ML17305A479

Forwards Final Response to NRC Bulletin 88-010 & Suppl 1, Nonconforming Molded-Case Circuit Breakers. High Percentage of Acceptable Circuit Breakers Stored at Facility Warehouse Reflects High Confidence Factor in Procurement

ML17305A479
Person / Time
Site:	Palo Verde
Issue date:	12/27/1989
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
161-02724-WFC-J, 161-2724-WFC-J, IEB-88-010, IEB-88-10, NUDOCS 9001190405
Download: ML17305A479 (26)

Text

gCCE~RATED DRKBUTION DEMO4S1%TION SYSTEM REGUIATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9001190405 DOC.DATE: 89/12/27 NOTARIZED: YES DOCKET I FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION CONWAYPW.F. Arizona Public Service Co. (formerly Arizona Nuclear Power RECZP.NAME RECIPIENT AFFILIATION

, Document Control Branch (Document Control Desk)

SUBJECT:

Forwards final response to NRC Bulletin 88-010 a Suppl 1, "Nonconforming Molded-Case Circuit Breakers."

DISTRIBUTION CODE: IE21D COPIES RECEIVED:LTR g ENCL /

TITLE: Bulletin Response 88-10 Nonconforming Molded Case Circuit SIZE:

Breakers.

NOTES: 05000528 Standardized plant. 05000529 g Standardized plant. 05000530 RECIPIENT COPIES RECIPIENT COP1ES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 1 1 CHANPT 1 1 DAVIS,M. 1 1 PETERSONPS. 1 1 INTERNAL: AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 NRR DOEA/GCB 11 1 1 NRR GILLPA.S. 1 1 NRR GUILLENgJ 1 1 NRR POTAPOUSPU 1 1 NRR STONE,J.C. 1 1 NRR/DET/EMEB9H3 1 1 NRR/DOEA/OEAB11 1 1 NRR/DOEA/OGCB11 1 1 NRR/DREP/PEPB9D 1 1 NRR/DST 8E2 1 1 ILRB12 1 1 .NUDOCS-ABSTRACT 1 1

- 6 FILE 02 1 1 RES/DSIR/EIB 1 1 RGN5 LE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSZC 1 1 NOTES: 1 1 D

NAZE Zl3 ALL 'RIES" RECIPIENTS:

PLEASE HELP US IO KKQCB HASTE! CORIACT THE DOCUMEÃZ CXKZROL DESK, RGB Pl-37 (EXT. 20079) KO ELXHXKQR YOOR MME HKH DISTBZBUTZCII LISTS FOR DCCUMEHIS KXJ DGHPT NEEDf TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 25

Arizona Public Service Company P.O. 8OX 53999 ~ PHOENIX. ARIZONA 85072-3999 WILLIAMF. CONWAY 161-02724-WFC/JMQ EXECUTIVEVICE PRESIDENT NUCLEAR December 27, 1989 Docket Nos. STN 50-528/529/530 Document Control Desk U. S. Nuclear Regulatory Commission Mail Station Pl-37 Washington, D. C. 20555

References:

(1) Letter from NRC to all Holders of Operating Licenses or Construction Permits for Nuclear Power Reactors dated November 22, 1988.

Subject:

NRC Bulletin 88-10, "Nonconforming Molded-Case Circuit Breakers (2) Letter from D. B. Karner, APS, (161-01808), to NRC dated March 30, 1989.

Subject:

Response to NRC Bulletin 88-10, "Nonconforming Molded-Case Circuit Breakers (3) Letter from NRC to NUMARC dated February 17, 1989.

Subject:

NRC Comments on NUMARC's Draft Clarification of NRC Bulletin 88-10 (4) Letter from NRC to all Holders of Operating Licenses or Construction Permits for Nuclear Power Reactors dated August 3, 1989.

Subject:

NRC Bulletin 88-10, "Supplement 1 Nonconforming Molded-Case Circuit Breakers"

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Response to NRC Bulletin 88-10 and Supplement 1, Nonconforming Molded Case Circuit Breakers File: 89-056-026 Attached is the PVNGS final response to NRC Bulletin 88-10.

If you have any questions on this matter, please call Mr. A. C. Rogers of my staff at (602) 340-4041.

