ML13331A349
| ML13331A349 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/16/1989 |
| From: | Nandy F SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, NUDOCS 8911210206 | |
| Download: ML13331A349 (10) | |
Text
Southern California Edison Company 23 PARKER STREET IRVINE. CALIFORNIA 92718 F. R. NANDY November 16, 1989 TELEPHONE MANAGER OF NUCLEAR LICENSING (714) 587-5400 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Docket Nos. 50-206, 50-361 and 50-362 Response to NRC Bulletin 88-10, Supplement 1, "Nonconforming Molded Case Circuit Breakers" San Onofre Nuclear Generating Station Units 1, 2 and 3
References:
- 1. M. 0. Medford (SCE) to Document Control Desk (NRC) letter dated March 30, 1989;
Subject:
Response to NRC Bulletin 88-10
- 2. R. M. Rosenblum (SCE) to Document Control Desk (NRC) letter dated September 6, 1989;
Subject:
Supplement Report No. 1 for NRC Bulletin 88-10 This letter provides SCE's response to NRC Bulletin 88-10, Supplement 1, "Nonconforming Molded Case Circuit Breakers" and our report is provided as an enclosure to this letter.
Consistent with the requirements of NRC Bulletin 88-10, Supplement 1, SCE reviewed our original (Reference 1) and supplement response (Reference 2) for NRC Bulletin 88-10 against the additional clarifications provided in the bulletin supplement. SCE's review indicated that our original response is consistent with the additional clarifications provided in Bulletin 88-10, Supplement 1 in all but two areas. These areas are identified as NRC Positions 1 and 5 of.Bulletin 88-10, Supplement 1. SCE has included modifications consistent with NRC Position 5 in the enclosed report. However, due to the time required to conform with NRC Position 1, SCE has not been able tF
Document Control Desk November 16, 1989 to complete these activities by the NRC's due date for NRC Bulletin 88-10, Supplement 1. SCE will complete our efforts for NRC Position 1 by February 1, 1990 and submit an additional MCCB Report supplement to the NRC by March 1, 1990.
SCE's efforts to respond to the bulletin were directed only toward molded case circuit breakers. SCE's response does not include any actions for nonautomated trip devices, (e.g., molded case switches).
SCE has used the criteria contained in Attachment 1 and input from other Licensees to establish the type of device applicable to the bulletin. Any efforts directed toward specific switches or other electrical devices will be completed as part of SCE's investigations necessary to resolve the issues associated with suspect Suppliers equipment as identified in NRC Notice 88-46, Licensee Report of Defective Refurbished Circuit Breakers.
Respectfully submitted, F. R. Nandy Manager of Nuclear Licensing Subscribed and sworn to before me this 16th day of November, 1989 O
OFFICIALT SEAL CAROL A.60/MZ NOTARYPFUSUC-CAUF1ORNl4 LOS AtGELES COUNTY myComrm.
Excirts Feb. 26. 1993 Notary Public in the State of California Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V C. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3
NRC BULLETIN 88-10, SUPPLEMENT 1, RESPONSE REPORT TABLE OF CONTENTS SUBJECT DESCRIPTION PAGE I.
SUBJECT.....................
1 II.
SCOPE.....................
1 III.
REVIEW OF THE ORIGINAL SCE RESPONSE.........
1 IV.
CORRECTIONS TO ORIGINAL RESPONSE REQUIRED..........
5 V.
SCHEDULE FOR COMPLETING CORRECTIONS.............
7
I.
SUBJECT NRC Bulletin 88-10, Supplement 1, Response Nonconforming Molded Case Circuit Breakers II. SCOPE Southern California Edison (SCE) has performed a review of the responses submitted in accordance with NRC Bulletin 88-10, Nonconforming Molded Case Circuit Breakers, for San Onofre Nuclear Generating Station (SONGS) Units 1, 2 and 3. This review was performed as requested by Supplement 1 to the NRC Bulletin. Contained herein is a report based on that review summarizing the findings and the corrections required to the original SCE response.
This report is presented as follows:
Section III:
Review of the Original SCE Response A description of SCE's findings are provided as they pertain to each of the NRC Positions presented in Supplement 1.
