ML20005F048
| ML20005F048 | |
| Person / Time | |
|---|---|
| Issue date: | 06/01/1989 |
| From: | Guillen J NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Lewis S NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20005F034 | List: |
| References | |
| FOIA-89-404 IEB-88-010, IEB-88-10, NUDOCS 9001120221 | |
| Download: ML20005F048 (5) | |
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June 1, ~1989
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NOTE 'IO:
Stephen Lewis, 000 FROM:
.J. Guillen, OGCB
SUBJECT:
DRAFT NRC BULLETIN NO 88-10, SUPPL 91ENT 1-
.'NRR has performed a preliminary review of responses to NRC Balletin No. 88-10~
.l and detennined that many responses do not adequately satisfy the provisions of -
l the bulletin. As a result, NRR has prepsred a supplement to Balletin No. 88 j to request that licensees verify that their responses meet the bulletin provisions and are consistent with NRC positions.
'l We request that OGC review the enclosed draft supplement and provide comments by June-7, 1989.
If you have any questions, please contact me (X2-1170) or-
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Carl Berlinger (X2-1162).
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J im Guillen L
Generic Consnunications Branch i
Enclosure as stated j
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9001120221 900110 PDR FOIA 8902435
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!l-E June 1, 1989
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HOTE 'IO:
Stephen Lewis, 000 I
FRCH:
J. Guillen, CGCB
SUBJECT:
DRAFT NRC BULLETIN NO. 88-10, SUPPIRIENT 1 s
i NRR has performed a preliminary review of responses to NRC & lletin No. 88-10 and detemir.ed that many responses do not adequately satisfy the provisions of the lulletin. As a mault, NRR has pmpared a suppleriant to N11etin No. 88-10 to mquest that licensees verify that their responses meet the bulletin provisions and are consistent with NRC positions.
We mquest that OGC myiew the enclosed draft supplement and provide coments by June 7, 1989.
If you have my questions, please contact me (X2-1170) or Carl Berlinger (X2-1162). -
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i JMre Guillen Generic Comunications Branch Enclosure as stated cc: CHBerlinger L
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OMB No.: 3150-0011 NRCB 88-10, Supplement 1 4
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555 June, 1989 NRC BULLETIN NO. 88-10, SUPPLEMENT 1: NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS Addressees:
- All holders of operating licenses or construction permits for nuclear power reactors.
Purpose:
The purpose of this bulletin is to inform addressees that based on a prelimi-nary review of responses to NRC Bulletin No. 88-10, the NRC staff has deter-mined that many responses do not adequately satisfy the provisions of Bulletin No. 88-10 and that some addressees may need to take additional actions.
This supplement also provides specific examples of common deficiencies identified-during the-preliminary review of responses.
Description of Circumstances:
NRC Bulletin No. 88-10 was issued on November 22, 1988, to request that ad-dressees take actions to provide a reasonable assurance that molded-case circuit breakers (CBs) purchased for use in safety-related applications perform
. their safety functions.
In addition, the bulletin requested that addressees submit certain information to the NRC regarding CBs that could not be traced to the circuit breaker manufacturer (CBM).
An NRC staff review of the writter, reports submitted by addressees in accor-dance with Bulletin No. 88-10 revealed several comon deficiencies. In addi-tion, the NRC staff has received requests for positions on specific issues that j
were not explicitly addressed in Bulletin No. 88-10.
The NRC analyses and positions on these issues are summarized herein.
1.
If CBs are traceable to an original plant construction order and the order was procured directly from the CBM, there is reasonable assurance that the CBs are acceptable, and no additional traceability is required. However, if the CB purchase orders were procured from intemediate suppliers, such as panel or motor control center manufacturers, traceability should be established to the CBM in accordance with Bulletin No. 88-10.
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1 NRCB 88-10, Supplement 1 June xx, 1989 Page 2 of 3 2.
Visual inspection and physical examination of the CBs by the CBM is not considered adequate to meet the traceability requirements 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 l
a substantial way, there is no reasonable assurance that the CBs have not been previously used or subjected to service conditions that may have adversely affected the performance capabilities of the CBs.
i 3.
Item 4 of the actions requested applies only to CBs that were purchased and installed after August 1,1983.
However, it is expected that address-ees will assess, as currently required by 10 CFR Part 50 Appendix B, the acceptability of installed CBs, regardless of their purchase date, that were procured under the same purchase orders as CBs that are identified as nontraceable during the review requested by Bulletin No. 88-10.
4.
Nontraceable CBs that were installed or in stores as of August 1,1988, and that successfully pass all tests specified in Attachment 1 of Bulletin No. 88-10 are considered acceptable for use as replacements for safety-related CBs that are found to be nontraceable, provideo that visual inspections and physical examinations of the CBs reveal no evidence of tampering.
i 5.
Regardless of the number of CBs stored as spares, each individual CB stored for future use in safety-related applications should be reviewed in order to establish proper traceability.
For CBs that were not procured directly from the CBM, traceability on a sample basis does not establish traceability for ~all CBs.
6.
All safety-related CBs from the same procurement order are considered traceable if the order was procured directly from a CBM having a quality assurance program consistent with-10 CFR Part 50, Appendix B, if the CBM has been audited in accordance with Appendix B, and if documented evidence i
has been furnished, such as a certificate of compliance. However, if safety-related CBs 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 procuroment/ shipping records back to the CBM. Telephone discussions with the CBM or vendor are not acceptable for establishing a basis for traceability.
Actions Requested:
In response to the aforementioned circumstances, addressees are requested to perform the following actions within 30 days from the receipt of this bulletin:
1.
Review written reports submitted to the NRC in accordance with Bulletin No. 88-10 and verify that the responses meet the bulletin provisions and are consistent with the above NRC positions.
2.
Prepare and retain documentation for possible audit that indicates that item 1 of the actions requested has been performed as requested.
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NRCB 88-10, Supplement 1 June xx, 1989 i
Page 3 of 3 d
Reporting Requirements:
No written reports are required to be submitted to the NRC by this supplement; however, addressees are required to provide any appropriate corrections to previous responses to Bulletin No. 88-10. The NRC may conduct inspections at
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selected nuclear power plant sites in order to verify that issues associated i
with Bulletin No. 88-10 and this supplement have been adequately resolved, j
If you have any q"e elons regarding this matter, please contact one of the technical contacti M;ted below or the kegional Administrator of the appropri-l ate NRC regional u.11ce.
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[U bid o.J Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts:
Uldis Potapovs. NRR (301)492-0984e Jaime Guillen, NRR (301)492-1170
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Attachment:
List of Recently Issued NRC Bulletins l
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