supplied from General Electric Supply Company.
The MCCB for Record ID 301 was supplied from BBC-Brown Boveri, Incorporated.
The MCCB.for Record ID 330 was supplied from Satin America, who is not NRC Notice 88-46 listed, but who specializes in the distribution of surplus electrical equipment. This MCCB is an early M461 vintage.
V.
DES-GN REQUIREMENTS AND VERIFICATION ACTIVITIES A.
STATION APPLICATION AND FUNCTION A description of each MCCB application and their respective station application are provided as follows:
NOTE:
Each MCCB listed is identified by Breaker ID except ID 296 which is part of the skid mounted equipment, in the Electrical Set Point List (ESL).
Circuit breakers which are credited to provide isolation in an Appendix R scenario have been analyzed in station coordination study, 90036AB, for fire protection and safe shutdown requirements.
MCCB 8-1134 (288)
MCCB 8-1134 feeds 480 volt power to the 3 Ton New Fuel Bridge Crane. The crane's function is to manipulate New Fuel Assemblies between New Fuel Cask, New Fuel Storage Racks, receiving/inspection area, and the Fork Lift Truck that transports New Fuel Elements to the Refueling Cavity. A spurious MCCB trip would delay movement of New Fuel. However, it would not affect other safety systems.
4
MCCBs 152 1A403, 152 1A404 and 152 1A405 (301)
MCCBs 152 1A403, 152 1A404 and 152 1A405 feeds 125 VDC control power to Dedicated Safe Shutdown (DSD) 4160 VAC Bus A4, cubicles 1A403, 1A404 and 1A405, respectively, from the 125 VDC DSD Bus D28, breaker D2804.
The load function is non-safety related, but fire protection related (NSR-FP).
The DSD System is designed to be placed into operation in the event of a fire in designated fire zones affects the ability of the plant to establish Hot Shutdown, and to achieve and maintain Cold Shutdown conditions with the normal Safe Shutdown System.
The DSD 4160 VAC Bus cubicles mentioned above house the 4160 VAC circuit breakers that feeds 4160 VAC power as follows:
o Circuit breaker 1A403 -
feeds 4160 VAC backup power, generated by the DSD diesel generator, to Charging Pump G-8A o
Circuit breaker 1A404 -
feeds 4160 VAC backup power, generated by the DSD diesel generator, to the third Auxiliary Feedwater Pump G-10W Circuit breaker 1A405 -
is the DSD diesel generator feeder circuit breaker. It feeds the 4160 VAC backup power to the DSD 4160 VAC Bus A4 The operation of these circuit breakers, i.e., to close when the 4160 VAC backup power is needed and to trip open to protect the electrical equipment it is feeding power to, in the event of an abnormality, is dependent upon the availability of the 125 VDC control power.
The design bases for the DSD System to satisfy 10CFR50 Appendix R requirements is for the system to be able to perform its functions as designed. A spurious MCCB trip would, therefore, impact compliance with this requirement.
MCCB VTB INVTR 3 (296)
MCCB VTB INVTR 3 is installed within vital bus invertor No. 3. It is the main input circuit breaker, feeding 125 VDC main power to the invertor, from the 125 VDC Distribution Switchgear No. 1, breaker 72-137.
The MCCB is equipped with an under voltage coil which trips the MCCB if the 125 VDC power supply to the invertor is interrupted. The load function is safety related. The invertor provides conditioned 120 VAC, 60 Hz power to 5
various safety related control and instrument loads, which are susceptible for jeopardizing the safe operation of the plant when a power loss occurs.
Therefore, a spurious MCCB trip would impact plant safety. The 120 VAC system, however, has been designed to provide a reliable source of power. To accomplish this, a back-up emergency power source has been provided for each vital bus invertor. For vital bus invertor No. 3, an automatic transfer provides the emergency back-up power from a 37.5 KVA transformer to the vital buses normally supplied from invertor No. 3.
MCCB Y15-1500 (330)
MCCB Y15-1500 is the Utility Bus Main Breaker supplied from Motor Control Center MCC-2. The Utility Bus supplies power to various safety related loads which are susceptible for causing a unit trip when a power loss occurs. Therefore, a spurious MCCB trip would impact unit reliability. The Utility Bus is upstream protected by the MCC-2 Feeder MCCB 8-1238.
MCCB Y15 1500 provides protection against low duty faults at the Utility Bus which could be undetected by the MCCB 8 1238 due to the presence of the MCC -
Utility Bus step down transformer.
Asiplified Main One Line Diagram illustrating the in rrelationship of these MCCBs with the Electrical Power System is attached to this JCO as Exhibit 1.
B.
PRESERVICE TEST AND INSPECTIONS Preservice testing of Record ID 288 MCCB has not been documented. It is a current vintage MCCB, Westinghouse FB 30 amp Tri-Pac.
A visual inspection was conducted by Engineering and Maintenance Planning personnel of the MCCB for Record ID 288.
The inspection was limited to the attributes which are visually accessible in the installed configuration. The MCCB appeared new and no evidence of tampering was noted. There is no reason to suspect that this current model breaker would be refurbished from its appearance.
Record ID 330 MCCB was preservice tested in accordance with the Station Test Procedure for Molded Case Circuit Breakers. It was subjected to a 300% over-current trip and dielectric test.
Another MCCB listed, Record ID 296, was tested after installation in accordance with the Station Circuit 6
Device Tests and Overall Functional Test Procedure.
The MCCBs together with the involved circuitry, was tested to verify that the circuitry operated per the design.
A visual inspection was conducted by test technician and QC personnel of the MCCB for Record ID 296. The inspection was limited to the attributes which are visually accessible in the installed configuration.
The MCCB appeared new and no evidence of tampering was noted. The date stamp on the breaker indicates that it was manufactured mid May 1985.
The breaker was received by SCE June 24, 1985.
There is no reason to suspect that this current-model breaker would be refurbished in this short a time span.
MCCBs listed as Record ID 301 have not been given preservice testing by themselves but were part of the overall circuit and functional testing given to the main 4.16 KV circuit breakers. The MCCBs together with the other components comprising the control circuitry of the 4.16 KV circuit breakers were tested to verify that the control circuitry and its components operated per the design.
"The test results are contained in the Maintenance Work Order packages referenced in Section IV of this JCO.
These test results demonstrate satisfactory breaker performance within selected ranges of the manufacturer's design characteristics.
The tests performed are not as severe as those prescribed in NRC Bulletin 88-10. However, the tests performed did check breaker performance for most anomalies that could potentially be present due to refurbishment. Any gross disrepair would be detected by the station tests performed.