Sincerely, 9001190405 S91227 PDR ADOCK 05000528 8 PNU

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Document Control Desk 161-02724-WFC/JMQ U. S. Nuclear Regulatory Commission December 27, 1989 Page 2 WFC/JMQ/jle Attachment CC'. B. Martin (all w/attachment)

M. J. Davis T. L. Chan T J Polich

~ 0 G. W. Knighton A. C. Gehr A. H. Gutterman

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161-02724-WFC/JMg December 27, 1989 STATE OF ARIZONA )

) SS ~

COUNTY OF HARICOPA )

I, Vi. F. Conway, represent that I am Executive Vice President Nuclear, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true and correct.

W. F Conwa Sworn to before me this day of IQ~ ~,<~ iaaf, 1989.

Notary Public Hy Commission Expires:

Mf CQwMgg QPjgg Jggg 5 1ggy

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Res onse to NRC Bulletin 88-10 and Su lement 1:

Nonconformin Molded-Case Circuit Breakers The following summarizes the actions taken by APS for each of the Bulletin's "Actions Requested," Item Nos. (AI) 1 thru 8 of Bulletin 88-10.

1-Per this requested action item, the Molded Case Circuit Breakers (MCCBs) stored in the PVNGS warehouse, classified for use or potential use in safety related applications, were identified. The total number of CBs identified was 1309, thus exceeding the required minimum sample of 50 CBs. As a result, no installed CBs were required to be removed from the plant safety related systems to form the 50 CB minimum required sample. The traceability and/or acceptance status, as defined within the context of the Bulletin, was verified for 1240 CBs of the 1309 CBs identified. Of the 1240 CBs, 159 were received prior to August, 1983. This effort resulted in the traceability/acceptance of 94.73% of the CB (i.e., 1240) and the rejection of 5.27% of the CBs (i.e., 69).

Attachment 1 includes a complete listing of the non-traceable CBs with all the associated information (i.e., manufacturer, model number and the procurement chain when available).

2-This requested action item is considered not applicable to PVNGS since no installed CBs were recovered per AI 1. In addition, a justification for continued operation will not be required for the case of the non-traceable CB described in the response to AI 5 below.

'This CB was discovered during the current Unit 1 outage and will be removed prior to the start-up of the Unit 1.

3-Based on the 80% or more CB traceability to the Circuit Breaker Manufacturer (CBM),

this action item requires testing of the non-traceable CBs per the test criteria as set forth in the Bulletin. Per Reference 3 (paragraphs 4 and 5), the NRC intent for the testing of non-traceable CBs is to demonstrate the proper operability of these CBs in the case where proper replacements are not readily available. It is stated, however, that "The Staff will not require utilities to test stored non-traceable MCCBs but will require, in lieu of testing, all non-traceable breakers be considered failed within the context of the Bulletin." As a result, APS has opted not to perform any testing on the non-traceable CBs identified in the response to AI 1, but rather to remove the identified non-traceable CBs from PVNGS warehouse stock. In addition, per the stated NUMARC recommendation, APS will also quarantine the non-traceable CBs for the requested one year period.

4-This requested action item requires that if more than 10% of the non-traceable CBs fail the proposed Bulletin's tests, all molded-case CBs purchased between August 1, 1983 and August 1, 1988, be identified, traceability verified and all associated information identified (i.e., model number, manufacturer, installation application and procurement chain). In lieu of testing, PVNGS has considered that all non-traceable CBs failed the Bulletin's required tests.

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I In response to this item, reference is again being made to the Staff's clarifications of Bulletin 88-10 (Reference 3). Per paragraph 4, "...Given the existing language of Bulletin 88-10, this requires utilities with even a small percentage of non-traceable breakers to proceed with AIs 4 and 5. The Staff will, on a case by case basis only, consider the circumstances of individual utilities with a very small number of non-traceable MCCBs.

Provided all non-traceable MCCBs can be accounted for and the circumstances contributing to the non-traceable stock do not suggest repeatable programmatic breakdowns of the utility procurement practices, the staff may relieve utilities from AI's 4 and 5 and instead requires only the removal from stock of the non-traceable MCCBs...."

