ML18054A816
| ML18054A816 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/28/1989 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, TAC-71330, NUDOCS 8907030271 | |
| Download: ML18054A816 (3) | |
Text
General Offices:
1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 June 28, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RELIEF REQUEST FOR REQUESTED ACTIONS 4 AND 5-0F NRC BULLETIN 88-10 (TAC NO 71330)
Kenneth W Berry Director Nuclear Licensing Consumers Power Company letter dated March 22, 1989 submitted our response to NRC Bulletin 88-10.
This submittal identified one (1) of 132 in stock molded-case circuit breakers that was determined to not be sufficiently traceable to the circuit breaker manufacturer.
In accor.dance with NRC' s February 17, 1989 clarification letter to NUMARC, this breaker is to be considered failed within the context of Action Item 3 of the Bulletin and Action Items 4 and 5 are to be implemented.
The clarification letter also indicates the NRC staff will consider the circumstances of individual utilities with a very small number of non-traceable molded-case circuit breakers on a case by case basis and may grant relief from the implementation of Action Items 4 and 5.
For the reasons stated herein, Consumers Power Company requests relief from the implementation of Action Items 4 and 5 of NRC Bulletin 88-10.
When the NRC Bulletin was received, 132 molded-case circuit breakers (MCCB's) in warehouse stock for safety-related usage were identified.
There were 26 different models from five manufacturers, obtained on 16 different purchase orders from 1977 to 1988.
These breakers are as follows:
Westinghouse 114 MCCB's 19 models 8 POs (1977-1988)
AMF 6 MCCB's 1 model 2 POs (1981, 1985)
ITE 6 MCCB's 3 models 3 POs (1979' 1986)
GE 4 MCCB's 2 models 2 POs (1983)
Square D 2 MCCB's 1 model 1 PO (1983) 132 MCCB's 26 models T6 POs Comprehensive traceability investigations were completed covering all aspects of three areas.
The investigations included 1) order placements through all distributors, suppliers and manufacturers; 2) physical shipments and receipts from manufacturing facilities, through all distributors, distribution OC0689-0145-NL04 JO(
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Nuclear Regulatory Commission Palisades Plant Relief Request - Bulletin 88-10 June 28, 1989 warehouses and suppliers to Palisades; and 3) the sources of certification and their routing to Palisades.
The information from all three areas was thoroug6ly cross-checked against other available data (e.g. codes on breakers and boxes, breaker and packaging markings, warehouse and receipt inspection records).
After all information was determined to be consistent, the trace-ability was considered sufficiently verified.
This included establishment of procurement process integrity and a determination that a MCCB did not have an opportunity to be used elsewhere and reenter the supply stream.
Personnel from manufacturing facilities, distribution and modification centers, quality assurance organizations, suppliers, distributors, etc. assisted in reviewing manufacturing and distribution records at their location(s) and either provided further assistance or confirmed information.
The one MCCB which was formally declared non-traceable is an ITE, Gould, 2 pole, EQ, 20 amp breaker.
The following is known about this breaker:
Ordered from Gould, Inc. Electrical Systems Group of Southfield, Michigan by Palisades on purchase order 12182-Q of April 18, 1979 and received on October 14, 1979.
It has remained in storage at Palisades since.
Manufactured in Wilmington~ North Carolina by Gould, Inc., Circuit Production Division.
Shipped to Palisades from Trenton, New Jersey, by Gould, Inc.
Industrial Battery Division of Langhorne, Pennsylvania.
Inspected and considered to be genuine by an ITE representative who was present at the NUMARC Workshop in Rockville, Maryland on April 10, 1989.
Passed the examination to NUMARC criteria provided by NUMARC/ITE.
Although the MCCB appears to be genuine and unused, our investigation, which has used a conservative approach throughout, does not consider this MCCB traceable.
The lack of a date code precludes verification of the starting point and confirmation of movements from the date of manufacture until shipment from Trenton.
In accordance with the NUMARC/NRC clarification of the Bulletin, Palisades is requesting relief because:
Our investigations, in general, yielded very positive results for 131 of 132 breakers.
Much is known about the MCCB determined to be non-traceable. It appears to be genuine and unused, therefore, it does not indicate a breakdown of the Palisades procurement process or quality assurance program.
OC0689-0145-NL04 2
Nucl'ear Regulatory Commission Palisades Plant Relief Request - Bulletin 88-10 Jun.e 28, 1989 The breaker is not obsolete.
Replacements can be obtained if needed.
NUMA.RC recommended in their letter of March 9, 1989 that non-traceable breakers be removed from stock rather than be tested.
The questionable MCCB has been pulled from stock for future evaluations; NRC investigations, or testing.
We feel the ~eviews required by the Bulletin have been performed completely and timely, and relief from implementation of Action Items 4 and 5 of the Bulletin is appropriate.
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Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point OC0689-0145-NL04 3