A visual inspection was conducted by test technician and QC personnel of the MCCBs for Record ID 301. The inspection was limited to the attributes which are visually accessible in the installed configuration.
Although the labels on the MCCBs (except for the label for the MCCB in cubicle 1A405 which was missing) are typewritten labels, the MCCBs for Record ID Number 301 shows firm appearances of factory intact assembly. The upper hole on each MCCBs is filled with compound (a method used by some manufacturers in lieu of a tamper proof seal).
The front side of the MCCB in cubicle 1A405 is partially covered such that not enough of the MCCB was visible. Overall, however, the MCCBs appear new and no evidence of tampering was noted. The MCCB cases showed signs of normal wear and tear.
7
A review of inspections and tests conducted on stored spares was checked to determine what inferences could apply based on common RSO, material codes or model numbers. There is no similar commonality for the MCCBs listed for Record IDs 296, 301 and 330.
VI. JUSTIFICATION FOR CONTINUED OPERATION A.
JUSTIFICATION Based on the existing condition identified in Section III as it relates to the station applications described in Section V, the following justification for continued operation is provided for each MCCB:
MCCB 8-1134 (288)
Although preservice testing was not documented for Record ID 288 MCCB, it has accumulated 45 months of service in its present application without spurious trips. This breaker is of current vintage and thus less susceptible to the concerns of Bulletin 88-10.
Also, the inspection results infer an MCCB with no
.-signs of tampering. Thus the breaker is expected to function based upon the relative absence of suspect indications. However, the breaker will be opened and tagged to alleviate further circuit protection concerns. The controls to assure that 8-1134 remains "out of service until tested or replaced are addressed in Section VI, JCO Duration and Temporary Controls.
MCCBs 152-1A403. 152-1A404 and 152-1A405 (301)
Although the MCCBs installed have not been given preservice testing, they have accumulated 38 months of service in their present application without spurious trips.
These MCCBs are of current vintage and thus less susceptible to the concerns of Bulletin 88-10.
- Also, the inspection results infer MCCBs with nil probability of tampering. Thus, the MCCBs are assured to function based on the relative absence of suspect indications.
The time that the DSD System will be activated and.
utilized to satisfy 10CFR50 Appendix R requirements is an event of remote probability. The system was installed after the plant has been in operation for years. During this time, none of the DSD System design bases events has ever been experienced, such that the 8
safe operation of the plant was placed in jeopardy.
Failure of the MCCBs could render the DSD System inoperable. It is our judgement, however, that there is a very remote probability that the DSD System design bases events would occur during the duration of this JCO. Further more, there is also a very remote probability that any of the three MCCBs would malfunction in the unlikely event that the DSD System would be called upon to perform its function.
MCCB VTR INVTR 3 (296)
This MCCB is of current vintage purchased in 1985 from a supplier who is not on the list of the NRC named suppliers as suspect for supplying refurbished MCCBs.
This would make the MCCB less susceptible to the concerns of this job.
In addition, although the MCCB installed has not been bench-tested, it has undergone functional testing, together with the other devices in the circuit, to verify that the circuitry operated per the design. It is our judgement, however, that Invertor No. 3 will not be lost due to MCCB spurious trips for the duration of A'this JCO. The MCCB has accumulated 39 months of sservice in its present application without spurious trips.
In the unlikely event that the MCCB fails to interrupt a fault or an overload, its upstream feeder circuit breaker, MCCB 72-137, located in 125 VDC Bus No. 1, will isolate the fault.
Losing Invertor No. 3 will not impact the operation of the system. The system has been designed to switch over to a back-up emergency power source. An automatic transfer will provide the emergency back-up power from a 37.5 KVA transformer to the vital buses normally supplied power from Invertor No. 3.
MCCB Y15-1500 (330)
The MCCB installed has been tested to verify it's 300%
overload current trip capability complies with the manufacturer's design characteristics. This MCCB has accumulated 9 months of service in its present application without spurious trips. The overload trip test demonstrates reasonable assurance that the MCCB will function.
Furthermore, because this MCCB was subjected to high test currents for the instantaneous trip, additional 9
assurances were gained as to the MCCBs ability to function. Such high duty tests serve to better reveal potential disrepair inherent to refurbishment.
Electrical failure on the Utility Bus is considered an event of remote probability as compared to disturbances that could occur downstream of any of the branch circuit MCCBs. Therefore, the level of detrimental exposure to unit operation is nil when the low probability of bus failure is factored with the high degree of assurance achieved through the tests performed.
General Comments Additionally, the following comments also apply collectively to the MCCBs addressed:
The MCCBs will remain in service only for the remaining Refuel cycle. These MCCBs are only a few of many trip devices used in Unit 1's Electrical Power Systems. It is unlikely that an event related to the affected circuits would occur for the JCO duration such that it would compromise equipment important to safety.
B.
SAFETY EVALUATION This safety evaluation is provided to determine as to whether the justification for continued operation relative to the use of the subject MCCBs does or does not involve an "unreviewed safety question".
This determination will be based on the response provided for the following questions:
- 1.
Is the probability of occurrence of an accident or malfunction of any equipment important to safety previously evaluated in the UFSAR increased?
Response
No.
Each MCCB has been evaluated for the described conditions as it pertains to the functional requirements specific to its station application.
This evaluation assures that equipment function important to safety is maintained. This assurance is achieved based on MCCB characteristics which have been checked or because appropriate operating restrictions have been imposed where characteristics remain uncertain.
- 2.
Are the consequences of an accident or malfunction of equipment important to safety as evaluated.in the USFAR increased?
10
Response
No.
For the affected circuits which remain in service, the required MCCB protection is maintained. The MCCBs are still assured to function to provide train separation in case of electrical failure as assumed in the fire analysis. Otherwise, the MCCB is restricted or removed from service.
Also, based on their accumulated service life, these MCCBs are assured to be a reliable source of power without spurious trips.
- 3.
Is the possibility of an accident or malfunction of a different type than previously evaluated in the UFSAR created??
Response
No.
The MCCBs are assured to provide the same safety function as analyzed in the UFSAR.
- 4.
Is the margin of safety as defined in the basis for any technical specification reduced?
Response
No.
The condition described in the JCO does not result in changes to equipment characteristics. The margin of safety is not changed.