Based on the above provision, APS has met the intent of this action item, based on the following justification and other actions taken in support of Bulletin 88-10 and Supplement 1:

a) The high percentage of traceable/acceptable CBs (i.e., 95%) stored in for safety related (SR) service totaling 1240 CBs, reflects a very high PVNGS'arehouse, confidence factor in the procurement, storage and application programs of safety related (SR) CBs at PVNGS.

b) APS assessed and accounted for the installed CBs, that were procured under non-traceable purchase orders, identified as a result of the PVNGS warehouse inspections (see AI 5).

c) The 5% (69) non-traceable CBs are divided into two categories; MRS (Material Returned to Stores) rejects (21 CBs) and supplier rejects (48 CBs).

The MRS CBs were returned to the warehouse stock, after being tested for acceptability per PVNGS test procedures, either from PVNGS original plant equipment or after being released from the warehouse for the plant's use.

Documentation relating the MRS CBs to a particular purchase order does not exist, thus deeming these CBs as non-traceable per the guidelines of Bulletin 88-10.

Forty two of the non-traceable CBs from the supplier rejects category were procured from three of PVNGS'ajor equipment suppliers of safety related equipment:

Combustion Engineering (CE, the NSSS supplier), Cooper (Safety Related Diesel Generator supplier) and Elgar (Inverter supplier). All of the non-traceable CBs were procured as class IE SR from an approved PVNGS vendor and with a certificate of compliance. The other six CBs that belong to the supplier rejects category were procured from a local distributor (J. E. Redmond) thru a regional distributor (MAG-TROL). Although both vendors produced traceability and procurement records for only selling new and factory originated CBs, their records were not kept for more than Gve years. Due to the procurement date of the six CBs (August, 1983) these CBs were deemed non-traceable, since no traceability documentation was found.

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The described circumstances and non-traceability cases definitely do not suggest repeatable programmatic breakdowns of PVNGS procurement practices. As stated earlier and during the performance of AI 1, it was clearly identified that a great majority of the CBs were traceable to the CBM.

d) As indicated in Reference 2, during the five years covering August 1, 1983, through August 1, 1988, there were only four Engineering Change Evaluations (ECEs) for commercial grade dedication of molded-case circuit breakers. In all of the four identified cases the molded-case CBs were traced back to the CBM. There was another commercial grade dedication case, however, that identified non-automatic type CBs, classified as molded-case switches which did not contain any overcurrent trip mechanisms. These switches were determined to be non-traceable and, although were not considered to be within the scope of the Bulletin, were addressed immediately upon discovery and replaced in all PVNGS'nits per PNVGS internal procedures, regulatory and reportability requirements.

5-This requested action requires the replacement of all non-traceable molded-case CBs installed in safety related systems with CBs that meet the traceability criteria of Bulletin 88-10. As a result of this action item, PVNGS has identified only two cases of non-traceable molded-case CBs, resultant from the warehouse inspections. In one case, two CBs, although classified for safety related applications, were issued for use in a non-safety related application as part of a PVNGS temporary modification. In the second case, two CBs were issued for use in a safety related application in Unit 1. As a result, a PVNGS work order has been issued to replace the installed CB during the current PVNGS Unit 1 outage. All the other non-traceable molded-case CBs, part of the purchase orders listed in Attachment 1, are accounted for and currently quarantined in the PVNGS warehouse, as previously indicated in the response to AI 1 above. This response also meets the NRC position "4" requirements of Bulletin 88-10, Supple-ment 1.

6-This requested action requires the documentation and maintenance of the generated information while performing the required actions for Bulletin 88-10 for a period of five years, As requested, PVNGS will be maintaining all the generated documentation in an auditable form.

7-This requested action requires that molded-case CBs installed after August 1, 1988, be procured and dedicated per the Bulletin's stated criteria. As a result of this requested action, PNVGS procurement and dedication practices for molded-case CBs are being revised to meet or exceed the criteria delineated in Bulletin 88-10 (delineated in Section 4 of the attached report). In addition, per the response to AI 5 above, non-traceable molded-case CBs were identified and replaced.

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8-This requested action item is for addressees who cannot meet the schedule for responding to the Bulletin by April 1, 1989, to provide and justify to the NRC their proposed alternative schedule. As a result, per Reference 2, APS requested an extension for submitting the final Bulletin's response by December 31, 1989.

