ML20011D436
| ML20011D436 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/11/1989 |
| From: | Frizzle C Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CDF-89-155, IEB-88-010, IEB-88-10, MN-89-127, NUDOCS 8912270213 | |
| Download: ML20011D436 (7) | |
Text
i Ce de,, I MaineYankee ktiAntt (LT6iis6ifFror4 MArNE tsNct ar?
EDISON DRIVE e AUGUSTA, MAINE 04336 * (207) 6224868 l
December 11, 1989 l
MN-89-127 CDF-89-155 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk n
Washington, DC 20555' j
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b)
NRC Bulletin No. 88-10: Non-Conforming Molded-Case Circuit Breakers, dated November 22, 1988 (c)
NRC Information Notice No. 88-46: Licensee Report of Defective Molded-Case Circuit Breakers, dated July 8, 1988 (d)
NUMARC Letter to USNRC Board of Directors, dated March 9,1989, l
MYAPCo Letter to USNRC, dated March 31, 1989 (MN-89-44)
(f)
MYAPCo Letter to USNRC, dated June 19, 1989 (MN-89-83)
(g)
MYAPCo Letter to USNRC dated August 4, 1989 (MN-89-102)
(h)
'USNRC Letter to MYAPCo dated August 3,1989 - NRC Bulletin No.
88-10, Supplement 1:
Non-Conforming Molded-Case Circuit Breakers i
Subject:
NRC Bulletin No. 88-10, Supplement 1 - Nonconforming Molded Case Circuit Breakers Gentlemen:
NRC Bulletin No. 88-10 was issued in November of 1988, Reference (b).
Licensees were required to demonstrate traceability of in-stock molded case circuit breakers (CBs) to the original equipment manufacturer to provide reasonable assurance that the CBs were capable of performing their safety functions. The NRC staff reviewed licensee responses to Bulletin No. 88-10 and identified several areas where they wished to impose additional requirements.
Supplement I to the Bulletin was issued (Reference h) to impose these additional l
requirements. With Reference (h) the staff requested licensees to review earlier submittals on this matter and amend them as necessary, taking into consideration the additional Bulletin provisions imposed by the Supplement.
l The attachment to this letter amends our earlier responses to Bulletin No.
l.
88-10, and addresses the specific positions of the Supplement. For convenience, I
each position of Reference (h) has been restated, and the applicability to Maine l
Yankee is provided in response.
We have summarized the results of our molded case circuit breaker review by listing the CBs considered non-traceable in E
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- Attentiont Document-Control Desk Page Two Table 1.. In addition to the Bulletin Supplement, Maine Yankee discussed this matter with Messrs. McIntyre and Potapovs of the Vendor Inspection Branch during a recent inspection at Maine Yankee. As part of the inspection, they questioned Maine Yankee's dedication process for the molded case circuit breakers associated with four specific purchase orders. Maine Yankee agreed to review the staff's-concern, and report our results concurrent with this submittal.
Table 2 lists the circuit breaker purchase orders and their ultimate disposition.
Also, during the. above mentioned inspection, Maine Yankee agreed to
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establishing a test program for CB acceptance and dedication. Efforts to secure test equipment and establish a test procedure continue.
Stone and Webster has been contracted to assist with these efforts. During the inspection, we agreed to test the circuit breakers that were purchased as part of orders-listed in
-Table 2 and that are less than five years old.
Since the inspection, Maine Yankee has elected to expand -this effort and test all molded case circuit breakers in stock, regardless of age,- prior to their installation into safety class applications.
We have reviewed the traceability of each purchase order listed in Table 2 and, per Bulletin 88-10, we have reasonable assurance that the breakers are traceable to the original manufacturer.
We trust this information is satisfactory.
Please contact us should you have any questions in this matter.
Very rul yours y Au 9
Charles D. Frizzle President CDF:SJJ Attachment c:
Mr. William T. Russell Mr. Eric J. Leeds Mr. Cornelius Holden Mr. Donald J. Caphton STATE OF MAINE Then personally appeared before me, Charles D. Frizzle, who being duly sworn did state that he is President of Maine Yankee Atomic Power Company, that he is duly authorized to execute and file the foregoing response in the name and l-on behalf of Maine Yankee Atomic Power Company, and that the statements therein
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are true to the best of his knowledge and belief.
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ATTACHMENT e
The following NRC positions correspond to those stated in NRC Bulletin No. 88-10, Supplement 1.
The responses represent the results of Maine Yankee's review of written reports submitted tc the NRC in accordance with Bulletin No.
88-10.
NRC Position 1 If CBs are traceable to an original plant 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.
Maine Yankee Resoonse r
Through discussions with NUMARC and members of the NRC staff, we understand that this position was intended to provide relief from verifying CB traceability for those licensees with a large number of circuit breakers purchased as part
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of original plant construction and still residing in storage.
This allowance is only acceptable for those circuit breakers purchased prior to 1983.