VII. JCO DURATION and TEMPORARY CONTROLS This JCO applies for the remainder of the Unit 1 Refuel recycle.
Each of the MCCBs addressed in this JCO will be replaced with a MCCB that has been successfully tested to VTP-E-067 or with a MCCB for which traceability has been verified. The exception is MCCB Record ID 301, which is still undergoing traceability verification. If this MCCB passes traceability verification, it will not be replaced.
MCCB Record ID 288 will remain open and tagged by NCR Hold Tag with reference to NCR SO1-P-7129 until the aforementioned action is complete.
(II1
480 V SWGR. NO.1 480 V SWGR. NO.3 480 VSWGR. N02 110101la1314 1218 m
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UNIT 2 EVALUATION JUSTIFYING CONTINUED OPERATION (JCO) 0REV.
1 TABLE OF CONTENTS I.
INTRODUCTION II.
REFERENCES III. EXISTING CONDITION A.
BACKGROUND B.
EVENT and/or CONDITION IV. SCOPE OF MCCBs EVALUATION V.
DESIGN REQUIREMENTS and VERIFICATION ACTIVITIES A.'
STATION APPLICATION and FUNCTION B:{:PRESERVICE TEST and INSPECTIONS VI.
JUSTIFICATION FOR CONTINUED OPERATION A.
JUSTIFICATION B.
SAFETY EVALUATION VII. JCO DURATION and TEMPORARY CONTROLS EXHIBIT 1 SIMPLIFIED ONE LINE DIAGRAM 0II
I.
INTRODUCTION This JCO is provided to address continued operation as a result of completing traceability investigations for twelve of the Molded Case Circuit Breakers (MCCB) identified in NCR 2653 for SONGS Unit 2. These investigations are summarized in SCE QA Report MCCB -26,-27 and -28.
This JCO is provided as specified in the NCR Disposition under Block 21, Item II.C, which states that within 30 days of completing traceability investigation, perform an evaluation justifying continued operation based on the use of the existing MCCBs.
II.
REFERENCES Procedures Test Procedure, S0123-I-4.7, Molded Case Circuit Breakers Test Procedure, S0123-GT-400-07 Generic Test Procedure for Molded Case Circuit Breakers Test-Procedure, S023-302-4-1-785-0 Westinghouse Molded Case Circuit Breakers Verification Test Procedure, VTP-E-067, Molded Case Circuit Breaker Verification Test Program Drawings
- 90042, Unit 2/3 Safety Related Electrical Set Point List (ESL), QCII, REV. 0.
90035AE, Appendix R Fire Analysis Coordination Calculation Equipment specifications Purchase Specification S023-302-04, Motor Control Centers S023-302-05A, 125 VDC Distribution Switchboard S023-302-05B, 250 VDC and 125 VDC Distribution Switchboard Purchase Specification, DC Power Bus Breaker standards UL-489, Molded Case Circuit Breaker and Circuit Breaker Enclosures NEMA-AB1, Molded Case Circuit Breakers 1
III. EXISTING CONDITION A. BACKGROUND
- 1.
On July 8,
- 1988, the Nuclear Regulatory Commission (NRC) issued Information Notice 88-46, to alert licensees that refurbished MCCBs may have been supplied to nuclear power plants.
NRC Notice 88-46 stated that Pacific Gas and Electric had purchased MCCBs intended for non-safety related applications from a local distributor who in turn purchased the MCCBs from another supplier for drop shipment.
Square D questioned the delivery and requested an inspection.
Their findings indicated that the breakers showed signs of reassembly and relabeling.
Square D reported that the breakers did not comply with manufacturing specifications.
In two supplements to NRC Notice 88-46, the NRC named 14 suppliers as suspects for supplying refurbished MCCBs.
Based on NRC Notice 88-46, SCE commenced a set of actions to identify and mitigate the supply of suspect MCCBs for station use.
NRC Bulletin 88-10 The NRC issued Bulletin 88-10 on November 22, 1988, to request the addressees to provide reasonable assurances that MCCBs purchased for use in safety related applications without verifiable traceability perform their safety function.
The NRCs expressed concern is that MCCBs purchased as new may not conform to manufacturer's specifications.
Unauthorized refurbishing could jeopardize design capability and reliability.
MCCBs which cannot be traced to the manufacturer must be addressed for appropriate corrective action.
NEMA and UL have stated that fault protection capabilities are verified by destructive testing of selected breakers representing production under controlled conditions.
In Bulletin 88-10, the NRC prescribed actions, including implementation of a test and replacement program.
The NRC considers these actions as reasonable assurance that MCCBs that cannot be traced will perform their safety function.
NRC Bulletin 88-10 allows for continued use of installed MCCBs that cannot be traced until these actions can be implemented during the appropriate unit refuel. The 2
NRC also requested that a JCO be prepared for MCCBs that cannot be traced for the duration they remain in service.
- 3. SCE and Industry Findings The distribution of refurbished MCCBs has potentially reached significant proportions in the installed population within the nuclear power industry.
The significance of these proportions warrants appropriate investigation and corrective action.
SCE specifications for power distribution panels and motor control center require that the vendor furnish evidence that endurance test, in accordance with NEMA AB-1-1969, have been completed on breakers of the same design.
MCCBs which are supplied outside the manufacturing controls or jurisdiction intended by these specifications, represent a potential deviation from equipment design and performance requirements.
B. EVENT AND/OR CONDITION
!The event described in NRC Notice 88-46 and NRC Bulletin
,88-10 does not identify a specific nonconforming condition
.present in SONGS operating equipment.
However, the generic concerns described do represent real and likely conditions which potentially could occur.
This JCO considers the known procurement chain, testing and inspection, and station applications.
IV. SCOPE OF MCCBs EVALUATED FOR CONTINUED OPERATION The MCCBs which are addressed by this JCO are identified in NCR S02-2-2653 for SONGS Unit 2. These MCCBs were purchased and installed during the interval August 1,
- 1983, through August 1, 1988, as specified in NRC Bulletin 88-10.
The investigation to establish traceability for these MCCBs have been completed and have shown that these MCCBs represent the installed population which cannot be traced to the circuit breaker manufacturer.