Based on the above actions taken, the intent and requirements of NRC Bulletin 88-10 and Supplement 1 have been met. Per Bulletin 88-10 and Supplement 1 reporting requirements, APS confirms that only molded-case CBs that meet the requirements of AI 7 above, are being maintained as stored spares for future use in safety related applications.

In addition, the information pertaining to the non-traceable CBs is being provided as part of the Attachment 1. APS also confirms that items 1 thru 7 of the Bulletin's requested actions have been satisfactorily addressed and/or completed.

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1' ATTACHMENT 1 NRC BULLETIN 88-10 SAFETY RELATED MOLDED CASE CIRCUIT BREAKERS NON-TRACEABLE REJECTION

SUMMARY

Purchase Order/

Glass/ Material ANPP Item Receiving PKG¹ 4441- STY gauss t DESCRIPTION REJECTION BASIS 086 9 5 60117307/ AM2-A3A-10-2 C-E could not provide 861006895 HEINEMANN traceability to the CBM No S/N* (Reference C-E Letter Ext 89-144, dated 09/01/89) 004C 11 1 MRS23709 THED126015 Material returned from GE 15A, 2POLE unit and returned to stock.

S/N N3709000046 Traceability to purchase order could not be esta-blished.

004C 11 1 MRS24548 THED126015 Unable to locate MRS copy.

GE 15A, 2POLE S/N N3709000005 050 11 1 MRS18347 THED126015 Material returned from GE 15A, 2POLE unit and returned to stock.

S/N N4609100004 Traceablity to purchase order could not be esta-blished.

021 14 1 F174639/ AM2-A3A-15-2 C-E could not provide 206948 HEINEMANN traceability to the CBM (For QSPD System) (reference C-E Letter No S/N Ext-89-144, dated 09/01/89) 008 14 1 13NM001A/ AM2-A3A-15-2 C-E could not provide 177470 HEINEMANN traceability to the CBM (for QSPD System) (reference C-E letter No S/N Ext-89-144, dated 09/Ol/89) 077 14 4 60110023/ AM2-A3A-15-2 C-E could not provide 860814432 ,HEINEMANN traceability to the CBM (for QSPD System) (reference C-E letter No S/N Ext-89-144, dated (09/01/89)

• S/N - Serial Number

1 Purchase Order/

Class/ Materia1 ANPP Item Requiring PKG¹ '441- QTY Receuest DESCRIPTION REJECTION BASIS 050 34 2 MRS18347 THED126090 Material returned from GE 90A, 2POLE unit and returned to stock.

S/N's Traceability to purchase N6762390048 order could not be esta-N6762390052 blished.

069 71 4 33700299/ THJK426FOOO Elgar's supplier GESCO 860776212 GE cannot supply traceability No S/N to GE (Reference Elgar letter dated 10/18/89) 067 71 6 33700255/ THJK426FOOO Elgar's supplier GESCO 85047745 GE cannot supply traceability No S/N to GE (Reference Elgar letter dated 10/18/89) 053 123 2 NO PO CD2-A3-DU Breaker stored without HEINEMANN traceability to a PO or 15A, 240VAC MRS.

No S/N 101 123 3 60140015/ CD2-A3-DU C-E could not provide 871201038 HEINEMANN traceability to the CBM No S/N (reference C-E letter Ext-89-144, Dated 09/Ol/89) 013 123 1 F169196/ CD2-A3-DU C-E could not provide 205405 HEINEMANN traceability to the CBM No S/N (Reference C-E letter Ext-89-144, dated 09/Ol/89) 041 140 1 F180818/ 2-01E-028-038 Cooper could not provide 218328 HEINEMANN traceability to the CBM S/N 8612-2 027 141 1 F176575/ TED124070 Source Surveillance (Cooper) 204135 GE 70A, 2POLE - unable to establish S/N 128770 traceability to the CBM.

(Reference letter 028-01814 WPP/MDF) 028 141 1 F176577/ 2-01E-028-030 Source Surveillance (Cooper) 204135 GE 70A, 2POLE unable to establish S/N 128771 traceability to t:he CBM.

(Reference letter 028-01814 WPP/MDF)

• S/N - Serial Number

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Purchase Order Class/ Material/

ANPP Item Requiring PKG¹ 4441- QTY Roue et DESCRIPTION REJECTION BASIS 049 141 1 MRS18315 TED124070 Material returned from unit GE 70A, 2POLE and returned to stock.