Section IV:
Corrections to Original Response Required The corrections required to the original SCE response are identified for each NRC Position for which SCE is not in full compliance.
Section V:
Schedule for Completing Corrections A schedule is provided for each NRC Position for completion of the corrections identified.
III.
REVIEW OF THE ORIGINAL SCE RESPONSE Supplement 1, NRC Position 1:
If MCCBs are traceable to an original plant construction order and the MCCBs were received prior to August, 1983, there is reasonable assurance that the MCCBs are acceptable and no additional traceability is required.
Findings:
SCE's traceability investigation was extended to all spare MCCB's regardless of purchase date. As a result, SCE did not remove MCCB's received prior to August, 1983 or MCCB's purchased for original construction from this traceability effort. The determination of traceability was based on verifiable purchase order documentation only.
2 This effort was documented in Appendix C of SCE's original response to NRC Bulletin 88-10.
Based on the clarification provided in NRC position 1, SCE will update our original response to designate MCCB's received prior to August, 1983 and MCCB's traceable to an original plant construction order as traceable per NRC Bulletin 88-10 requirements.
Supplement 1, NRC Position 2:
Visual inspection and physical examination by the CBMs is not considered adequate to meet the requested traceability provisions of the NRC Bulletin. Although visual inspection and physical examination by the CBM may provide a reasonable basis that the MCCBs have not been opened or altered in a substantial way, there is no reasonable assurance that the MCCBs have not been previously used or subjected to service conditions that may have adversely affected the performance capabilities of the MCCBs.
Findings:
The original SCE response complies with this position. Traceability was established based solely on the QA audit of verifiable documentation.
Examinations performed by CBMs or SCE have not been used by SCE as a basis to meet the NRC Bulletin-requirements for traceability on any MCCB.
SCE performed inspections on each MCCB during the initial inventory and tagging of the spare population. The inspection was used to establish an as-found condition of each stored spare by checking for anomalous markings, missing seals or nameplates, rework indicators and alterations. The inspection has been used by SCE as a requirement for acceptance in addition to the NRC Bulletin requirements for traceability.
The results of these inspections were not applied to the QA traceability investigations.
Supplement 1, NRC Position 3:
Item 4 or the actions requested in the NRC Bulletin applies only to MCCBs which were purchased and installed after August 1, 1983.
Findings:
The original SCE response complies with this position. The SONGS maintenance and construction work order record search performed and reported in response to Item 4 of the NRC Bulletin, applied to MCCBs which were purchased and installed between August 1, 1983, and August 1, 1988.
3 Supplement 1, NRC Position 4:
If an addressee identifies any MCCBs as nontraceable during the review requested by the NRC Bulletin, it should take appropriate corrective actions as required by Criterion XVI of 10 CFR Part 50, Appendix B. As part of these corrective actions, the NRC expects addressees to assess the acceptability of all installed safety related MCCBs that were procured under the same purchase orders as the nontraceable MCCBs.
Findings:
The exercising of appropriate corrective action on other affected MCCBs has been fundamental to SCE's approach to tracing and evaluating spare and installed MCCBs. Criterion XVI of 10 CFR Part 50 Appendix B is integral to SCE policies and procedures concerning SONGS activities and the handling of data. The results from evaluating each individual MCCB have been consistently applied to the assessment of MCCBs from the same procurement sources.within the scope of the NRC Bulletin.
However, SCE did not establish as part of its NRC Bulletin effort a relationship of nontraceable spares to MCCBs installed prior to August 1, 1983.
NRC Position 3 states that the actions requested in Item 4 of the NRC Bulletin apply only to MCCBs which were purchased and installed after August 1, 1983. Therefore, SCE did not collect data on MCCBs installed prior to August 1, 1983.
San Onofre records provide the source of installed items beginning with the maintenance work order. However, San Onofre Warehouse receiving records were not used to provide a path to identify installed MCCB's.
This was due to the volume and complexity (restock, transfers, downgrade, salvage, etc.) of the Warehouse material tracking records when addressing generic processing of MCCB's.