3
MCCBs REFERENCED IN NCR S02-2-2653 WHICH PERTAIN TO THIS JCO NCR MO BREAKER SERVICE MNFR MODEL AMP ID ID 285 85050079000 CB3-E AUX FDW S/G EO-ITE EF2A 30 88, ISO VALVE 2HV4730 281 85022411000 2Q023 09 Spare SQD QOB1 20 291 85022411000 0Q033 29 Spare SQD QOB1 20 303 86042591000 2Q04114 Spare SQD QOB1 20 2Q04120 Spare SQD QOB1 20 2Q04122 Spare SQD QOB1 20 312 86061241000 2D106 Spare GE THJK 400 2D206 Spare GE THJK 400 277 84081468000 2Q020 20 Spare SQD QOB1 20 2Q020 23 Spare SQD QOBI 20 289 85081017000 2Q020 01 Spare SQD QOB1 20 2Q020 24 Spare SQD QOB1 20 The.MCCB for Record ID 285 was supplied from BBC Brown Boveri The MCCB for Record ID 277 was supplied from Amfac Electrical Supply Company The MCCB for Record ID 281 was supplied from Amfac Electrical Supply Company.
The MCCBo r Record ID 289 was supplied from Amfac Elecrical Supply Company.'.
The MCCB for Record ID 291 was supplied from Anfac Electrical Supply Company.
The MCCB for Record ID 303 was supplied from Amfac Electrical Supply Company.
The MCCB for Record ID 312 was supplied from General Electric Supply Company.
V.
DESIGN REQUIREMENTS AND VERIFICATION ACTIVITIES A.
STATION APPLICATION AND FUNCTION A
description of each MCCB application and their respective station application are provided as follows:
NOTE:
Each MCCB listed is identified by Breaker ID in the Electrical Set Point List (ESL),except for CB3-E which is in a relay panel.
Circuit breakers which are credited to provide isolation in an Appendix R scenario have been analyzed in station coordination
- study, 90035AE, for fire protection and safe shutdown 4
requirements.
MCCB CB3-E (285)
MCCB CB3-E is located in
- 2MS4705, the Auxiliary Relay Panel for Steam Generator E088 Auxiliary Feedwater Pump P-140 Discharge Control Valve 2HV-4705 and Auxiliary Feedwater Isolation Valve 2HV-4730.
125 VDC control and motive power comes from feeder breaker 2D105 in the 125 VDC Distribution switchboard Bus 2D1 for the Auxiliary Relay Panel for the control and operation of 2HV-4705 and 2HV-4730.
CB3-E feeds 2HV-4730.
The load function is safety related.
Discharge Control Valve 2HV-4705 and Isolation Valve 2HV 4730 provide controllable discharge flows from Turbine Driven Auxiliary Feedwater Pump P-140 to steam generator 2
(EO88).
Valves 2HV-4705 and 2HV-4730 automatically close on Main Steam Isolation Actuation (MSIS).
An Emergency Feedwater Actuation Signal (EFAS) automatically opens the valves overriding the MSIS received by the valves. Valve 2HV-4705 stays open under this condition.
Auxiliary feedwater flow to the steam generator is controlled by the cycling valve 2HV-4730, which opens and
-closes depending upon the steam generator water level.
e proper operation of valve 2HV-4730 is dependent upon
- jte existence of the 125 VDC power.
Therefore, a-spurious MCCB trip would impact the operation of the valve in the ent auxiliary feedwater is needed.
MCCB 2D106 and 2D206 (312)
MCCBs 2D106 AND 2D206 are in spare position.
They are,
- however, used in reserve for connection of the spare battery charger and other temporary connections in the event that the permanently installed battery chargers feeding 125 VDC power to 125 VDC Distribution Switchboard Buss 2D1 or 2D2, respectively, become inoperable.
The load function is safety related.
MCCB 20023 09 (281)
MCCB 2Q023 09 is in spare position.
The MCCB will be opened and tagged to alleviate further circuit protection concerns.
The controls to ensure that MCCB 2Q023 09 remains out of service are addressed in Section VI, JCO Duration and Temporary Controls.
MCCB 00033 29 (291) 5
MCCB 0Q033 29 is in spare position.
The MCCB will be opened and tagged to alleviate further circuit protection concerns.
The controls to ensure that MCCB 0Q033 29 remains out of service are addressed in Section VI, JCO Duration and Temporary Controls.
MCCBs 20041-14, 20041-20, 20041-22 (303)
MCCBs 2Q041-14, 2Q041-20, 2Q041-22 are in spare position.
The MCCBs will be opened and tagged to alleviate further circuit protection concerns.
The controls to ensure that MCCBs 2Q041-14, 2Q041-20, 2Q041-22 remain out of service are addressed in Section VI, JCO Duration and Temporary Controls.
MCCBs 20020 01, 20020 20, 20020 23, 20020 24 (277, 289)
MCCBs 2Q020 01, 2Q020 20, 2Q020 23, and 2Q020 24 are in spare position. The MCCBs will be opened and tagged to aleviate further circuit protection concerns.
e controls to ensure that MCCBs 2Q020 01, 2Q020 20, Q020 23 and 2Q020 24 remain out of service are addressed in Section VI, JCO Duration and Temporary Controls.
A simplified Main One Line Diagram illustrating the inter relationship of these MCCBs with the Electrical Power System is attached to this JCO Exhibit 1.
B. PRESERVICE TEST AND INSPECTIONS The MCCBs listed, for Record IDs 285 and 312 were preservice tested prior to installation in accordance with Station Molded Case Circuit Breaker Test Procedures. The MCCBs were tested with the instantaneous settings at mid position for Record ID 285 and at over 75% position for Record ID 312, tripping the breaker as indicated in the acceptance criteria given on the face of the breaker.
The MCCB was also given thermal trip and insulation resistance tests.
The test results are contained in the Maintenance Work Order package referenced in Section IV of this JCO.
These test results demonstrate satisfactory breaker performance within selected ranges of the manufacturer's design characteristics.
The preservice tests performed are not as severe as those 6
prescribed in NRC Bulletin 88-10.
- However, the tests performed did check breaker performance for most anomalies that could potentially be present due to refurbishment.
Any gross disrepair would be detected by the station tests performed.
A review of inspections and test conducted on Stored Spares was made to determine what inferences should apply based on common RSO and model numbers.
There is no similar commonality for the MCCBs listed for Record IDs 285 and 312.
VI. JUSTIFICATION FOR CONTINUED OPERATION A. JUSTIFICATION Based on the existing condition identified in Section III as it relates to the station applications described in Section V, the following justification for continued operation is provided for each MCCB:
MCCB CB3-E (285)
The MCCB installed has been tested to verify its jinstantaneous trip (as set in the mid position) capability 4complies with the manufacturer's design characteristics.
The MCCB passed the manufacturer's acceptance criteria.
14:e instantaneous trip test demonstrates reasonable assurance that the MCCB will function as assumed.
Furthermore, because this MCCB was subjected to high test currents for the instantaneous trip, there is an assurance that the MCCB has the ability to function.