This position was not intended to request licensees to verify traceability of circuit breakers installed in the plant that were not part of original construction orders.. If, however, there is another reason to believe a breaker is not traceable, (e.g. purchased as part of an order where others were found non-traceable) then installed breakers should be investigated.
Position 4 below applies to these circumstances.
Based on this understanding, position 1 does not apply to Maine Yankee.
NRC Position 2 Visual inspection and physical examination of the CBs by the 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 may have adversely affected the performance capabilities of the CBs.
Maine Yankee Response Maine Yankee has not relied upon visual inspection and physical examination l
L alone to substitute for the verifiable traceability requested by the Bulletin.
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NRC Posit' ion 3
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Item 4'of. the actions requested in Bulletin No.-88-10 applies only-to CBs that were purchased and installed after August 1, 1983.
e-Maine Yankee Response
)
Maine Yankee understands that item 4 applied to only those circuit breakers that were purchased and installed into safety class applications after August 1, 1983.
Maine Yankee has twelve circuit breakers in this category.
We have evaluated the traceability of these breakers and reported our results with a
References (f) and (g).-
4 NRC Position 4
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If an addressee identifies any CBs as non-traceable during the review 1
requested by Bulletin No.- 88-10, 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 CBs that were procured under the same purchase
. orders as the non-traceable CBs.
Maine Yankee Response Table 1 is a summary of the circuit breakers Maine Yankee classifies as non-traceable, and their respective purchase orders.
As can be seen by the
. table we investigated all breakers associated with those purchase orders having j
at least-one circuit breaker non-traceable.
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NRC Position 5 i
i In an effort to limit the number of nonconforming CBs in safety-related systems, nontraceable CBs that were installed or are being maintained as stored
-spares as of August 1,1988, and that successfully pass all tests _specified in 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 l
review requested by Bulletin No. 88-10.
These breakers-may not be used as i
safety-related replacements during other activities such as planned plant I
modifications or routine maintenance.
Maine Yankee Response l
This item does not apply to Maine Yankee as we have not tested any l
nonconforming CBs.
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CDF89155.LTR
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NRC Positied 1 For CBs stored as spares.that were not procured directly from the CBM, each individual CB should be reviewed in order to establish proper traceabili+v, regardless of the number of CBs.
Maine Yankee Response At Maine Yankee, traceability was established for individual purchase orders.
Shipping records were one method Maine Yankee used to verify circuit breaker traceability.
If the ordered quantity of CBs for a particular purchase order was not received at the same time (with the same shipping records), Maine Yankee sought the shipping records for the separated quantity. We consider this method a reasonable equivalent to tracing individual circuit breakers.
NRC Position 7 i
All safety-related CBs 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 CBs-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 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 procurement or shipping records back 1
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.
Maine Yankee Response As discussed above, Maine Yankee established traceability for individual CB purchase orders. We established traceability through shipping records back to the original CB manufacturer or to a warehouse facility controlled by the circuit breaker manufacturer.
Maine Yankee also audited several of our intermediate suppliers to obtain records necessary to demonstrate CB traceability.
The results of our efforts were reported with References (e),
(f),'and (g).
Circuit breakers having insufficient records to verify traceability are summarized in Table 1.
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TABLE 1
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' Purchase Ordered -- Instock") + NNS ) + Class Notes Total Safety Order-#
Sunolier-U 45112-00 Nutherm Int.
14-10 0
4 JC0 submitted.
R with Ref.(f)
, Nutherm Int.-
2 2
0 0
48520-00 1
During NRC au'dit, the. following breakers were deemed by the -NRC to have-1
. insufficient records to verify traceability:
34241-00 Gilman Electric 4 1
2(U 1 ")
Installed for LSI-M-21 21688-00.Gilman Electric 5 4
1 0
35665-00 Westinghouse-Electric Co.
4 4
0 0
48117-00 WESCO 1
1 0
0 30 22 3
5
") Breakers-in: stock shall. remain on QC hold until April 1,1990. At'that time
- they shall be made available for use in NNS applications or discarded.
(UThe material. issue. slip for one breaker could not be located.
This breaker was most likely installed in an NNS application.
("The molded case circuit breaker installed for LSI-M-21 was placed in service L
in 1984, and had functioned. satisfactorily for more than five years.
Because L
Gilman Electric does not maintain records for greater than three years, we were unable to obtain documentation tracing the breaker to the OEM.
A replacement breaker was ordered and installed.
This breaker has been discarded.
")Non-Nuclear Safety.
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TABLE 2 w J?
V-n;During a recent inspection the NRC requested Maine Yankee verify traceability of the circuit L
- breakers associated with the following purchase orders
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' Purchase Order i '
Vendor.
Total Ordered Traceabilitv1 I'
L29649-00L Westinghouse Ele'ctric 6
verified:
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'45904-00' Westinghouse. Electric 15 veri fied.
e-48212-00 Gilman Electric-10 verified 48351-00 Gilman Electric 1
verified l
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