ML19325C662
| ML19325C662 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/09/1989 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, NUDOCS 8910170153 | |
| Download: ML19325C662 (5) | |
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Stuppingprt, PA 150774004
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October 9, 1989 i
Ui1S. Nuclear' Regulatory Commission e
Attn:
Document Control-Desk '
if Washington, DC' 20555 h
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Reference:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-l' Docket No. 50-334~, L! cense No. DPR-66 BV-2 Docket No.-50-412, License No. i>'F-73 NRC Bulletin 88-10, Supplemer.t 1 Gentlemen:
g Previous. actions to resolve Bulletin 88-10 have-been reviewed
- as.requestedDin Supplement 1.
.The,;following: review of each NRC position is intended to documentTour; understanding of Supplement 1 to IE Bulletin 88-30.
NRC Position 1
-If" - Circuit' Breakers (CBs) are traceable to an original plant 3
construction-order and the CBs were received prior to August 1983, there is reasonable assurance that the CBs are. acceptable and no
' additional traceability is required.
J Bapponse j
It-is our understanding that this position is not intended to imply that _the converse is also true.
That is, if a CB is D21
- traceable to an original plant construction order then there is D21
reasonable
' assurance...
Duquesne Light Company has accomplished action' 4.a of the original'bul3etin which states,
" Identify 3 all-molded-case CBs that have been purchased between D
~ August E1,:1983-and August 1, 1988, and installed in safety-related j
applications as. replacements or installed during modifications."
- Duq0esne. Light ' Company _has not verified that all other it. stalled 1 breakers are
- traceable to the original plant construction order.
. Installed-breakers : purchased since August 1, 1983 for construction
=
- - o f -- BVPS-2 (Licensed 1987) were not reviewed par action 4.a since they were' not installed as replacements or modifications.
These particular breakers.were subjected to a formal testing program s
based Lon-NEMA AB1 during construction.
Examination of test
- procedures.used at that-time shows only minor differences from the test criteria presented in the Bulletin.
pl 9910170153 891009 3
r PDR ADOCK 05000334 S
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g-Bs4hcr'VallOy Pow 0r StttiCn, UnitLNo3. 1-&'2
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- Docket No. 50-334, License No. DPR-66 LDocket1No. 50-412, License No.-NPF-73 L.
' NRC. Bulletin.88-10, Supplement 1~
Page 2-l NRC Pos#. tion 2 Visual inspection and physical examination of the CBs by the E
circuit breaker manufacturer (CBM) is not considered adequate to
. meet 'the requested traceability provisions of Bulletin No. 88-10.
Although-visual-inspection and physical examination by the CBM may
. provide a
reasonable basis that the CBs have not been opened or altered in a
substantial
- way, there-is no reasonable assurance that 'the CBs have not been previously used or subjected to' service conditions that mdy have adversely affected the performance capabilities.of the CBs..
l Response-Duquesne. Light Company did not rely on visual examinations as c
. basis.for-accepting any circuit' breaker under Bulletin 88-10.
i
- NRC Position 3 h
Item 4 of the actions requested in Bulletin No. 88-10 applies only to CBs that were purchased and installed after' August 1, 1983.
l L
Engponse 1
This position ' appears to be a restatement of action 4.a of the original bulletin.- Duquesne Light Company has accomplished action l
4.a ef1the original Bulletin.
l NRC Position 4 If~ an addressee identities any CBs as nontraceable during tne
- review. requested by Bulletin No. 88-10, it should take appropriate i
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-1 related CBs that were procured-under the same purchase orders as the nontraceable CBs.
Egesonse l
This position appears to address situations where the entire i
purchased quantity of a
particular non-traceable breaker is no longer on-hand in the storeroom and action 4.a of the Bulletin
-(identification of installed breakers) was not required.
As previously
- stated, BVPS has accomplished action 4.a of the original Bulletin.
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Be 90r Villcy Pawcr Station, Unit No3. 1&2 e' Docket No-50-334,1 License No. DPR-66
' Docket No. 50-412,' License No. NPF-73
- NRC Bulletin 88-10, Supplement 1 Page 3 j
-1 NRC Position 5
]
lIn an effort to limit the number of nonconforniiLg CBs in 1
safety-related
- systems, nontraceable CBs that were installed or j
are being maintained as stored spares as of August 1, 1988, and i
that successfully pass all tests specified~ in Attachment 1 of Bulletin' No.