Such high duty tests serve to better reveal potential disrepair inherent to refurbishment.
In the event, however, of a power failure caused by the malfunctioning of the MCCB, resulting in the failure of Auxiliary Feedwater Isolation Valve 2HV-4730 and Auxiliary Feedwater Pump P-140 Discharge Control Valve 2HV-4705 to perform its intended function, the safety of the plant will not be put in jeopardy. Loss of valves 2HV-4730 and 2HV-4705 have been analyzed in the UFSAR (Table 10.4-7, sheet 1 of 3, Auxiliary Feedwater System Failure Mode and Effects Analysis). Results of the FMEA show that loss of 2HV-4730 has no effect on the system due to the redundant series valves ( if the failure mode is failing to close on MSIS or on removal of EFAS) or due to redundant parallel valve(if the failure mode is that the valve fails closed on EFAS).
In addition, the loss of valve 2HV-4705 has no effect on the system due to parallel flow paths from auxiliary feedwater pumps to both steam generators (if the failure 7
mode is that the valve fails to open on EFAS) or due to the closure of pump discharge isolation valves (if the failure mode is that the valve fails to close on MSIS or on removal of EFAS).
It is our judgement, however, that valve 2HV-4730 will not be lost due to MCCB spurious trips for the duration of this JCO. The MCCB has accumulated 48 months service in it's present application without spurious trips.
In the unlikely event that the MCCB fail to interrupt a fault or an overload, its upstream feeder circuit breaker, 2D105, located in the 125 VDC Distibution Switchboard 2D1, will isolate the fault.
Losing the entire 125 VDC Distribution Switchboard Bus 2D1, supplying the 125 VDC power to the Auxilary Relay Panel MS4705, has been analyzed in the UFSAR (Table 8.3 8, Failure Modes and Effects Analysis).
The results of the analysis show that the loss of Bus 2D1 had no effect on the system since the three other 125 VDC channels will remain available.
In any event, adequate assurance of proper breaker
, function is provided by the instantaneous trip test a results.
Therefore, it can be concluded that the valve can be operated with the MCCB without detrimental exposure the plant.
CBs 2D106 and 2D206 (312)
The MCCB installed has been tested to verify its thermal and instantaneous trip (as set in the over 75 percent position) capability complies with the manufacturer's design characteristics.
The MCCB passed the manufacturer's acceptance criteria.
The thermal
& instantaneous trip test demonstrates reasonable assurance that the MCCB will function as assumed. Furthermore, because this MCCB was subjected to high test currents for the instantaneous trip, there is an assurance that the MCCB has the ability to function.
Such high duty tests serve to better reveal potential disrepair inherent to refurbishment.
Adequate assurance of proper breaker function is provided by the instantaneous trip test results. Therefore, it can be concluded that the battery charger can be operated with the MCCB without detrimental exposure to the plant.
Spare MCCBs 2023 09, 00033 29, 2004114, 2004120, 2004122, 20020 01, 20020 20, 20020 23, and 20020 24, (277,
- 281, 289, 291, 303) 8
These spare MCCBs will remain open and tagged in reference to NCR S02-2-2653 for the duration of this JCO.
No further evaluation for continued operation for these MCCBs is required.
General Comments Additionally, the following comments also apply collectively to the MCCBs addressed:
The MCCBs will remain in service only for the remaining Refuel cycle.
These MCCBs are only a few of many trip devices used in Unit 2 's Electrical Power Systems. It is unlikely that an event related to the affected circuits would occur for the JCO duration such that it would compromise equipment important to safety.
B. Safety Evaluation This safety evaluation is provided to determine as to whether the justification for continued operation relative to the use of the subject MCCBs does or does not involve n "unreviewed safety question".
This determination will
- be based on the response provided for the following qestions:
Is the probability of occurrence of an accident or malfunction of any equipment important to safety previously evaluated in the UFSAR increased?
Response
No Each MCCB has been evaluated for the described conditions as it pertains to the functional requirements specific to its station application.
This evaluation assures that equipment function important to safety is maintained. This assurance is achieved based on MCCB characteristics which have been checked or because appropriate operating restrictions have been imposed where characteristics remain uncertain.
- 2. Are the consequences of an accident or malfunction of equipment important to safety as evaluated in the UFSAR increased?
Response
No For the affected circuits which remain in
- service, the required MCCB protection is maintained.
The MCCBs are still assured to function to provide -train 9
separation in case of electrical failure as assumed in the fire analysis.
Otherwise, the MCCB is restricted or removed from service.
Also, based on their accumulated service life, these MCCBs are assured to be a reliable source of power without spurious trips.
- 3. Is the possibility of an accident or malfunction of a different type than previously evaluated in the UFSAR created?
Response
No The MCCBs are assured to provide the same safety function as analyzed in the UFSAR.
- 4. Is the margin of safety as defined in the basis for any technical specification reduced?
Response
No The condition described in the JCO does not result in changes to equipment characteristics. The margin of
-W safety is not changed.
VII. JCO DURATION AND TEMPORARY CONTROLS ThE;1CO applies for the remainder of the Unit 2 Refuel Cycle.
Each of the MCCBs addressed in this JCO will be replaced with a MCCB that has been successfully tested to VTP-E-067 or with a MCCB for which traceability has been verified.
Spare MCCBs 2Q023 09, 0Q033 29,
- 2Q04114, 2Q04120,
- 2Q04122, 2Q020 01, Q020 20, 2Q020 23, and 2Q020 24, will remain open and tagged by NCR HOLD TAG in reference to NCR S02-2-2653 to prevent use.
10
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4730
& 3H12-VD15IST IFE 125 VDCE DIT RA
UNIT 3 EVALUATION JUSTIFYING CONTINUED OPERATION (JCO)
Rev. 1 TABLE OF CONTENTS I.
INTRODUCTION II.
REFERENCES III. EXISTING CONDITION A.
BACKGROUND B.
EVENT and/or CONDITION IV. SCOPE OF MCCBs EVALUATION V.
DESIGN REQUIREMENTS and VERIFICATION ACTIVITIES A.'
STATION APPLICATION and FUNCTION B.
PRESERVICE TEST and INSPECTIONS VI.
JUSTIFICATION FOR CONTINUED OPERATION A.
JUSTIFICATION B.
SAFETY EVALUATION VII. JCO DURATION and TEMPORARY CONTROLS EXHIBIT 1 SIMPLIFIED ONE LINE DIAGRAM
I.