Because Supplement 1 raises our attention on MCCBs installed prior to August 1, 1983, SCE has initiated an assessment of the population of nontraceable spares purchased prior to August 1, 1983, and the potential effect on SONGS Units 1, 2 and 3. SCE will also include in this assessment, MCCBs which were purchased after August 1, 1983, so as to provide uniformity and consistency in the complete account of the entire MCCB population. SCE is performing this assessment in accordance with Station NCR Procedure S0123-XV-5.
Supplement 1, NRC Position 5:
In an effort to limit the number of nonconforming MCCBs in-safety related systems, nontraceable MCCBs that were installed or are being maintained as stored spares as of August 1, 1988, and that successfully pass all tests specified in Attachment 1 of the NRC Bulletin are considered acceptable for use only as replacements for safety related MCCBs that are found to be nontraceable during the review requested by the NRC Bulletin. These MCCBs may not be used as safety related
4 replacements during other activities such as planned plant modifications or routine maintenance.
Findings:
SCE's original response (dated March 30, 1989) to NRC Bulletin 88-10 stated that non-traceable MCCB's that passed the NRC's testing requirements would be maintained as stored spares.
Prior to receipt of NRC Bulletin Supplement, there was no restriction on the use of these MCCB's and they were allowed to be installed as replacements in safety related applications. This practice was consistent with SCE's understanding of NRC requirements of the original Bulletin.
Following receipt of Supplement 1 of NRC Bulletin 88-10 in August, 1989, SCE placed these non-traceable but successfully tested MCCB's back into quarantine to prevent their use in safety-related applications.
Since August 1, 1988, SCE has installed only 1 non-traceable but successfully tested MCCB in a safety related application (at Unit 1) which was installed as a replacement during corrective maintenance.
Use of this MCCB is not within the provisions of NRC Bulletin 88-10 as clarified by Supplement 1. Therefore, SCE will replace this MCCB with a traceable MCCB during the first available outage after a traceable replacement is located.
(Note: Some Unit 1 MCCB's have limited availability due to product obsolescence.)
By letter dated March 16, 1989, SCE informed the NRC of our intentions to replace 5 Westinghouse "E" series MCCB's with non-traceable but successfully tested MCCB's at San Onofre Unit 1. This action was based on SCE's interpretation of requirement 5 of NRC Bulletin 88-10 and the unavailability of traceable Westinghouse "E" series breakers.
Replacement of these MCCB's was required because visual inspections of installed MCCB's during construction activities discovered physical alterations to the external casing of these 5 Vital Bus MCCB's.
After SCE replaced these 5 Vital Bus breakers, Westinghouse identified a potential direct replacement for these older MCCB's which is now available for purchase, pending Westinghouse qualification testing. SCE is evaluating the suitability of these new Westinghouse MCCB's for use in the Unit 1 Vital Bus and will install them if possible. However, if this replacement is not possible, SCE will continue to use the non traceable but successfully tested MCCB's in the Unit 1 Vital Bus.
Supplement 1, NRC Position 6:
For MCCBs stored as spares that were not procured directly from the CBM, each individual MCCB should be reviewed in order to establish proper traceability, regardless of the number of MCCBs.
5 Findings:
The original SCE response complies with this position. At the start of the MCCB project, each spare MCCB was identified, tagged and track to a unique control number. With the exception of the Westinghouse warehouse facility identified below in the findings for NRC Position 7, each MCCB which was determined as acceptable, has been uniquely investigated based on verifiable documentation traceable to the plant of manufacture.
Supplement 1, NRC Position 7:
All safety related MCCBs from the same procurement order are considered traceable provided that 1) the order was procured directly from a CBM having a quality assurance program in accordance with 10 CFR Part 50, Appendix B, 2) the CBM has been audited by the addressee in accordance with'Appendix B, 3) the MCCBs were ordered as safety related, and
- 4) documented evidence has been furnished to the addressee, such as a certificate of compliance. However, if safety related MCCBs were procured from a vendor other than the CBM, a certificate of compliance by itself is not considered an adequate basis for establishing traceability. In such cases, traceability of individual procurement orders should be established through the review of procurement or shipping records back to the CBM. Telephone discussions with the CBM or vendor are not acceptable for establishing a basis for traceability.