No S/N Traceability to purchase order could not be esta-blished.

027 142 1 F176575/ 2-01E-028-026 Source surveillance (Cooper) 208809 HEINEMANN unable to establish 5A, 1POLE traceability to the CBM.

No S/N (Reference letter 028-01814 WPP/MDF) 028 142 1 F176577/ 2-01E-028-026 Source surveillance (Cooper) 205422 HEINEMANN unable to establish 5A, 1POLE traceability to the CBM.

No S/N (Reference letter 028-01814 WPP/MDF) 028 143 1 F176577/ 2-01E-028-017 Source surveillance (Cooper) 204134 HEINEMANN unable to establish 1163A traceability to the CBM.

No S/N (Reference letter 028-01814

- WPP/MDF) 097 143 6 60133325/ 2-01E-028-017 Source surveillance (Cooper) 861018400 HEINEMANN unable to establish 1163A traceability to the CBM.

(Reference letter 028-01814

'o S/N

- WPP/MDF) 027 143 1 F176575/ 2-01E-028-017 Source surveillance (Cooper) 204135 HEINEMANN unable to establish 1163A traceability to the CBM.

No S/N (Reference letter 028-01814 WPP/MDF) 050 240 1 MRS18347 THED113CB020 Material returned from unit GE 20A, 1POLE and returned to stock.

S/N N4651300010 Traceability to purchase order could not be esta-blished.

046 260 1 MRS18303 THED136015N Material returned from unit GE 15A, 1POLE and returned to stock.

S/N N780T280003 Traceability to purchase order could not be esta-blished.

• S/N - Serial Number

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Purchase Order/

Class/ Material ANPP Item Requiring PKG¹ 4441- QTY ~Re eeet DESCRIPTION REJECTION BASIS 100 484 3 60139040/ N852-103-08 Elgar's supplier GESCO 871162288 GE cannot supply traceability No S/N to GE (Reference Elgar letter dated 10/18/89) 054 564 3 33400041/ TEC36015S J. E. Redmond's supplier, 830229361 GE 15A, 3POLE Magtrol unable to provide No S/N traceability to the CBM.

Both suppliers maintain their PO records for a period of 5 years; PO was issued in 1983.=

054 568 3 33400041/ TEC36050S J. E. Redmond's supplier, 830229361 GE 50A, 3POLE Magtrol unable to provide No S/N traceability to the CBM.

Both suppliers maintain their PO records for a period of 5 years; PO was issued in 1983.

051 576 1 MRS23745 THED136050 Material returned from unit GE 50A, 3POLE and returned to stock.

No S/N Traceabili.ty to purchase order could not be esta-blished.

052 576 1 MRS24625 THED136050 Material returned from unit GE 50A, 3POLE and returned to stock.

S/N N890T410007 Traceability to purchase order could not be esta-blished.

046 576 1 MRS18303 THED136050 Material returned from unit GE 50A, 3POLE and returned to stock.

No S/N Traceability to purchase order could not be esta-blished.

048 577 2 MRS18314 THED136070 Material returned from unit GE 70AI 3POLE and returned to stock.

QTY 1 No S/N Traceabili.ty to purchase S/N N1095970010 order could not be esta-blished.

• S/N - Serial Number

t Purchase Order/

Class/ Material ANPP Item Requiring PKG¹ 4441- QTY ~Re eeet DESCRIPTION REJECTION BASIS 006 600 1 13MM018/ 55519 ITEM 9 Source surveillance (Cooper) 191962 WESTINGHOUSE unable to establish EB1015 traceability to the CBM.

No S/N (Reference letter 028-01814 WPP/MDF) 002A 604 2 MRS18311 THFK236070 Unable to locate MRS copy GE 70A, 3POLE No S/N 006 615 1 MRS18303 THED136070N Material returned from unit GE 70A, 3POLE and returned to stock.

S/N N890T410016 Traceability to purchase order could not be esta-blished.

047 616 3 MRS18310 THFK236125 Material returned from unit GE 125A, 3POLE and returned to stock.

Qty 1 No S/N Traceability to purchase order could not be esta-blished.

• S/N - Serial Number

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