INTRODUCTION This JCO is provided to address continued operation as a result of completing traceability investigations for seven of the Molded Case Circuit Breakers (MCCBs) identified in NCR 3-2364 for SONGS Unit 3. These investigations are summarized in SCE QA Report MCCB -26, -27 and -28.
This JCO is provided as specified in the NCR Disposition under Block 21, Item II.C, which states that within 30 days of completing traceability investigation, perform an evaluation justifying continued operation based on the use of the existing MCCBs.
II.
REFERENCES Procedures Test Procedure, S0123-1-4.7, Molded Case Circuit Breakers Test Procedure, S0123-GT-400-07 Generic Test Procedure for Molded Case Circuit Breakers Test Procedure, S023-302-4-1-785-0 Westinghouse Molded Case Circuit Breakers Verification Test Procedure, VTP-E-067, Molded Case Circuit Breaker Verification Test Program Drawings 90042, Unit 2/3 Safety Related Electrical Set Point List (ESL), QC II, REV. 0.
90035AE, Appendix R Fire Analysis Coordination Calculation Equipment specifications Purchase Specification, S023-302-04, Motor Control Centers S023-302-05A, 125 VDC Distribution Switchboard S023-305-05B, 125 VDC and 125 VDC Distribution Switchboard Purchase Specification, DC Power Bus Breaker standards UL-489, Molded Case Circuit Breaker and Circuit Breaker Enclosures NEMA-AB1, Molded Case Circuit Breakers
I III. EXISTING CONDITION A. BACKGROUND
- 1. On July 8, 1988, the Nuclear Regulatory Commission (NRC) issued Information Notice 88-46, to alert licensees that refurbished MCCBs may have been 4
supplied to nuclear power plants. NRC Notice 88-46 stated that Pacific Gas and Electric had purchased MCCBs intended for non-safety related applications from a local distributor who in turn purchased the MCCBs from another supplier for drop shipment.
Square D questioned the delivery and requested an inspection.
Their findings indicated that the breakers showed signs of reassembly and relabeling.
Square D reported that the breakers did not comply with manufacturing specifications.
In two supplements to NRC Notice 88-46, the NRC named 14 suppliers as suspects for supplying refurbished MCCBs.
Based on NRC Notice 88-46, SCE commenced a set of actions to identify and mitigate the supply of suspect MCCBs for station use.
.2. NRC Bulletin 88-10 The NRC issued Bulletin 88-10 on November 22, 1988, to request the addressees to provide reasonable assurances that MCCBs purchased for use in safety related applications without verifiable traceability perform their safety function.
The NRCs expressed concern is that MCCBs purchased as new may not conform to manufacturer's specifications. Unauthorized refurbishing could jeopardize design capability and reliability. MCCBs which cannot be traced to the manufacturer must be addressed for appropriate corrective action.
NEMA and UL have stated that fault protection capabilities are verified by destructive testing of selected breakers representing production under controlled conditions.
In Bulletin 88-10, the NRC prescribed actions, including implementation of a test-and replacement program. The NRC considers these actions as reasonable assurance that MCCBs that cannot be traced will perform their safety function. NRC Bulletin 88-10 allows for continued use of installed MCCBs that cannot be traced until these actions can be implemented during the appropriate unit refuel.
2
The NRC also requested that a JCO be prepared for MCCBs that cannot be traced for the duration they remain in service.
- 3. SCE and Industry Findings The distribution of refurbished MCCBs has potentially reached significant proportions in the installed population within the nuclear power industry. The significance of these proportions warrants appropriate investigation and corrective action.
SCE specifications for power distribution panels and motor control center require that the vendor furnish evidence that endurance test, in accordance with NEMA AB-1-1969, have been completed on breakers of the same design.
MCCBs which are supplied outside the manufacturing controls or jurisdiction intended by these specifications, represent a potential deviation from equipment design and performance requirements.
B. EVENT AND/OR CONDITION
,The event described in NRC Notice 88-46 and NRC Bulletin 88-10 does not identify a specific nonconforming Condition present in SONGS operating equipment.
.Bowever, the generic concerns described do represent real and likely conditions which potentially could occur. This JCO considers the known procurement chain, testing and inspection, and station applications.
IV. SCOPE OF MCCBs EVALUATED FOR CONTINUED OPERATION The MCCBs which are addressed by this JCO are identified in NCR S03-3-2364 for SONGS Unit 3. These MCCBs were purchased and installed during the interval August 1, 1983, through August 1, 1988, as specified in NRC Bulletin 88-10.
The investigation to establish traceability for these MCCBs have been completed and have shown that these MCCBs represent the installed population which cannot be traced to the circuit breaker manufacturer.
3
MCCBs REFERENCED IN NCR 503-3-2364 WHICH PERTAIN TO THIS JCO NCR MO BREAKER SERVICE MNFR MODEL AMP ID ID 280 85012661000 3Q039 26 Sample Detect-SQ D QOB1 30 ion Skid 283 8504021000 0Q033 30 Spare SQ D QOB1 20 294 85121814000 3Q020 03 Spare SQ D QOB1 20 312 86061241000 3D106 Spare GE THJK 400 3D206 Spare GE THJK 400 318 86090374001 CB2-D AUX FDW S/G EO-ITE EF2A 5
89, P-140 DISCH.
CONTROL VLV.
3HV-4706 329 88061364000 3D306 Spare GE THJK 400 The MCCB for Record ID 280 was supplied from Orange Coast Electrical Company.
The MCCB for Record ID 283 was supplied from Amfac Electrical Supply Company.
The MCC, for Record ID 294 was supplied from Amfac Electrical Supply Capany.
The MCCBs for Record ID 312 was supplied from General Electric Supply Company.
The MCCB for Record ID 318 was supplied from Consolidated Electric.
The MCCB for Record ID 329 was supplied form GE Nuclear Division V.
DESIGN REQUIREMENTS AND VERIFICATION ACTIVITIES A.
STATION APPLICATION AND FUNCTION A description of each MCCB application and their respective station application are provided as follows:
NOTE:
Each MCCB listed is identified by Breaker ID in the Electrical Set Point List (ESL), except for CB2-D which is in a relay panel. Circuit breakers which are credited to provide isolation in an Appendix R scenario have been analyzed in station coordination study, 90035AE, for fire protection and safe shutdown requirements.
4
MCCB 30039 26 (280)
MCCB 3Q039 26 feeds 120 VAC power to the Sample Detection Skid located in the penetration building, from the 208/120 VAC heater panel 3Q039. The load function is not safety related. The Sample Detection Skid consists of the High Purity Germanium Detector System designed to supplement the Post Accident Sampling System (PASS).