Traceability to a warehouse facility controlled by the CBM is considered equivalent to traceability to the CBM.
Findings:
The original SCE response complies with this position. SCE performed a unique traceability investigation for each MCCB by QA audit of verifiable documentation such as procurement and shipping papers and the identifiers contained on the MCCB without regard to purchase order. The one exception to this finding is described in QA Report MCCB-23, dated May 18, 1989, where SCE credits 12 MCCBs as a group based on the controls by Westinghouse WNSD of a Westinghouse warehouse facility in Spartansburg, SC, and the shipping papers presented for each MCCB by WNSD. This exception, however, complies with the NRC position stated.
IV. CORRECTIONS TO ORIGINAL RESPONSE REQUIRED This section states the corrections that apply to the original SCE response based on the findings described in Section III of this report.
Supplement 1, NRC Position 1:
Based on the clarification offered by this NRC position for MCCBs received prior to August, 1983, SCE will designate each MCCB which is traceable to an original construction order as acceptable.
6 Acceptability will include MCCBs in which SCE had previously been unable to establish traceability by QA audit of verifiable documentation.
Additional traceability investigations as performed by SCE QA audit will not be required. SCE will document acceptability in accordance with Station NCR Procedure S0123-XV-5 and report its findings as a supplement to the original SCE response.
Supplement 1, NRC Position 2:
No corrections are required.
Supplement 1, NRC Position 3:
No corrections are required.
Supplement 1, NRC Position 4:
No corrections are required.
All corrective actions needed as a result of the findings made in reference to this NRC position will be performed in accordance with Station NCR Procedure S0123-XV-5. The additional actions to be performed for MCCBs purchased prior to August 1, 1983, will not impact the data provided in the original SCE response. Therefore corrections to the original SCE response are not required. However, because of SCE's intention to also include selected MCCBs which were purchased after August 1, 1983, data in addition to that already supplied as it pertains to Item 4 of the NRC Bulletin, could become available.
Supplement 1, NRC Position 5:
Contrary to the original SCE response, SCE will not maintain nontraceable MCCBs as stored spares, except as noted below. SCE's original plan was to return MCCBs which had been successfully tested to stock. In compliance with the NRC position, SCE will retain nontraceable MCCBs in quarantine.
For station applications which require an obsolete model or instances of corrective maintenance in which SCE has not yet obtained traceable products, SCE will continue to maintain sufficient stored spares utilizing nontraceable MCCBs which have been satisfactory tested.
However, contrary to the original SCE response, access to these MCCBs will be controlled and limited to serve short term measures. For each occurrence of use, the MCCB will be evaluated for operability and resolved for the long term per Station NCR Procedure S0123-XV-5. SCE will ensure that all reasonable courses of action are evaluated before proceeding with the use of a nontraceable MCCB.
7 SCE intends to refrain from the use of all nontraceable MCCBs upon establishing a reliable supply of acceptable replacements.
SCE has launched a major restocking of the MCCB spare inventory to achieve total compliance with the NRC Bulletin and Supplement 1. Our engineers, purchasing agents and expediters are focused on a restock plan for this purpose. Achieving this goal requires much contact with the manufacturers to ensure that the delivered products will meet traceability as well as station design requirements. SCE believes that these measures will limit the number of nonconforming MCCBs in safety related systems.
Supplement 1, NRC Position 6:
No corrections are required.
Supplement 1, NRC Position 7:
No corrections are required.
V.
SCHEDULE FOR COMPLETING CORRECTIONS As a result of the findings presented in this response, corrections required to the original SCE response have been identified for NRC Positions I and 5. The corrections for NRC Position 5 have been included in this response. No further corrections are required to comply with NRC Position 5.
The corrections for NRC Position 1 must be scheduled beyond the submittal date of this response due to the time needed to complete the engineering and warehouse efforts. These corrections will be submitted as an additional supplement to the original SCE response. SCE will submit the additional supplement by March 1, 1990.
That supplement will provide a revised summary of nontraceable stored spares contained in Appendix A of the original SCE response. SCE expects the population of nontraceable MCCBs to be reduced.
SUPP-1WP.CEW2