88-10 are considered acceptable for use only as replacements for safety-related-CBs that are found to be nontraceable during the review requested by-Bulletin Ho. 88-10.
These breakers may not be used as safety-related replacements during other activities such as planned plant modifications or routine maintenance.
i ResDonse Although the original bulletin placed no restrictions on the use
- of stored brehkers which passed the Attachment 1 test, Duquesne Light Company reserved the use of such breakers only as a last
. resort (replacement of obsolete breaker styles for example).
Since our actions under Bulletin 88-10 are complete and did not require the use of tested spares to replace. installed 1
non-traceable
- breakers, Duquesne Light Company no longer requires this option to be available.
NRC Position 5 For CBs etored as spares that were not procured directly from the
- CBM, each individual CB should be reviewed in order to establish i
-proper. traceability, regardless of the number of CBs.
l -
Resnonsa L
l Since previous conversations with NRC staff indicated their awareness -that these breakers are not uniquely identified and that documentation is not uniquely tied to individual breakers, it H
appears : that this position was intended to prohibit " sampling" of j
l stored spares.
Duquesne Light Company has not used sampling as the oasis for acceptance of breakers under Bulletin 88-10.
NRC Position _2 s
l' All safety-related CDs from the same procurement order are L
considered traceable provided that 1) the order was procured
.directly from a
CBM having a
quality assurance program in L
,accordance with 10 CFR Part 50, Appendix B, 2) the CBM has been audited. by the addressee in accordance with Appendix B, 3) the CBs were ordered as safety-related, and
- 4) documented evidence has E
-been furnished to the addressee, such as a
certificate of
- compliance.
- However, if safety-related CBs were procured from a 1
l
BethOr?Vallcy Powbr Station, Unit Nos.~1 & 2
,J Dooket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 NRC Bulletin'88-10,-Supplement 1 o
Psge 4 L
' vendor aether than the CBM,_a certificate of compliance by-itself
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is not considered an adequate basis for establishing
. traceability.
In such
- cases, traceability of individual O
procurement orders, should be established through the roview of
~
0 procurement or shipping records back to the' CBM.
Telephone H
discussions with the CBM or vendor are not acceptcble for L
establishing-a basis for traceability.
Traceability to a
warehouse ~ -facility controlled by the CBM is considered equivalent to traceabilit ?r.to the CEM.
i li Resoonsg The overall intent of this position is unclear because it appears to-require an Appendix B CA program controls in order to conclude j
traceability to the CBM.
The original bulletin recognized the 1
fact that molded-case circuit breakers are likely to be commercial 1
grade items which are used in safety related applications.
In such
- cases,
_the manufacturer may not have 1an Appendix B QA L
- Program, i
l l
Since we ; suspect that this posit' ion was not intended
- o be L
inconsistentf with the traceability definition presented in the original
- bulletin, we have concluded that this position was o
-intended to, limit the.use of certificates of compliance (COC) by q
themselves-to purchases where Appendix B was rigorously applied.
Since COCs do not 'normally certify the' origin of purchased
~
l
- material, Duquesne Light Company has not relied on COCs as a basis-
.for establishing traceability to the CBM regardless of the p
application of Appendix B to the purchase.-
No reliance was-placed l
on verbal communicationa with the vendor as the sole basis.for establishing traceability.
We believe that our understanding of thc supplement is
' consistent with your intent.
Plertse contact my' of fico if there are-further. questions on this matter.
Very truly yours, 4
J.
D. Sieber
)
l Vice President Nuclear Group 1
cc:
Mr. J.
Baall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator
)
l Mr.
P.
Tam, Sr. Project Manage.
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.;- COMMONWEALTH OF: PENNSYLVANIA) e
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^ COUNTY OF BEAVER
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7 on this i
day of d
2 J//
, 1989, before:me,(
/ /,1> b bkV/,
a Notary Public in and for.sairi
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_ Commonwealthand-County, persor. ally appeared J.
D. Sieb'er, who being'
- i dhly; sworn,
' deposed,- and said-that (1) he ' is Vice-President of=
Duquesne-Light,
.(2) -he is. duly authorized to! execute and file the foregoing Submittal on-behalf of said Company, and (3) the statements-set.forth; 'in the SuF.nittal arce true and correct to the best of hisi knowledge, information and belief.
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