The Sample Detection Skid provides the operator with the capability to remotely monitor and quantify the activity concentrations of gamma emitting isotopes in the Reactor Coolant and the Containment atmospheres during and after postulated accidents.
Because of this capability, the system significantly reduces operating personnel occupational radiation exposures. The need to manually draw and transport high activity chemistry samples for radioanalysis is virtually eliminated.
This circuit is upstream protected by the main feeder MCCB to heater panel 3Q039.
spurious MCCB trip would therefore impact the operation of the Sample Detection Skid.
CCB CB2-0 (318)
MCCB CB2-D is located in 3MS4706, the Auxiliary Relay Panel for Steam Generator E089 Auxiliary Feedwater Pump P-140 Discharge Control Valve 3HV-4706 and Auxiliary Feedwater Isolation Valve 3HV-4715.
125 VDC control and motive power comes from the feeder breaker 3D205 in the 125 VDC Distribution Switchboard Bus 3D2 to the Auxiliary Relay Panel for the control and operation of 3HV-4706 and 3HV-4715. CB2-D feeds 3HV 4706. The load function is safety related.
Discharge Control Valve 3HV-4706 and Isolation Valve 3HV-4715 provide controllable discharge flows from Turbine Driven Auxiliary Feedwater Pump P-140 to Steam Generator 1 (E089).
Valves 3HV-4706 and 3HV-4715 automatically close on Main Steam Isolation Actuation (MSIS).
An Emergency Feedwater Actuation Signal (EFAS) automatically opens the valves overriding the MSIS received by the valves. Valve 3HV-4706 stays open under this condition. Auxiliary feedwater flow to the steam generator is controlled by the cycling valve 3HV-4715, which opens and closes depending upon the Steam Generator water level.
5
The proper operation of valve 3HV-4706 is dependent upon the existence of the 125 VDC power. Therefore, a spurious MCCB trip would impact the operation of the valve in the event auxiliary feedwater is needed.
MCCB 3D306 (329)
MCCB 3D306 is in spare position. It is, however, used in reserve-for connection of the spare battey charger and other temporary connections in the event that the permanently installed battery charger feeding 125 VDC power to 125 VDC Distribution Switchboard Bus 3D3 become inoperable. The load function is safety related.
MCCBs 3D106 and 3D206 (312)
MCCBs 3D106 and 3D206 are in spare position. They are, however, used in reserve, for connection of the spare battery charger and other temporary connections in the event that the permanently installed battery chargers feeding 125 VDC power to 125 VDC Distribution Switchboard Bus 3D1 or 3D2, respectively, become inoperable. The load function is safety related.
MCCB 00033 30 (283)
_JjCCB 0Q033 30 is in spare position. The MCCB will be pened and tagged to alleviate further circuit protection concerns.
The controls to ensure that MCCB 0Q033 30 remains out of service are addressed in Section VI, JCO Duration and Temporary Controls.
MCCB 30020 03 (294)
MCCB 3Q020 03 is in spare position. The MCCB will be opened and tagged to alleviate further circuit protection concerns.
The controls to ensure that MCCB 3Q020 03 remains out of service are addressed in Section VI, JCO Duration and Temporary Controls A simplified Main One Line Diagram illustrating the inter relationship of these MCCBs with the Electrical Power System is attached to this JCO Exhibit 1.
6
B. PRESERVICE TEST AND INSPECTIONS The MCCBs listed, for Record IDs 329 and 312 were preservice tested prior to installation in accordance with Station Molded Case Circuit Breaker Test Procedures. The MCCBs were tested with the instantaneous settings at over 75% position tripping the breaker as indicated in the acceptance criteria. MCCBs 3D106, 3D206 and 3D306 were also given thermal trip and insulation resistance tests.
The test results are contained in the Maintenance Work Order package referenced in Section IV of this JCO.
These test results demonstrate satisfactory breaker performance within selected ranges of the manufacturer's design characteristics.
The preservice tests performed are not as severe as those prescribed in NRC Bulletin 88-10.
However, the tests performed did check breaker performance for most anomalies that could potentially be present due to refurbishment. Any gross disrepair would be detected by the station tests performed.
he MCCB listed, for Record IDs 280 and 318 were not ubjected to testing. The MCCBs, however, were not
.&upplied from any of the 14 suppliers who were suspects or supplying refurbished MCCBs.
A review of inspections and tests conducted on stored spares was checked to determine what inferences could apply based on common RSO, material codes or model numbers. There is no similar commonality for the MCCBs listed for Record IDs 280, 312, 318 and 329.
An inspection was conducted by test technician, QC and engineering personnel of the MCCB for Record ID 280. The inspection was limited to the attributes which are visually assessable in the installed configuration.
The MCCB for Record ID 280 shows firm appearance of a factory intact assembly. It is a single pole circuit breaker with rivetted casing and is non-refurbishable.
The MCCB looks new and no signs of tampering was observed.
An inspection was conducted by test technician and engineering personnel of the MCCB for Record ID 318.
The inspection was limited to the attributes which are visually assessable in the installed configuration. The MCCB for Record ID 318 shows firm appearance of a factory intact assembly. The MCCB looks new and no signs of tampering was observed.
7
VI. JUSTIFICATION FOR CONTINUED OPERATION A. JUSTIFICATION Based on the existing condition identified in Section III as it relates to the station applications described in Section V, the following justification for continued operation is provided for each MCCB:
MCCBs 3D106 and 3D206 (312)
The MCCB installed has been tested to verify its thermal and instantaneous trip (as set in the over 75 percent position) capability complies with the manufacturer's design characteristics. The MCCB passed the manufacturer's acceptance criteria.
The thermal and instantaneous trip tests demonstrate reasonable assurance that the MCCB will function as assumed. Furthermore, because this MCCB was subjected to high test currents for the instantaneous trip, there is an assurance that the MCCB has the ability to function. Such high duty tests serve to better reveal
,jpotential disrepair inherent to refurbishment.
Adequate assurance of proper breaker function is provided by the instantaneous trip test results.
erefore, it can be concluded that the battery charger an be operated with the MCCB without detrimental
.exposure to the plant.
MCCB 30039 26 (280)
This MCCB is of a current vintage purchased in 1985 from a supplier who is not on the list of the NRC named suppliers as suspect for supplying refurbished MCCBs and thus less susceptible to the concerns of this JCO.
Also, the inspection results infers an MCCB with nill probability of tampering. Because of its construction, the MCCB would be very difficult to tamper with. This MCCB 3Q039 26 is assumed to function based on the relative absence of suspect indications.
In addition, although MCCB 3Q039 26 has not been tested, it is our judgement that the Sample Detection Skid will not be loss due to MCCB spurious trips, for the duration of this JCO. The MCCB has accumulated 48 months of service in its present application without spurious trips.
In the event that the MCCB fail to interrupt a fault or an overload, its upstream circuit breaker, the main circuit breaker to panel 3Q039, will isolate the fault.
8
Loss of panel 3Q039 has no effect on the system since its redundant load group will remain available.
The loss of the Sample Detection Skid has been analyzed in the UFSAR (Table 9.3-16, Post Accident Sampling System, Failure Modes and Effects Analysis).
The results of the analysis show that the loss of the skid has no effect on the system, since there is no process interaction. In addition, there are several alternative methods of PASS designed into the system if normal sampling techniques become inoperative. The alternative sampling may not be as accurate as the PASS analysis but the information is deemed adequate for emergency estimates.
MCCB CB2-D (318)
This MCCB is of a current vintage procured in 1983 from a supplier who is not on the list of the NRC named suppliers as suspect for supplying refurbished MCCBs.
This would make the MCCB less susceptible to the concerns of this JCO. Inspection results infer an MCCB with nil probability of tampering.
.,In addition, although MCCB CB2-D has not been tested, it a our judgement that the valve will not be lost due to CCB spurious trips, for the duration of this JCO. The MCCB has accumulated 48 months of service in it's present application without spurious trips.
In the event, however, of a power failure caused by the malfunctioning of the MCCB, resulting in the failure of Auxiliary Feedwater Pump P-140 Discharge Control Valve 3HV-4706 and Auxiliary Feedwater Isolation Valve 3HV 4715, to perform its intended functions, the safety of the plant will not be put in jeopardy. Loss of valves 3HV-4706 and 3HV-4715 have been analyzed in the UFSAR (Table 10.4-7, sheet 1 of 3, Auxiliary Feedwater System Failure Modes and Effects Analysis).
Results of the FMEA show that loss of 3HV-4706 has no effect on the system due to the parallel flow paths from the auxiliary feedwater pumps to both steam generators(if the failure mode is that the valve fails to open on EFAS) or due to the closure of the pump discharge isolation valves ( if the failure mode is that the valve fails to close on MSIS or on removal of EFAS).
Also, loss of valve 3HV-4715 has no effect on the system.
due to redundant series valves (if the failure mode is that the valve fails to close on MSIS or on removal of EFAS or due to redundant parallel valve (if the failure mode is that the valve fails closed on EFAS).
9
In the unlikely event that the MCCB fail to interrupt a fault or an overload, its upstream feeder circuit breaker, 3D205, located in the 125 VDC Distibution Switchboard 3D2, will isolate the fault.
Losing the entire 125 VDC Distribution Switchboard Bus 3D2, supplying the 125 VDC power to the Auxilary Relay panel MS4705, has been analyzed in the UFSAR (Table 8.3 8, Failure Modes and Effects Analysis).
The results of the analysis show that the loss of Bus 3D2 had no effect on the system since the three other 125 VDC channels will remain available.
MCCB 3D306 (329)
The MCCB installed has been tested to verify its thermal and instantaneous trip (as set in the over 75 percent position) capability complies with the manufacturer's design characteristics. The MCCB passed the manufacturer's acceptance criteria.
The-thermal and instantaneous trip test demonstrates reasonable assurance that the MCCB will function as, assumed. Furthermore, because this MCCB was subjected o high test currents for the instantaneous trip, there s an assurance that the MCCB has the ability to function.
Such high duty tests serve to better reveal otential disrepair inherent to refurbishment.
Adequate assurance of proper breaker function is provided by the instantaneous trip test results.
Therefore, it can be concluded that the battery charger can be operated with the MCCB without detrimental exposure to the plant.
Spare MCCBs 00033 30, and 300020 03 (283, 294)
These spare MCCBs will remain open and tagged in reference to NCR S03-3-2364 for the duration of this JCO.
No further evaluation for continued operation for these MCCBs is required.
General Comments Additionally, the following comments also apply collectively to the MCCBs addressed:
The MCCBs will remain in service only for the remaining Refuel cycle. These MCCBs are only a few of many trip devices used in Unit 3's Electrical 10
Power Systems. It is unlikely that an event related to the affected circuits would occur for the JCO duration such that it would compromise equipment important to safety.
B.
Safety Evaluation This safety evaluation is provided to determine as to whether the justification for continued operation relative to the use of the subject MCCBs does or does not involve an "unreviewed safety question". This determination will be based on the response provided for the following questions:
- 1. Is the probability of occurrence of an accident or malfunction of any equipment important to safety previously evaluated in the UFSAR increased?
Response
No Each MCCB has been evaluated for the described conditions as it pertains to the functional requirements specific to its station application.
This evaluation assures that equipment function important to safety is maintained. This assurance is achieved based on MCCB characteristics which have been checked or because appropriate operating restrictions have been imposed where characteristics remain uncertain.
Are the consequences of an accident or malfunction of equipment important to safety as evaluated in the UFSAR increased?
Response
No For the affected circuits which remain in service, the required MCCB protection is maintained. The MCCBs are still assured to function to provide train separation in case of electrical failure as assumed in the fire analysis. Otherwise, the MCCB is restricted or removed from service.
Also, based on their accumulated service life, these MCCBs are assured to be a reliable source of power without spurious trips.
- 3. Is the possibility of an accident or malfunction of a different type than previously evaluated in the UFSAR created?
Response
No The MCCBs are assured to provide the same safety function as analyzed in the UFSAR.
11
- 4. Is the margin of safety as defined in the basis for any technical specification reduced?
Response
No The condition described in the JCO does not result in changes to equipment characteristics. The margin of safety is not changed.
VII. JCO DURATION AND TEMPORARY CONTROLS This JCO applies for the remainder of the Unit 3 Refuel Cycle.
Each of the MCCBs addressed in this JCO will be replaced with a MCCB that has been successfully tested to VTP-E-067 or with a MCCB for which traceability has been verified.
Spare MCCBs 0Q033 30, and 3QO20 03, will remain open and tagged by NCR Hold Tag in reference to NCR S03-3-2364 for the duration of this JCO.
12
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FOR 2HV - 4705 HV4706 FOR 3HV - 4706 EXHIBIT 1
& 2HV - 4730
& 3HV - 4715 SIMPLIFIED ONE LINE DIAGRAM