ML20042D111
| ML20042D111 | |
| Person / Time | |
|---|---|
| Issue date: | 03/21/1989 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20037B365 | List: |
| References | |
| FOIA-89-404 IEB-88-010, IEB-88-10, NUDOCS 8903300100 | |
| Download: ML20042D111 (8) | |
Text
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March 21, 1989 FEMORANDUM FOR:
All Project Managers FROM:
James C. Stone, Pro,iect Manager Pro,1ect Directorate I-2 Division of Reactor Projects I/!!
SUBJECT:
NRC BULLETIN 88 10: NONCONFORMING MOLDE0 CASE CIRCUIT BREAKERS Bulletin 88-10 was issued on November 22, 1988, requesting all holders of operating licenses and construction permits to take action to verify traceability of molded case circuit breakers (MCCBs) back to the original manufacturers (CBM). Responses are due by April 1, 1989.
Enclosed is guidance to be used by the PM in reviewing the licensees' responses.
I believe the guidance will cover the majority of cases. However, there will be cuestions. Any questions concerning the technical aspects (e.g.
suitability of breaker usage, acceptability of testing) should be directed to Paul Gill, SELB, X20811. Questions concerning the traceability of breakers should be directed to Uldis Potapovs, RVIB, X20984.
You may contact me for any questions and I will assist. My extension is X21422.
Also, I have enclosed sample letters to the licensee.
Because there are so many different responses that the licensee may send in, it will require the PM to fill in the blanks.
I do not need to be on concurrence, but please send a copy to Paul Gill, Mail Stop 8020. Uldis Potapovs. Mail Stop 904, and Jim Stone, Mail Stop 14E21.
You may want to include SEL8 or RV!B on concurrence if issues in their respective areas are of concern.
(-
James C. Stone, Project Manager Project Directorate 1-2 Division of Reactor Projects 1/II
Enclosures:
1.
Review Guidance - Bulletin 88-10 2.
Category 1 Letter L
3.
Category 2 Letter 4
Category 3 Letter 5.
November 30, 1987 Memo 6.
Flow Diagram I
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All Project Managers FROM:
James C. Stone, Project Manager Project Directorate 1-2 Division of Reactor Projects 1/11
SUBJECT:
HRC BULLETIN 88-10: NONCONFORMING MOLDE0 CASE circuli BREAKERS 1
Bulletin 88-10 was issued on November 22, 1988, requesting all holders of operating licenses and construction permits to take action to verify i
traceability of molded case circuit breakers (MCCBs) back to the original manufacturers (CBM).
Responses are due by April 1, 1989.
Enclosed is guidance to be used by the PM in reviewing the licensees' responses.
I believe the guidance will cover the majority of cases.
- However, there will be questions. Any qvestions concerning the technical aspects (e.g.
suitability of breaker usage, acceptability of testing) should be directed to Paul Gill, SELD, X20811. Questions concerning the traceability of breakers should be directed to Uldis Potapovs. RVlB X20984 You may contact me for any questions and I will assist.
My extension is X21422.
l Also, I have enclosed sample letters to the licensee.
Because there are so many dif ferent responses that the licensee may send in, it will require the PM to fill in the blanks.
I do not need to be on concurrence, but please send a copy to Paul Gill, Mail Stop 8D20, Uldis Potapovs, Mail Stop 904, and Jim Stone, Mail Stop 14E21. You may want to include SELB or RVlB on concurrence if issues in their respective areas are of concern.
i
/s/
James C. Stone, Project Manager Project Directorate 1-2 i
Division of Reactor Projects 1/11
Enclosures:
1.
Review Guidance - Bulletin 88-10 2.
Category 1 Letter l
3.
Category 2 Letter i
4.
Category 3 Letter S.
November 30, 1987 Memo 6._
Flow Diagram l
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REVIEW GillDANCE. rut.l.ETIN 88-10 A.
Operating License Holders If all breakers in the sample were traceable to the CBM then the response should:
a.
Confim that the sample was at least 50 MCC9s selected as follows:
- 1) All MCCBs in stores if 50 or more MCCBs in stores or 2) All MCCWin stores plus installed MCCBs to bring the sample size to 50.
If the response does not provide that infonnation, I recorrrnend a phone call to the licensee to confirm the sample size.
b.
Confirm that af ter August 1,1988, only MCCRs bought directly from a manufacturer using a 10 CfR 50, Appendix R quality program or MCCRs that can be traced directly to the CBM and upgraded" Tor safety related applications or MCCRs that have passed the tests of Attachment 1 of the BIITletin are being held 2
in stores for use, c.
Confim that all breakers were traceable to the CBM and provides some bases for the statement. To be traceable to the CBM the utility must have audited and verified documentation in their possession such as a certificate of compliance (CofC).
If procurement was direct from the CBM and the CBM has been audited in accordance with 10 CFR 50 Appendix B, then the CofC applicable to that action represents verifiable traceability for those MCCBs. Certification from other than the CBM should be verified by audit of the supplier or other means. Audit of an intermediary supplier must assure that the suppliers' MCCBs are consistently traceable to the CBM. Results of recent audits could support verifiable traceability only if-traceability of MCCBs to their CBM for each purchase order was specifically addressed. An audit of a sample of suppliers or orders is not acceptable in complying with the bulletin. Each intermedia W supplier and order that made up the sample siio'uTd be audited to ensure that the traceability to the CBM is clearly established.
If this infonnation is not clear in the licensees response then supplemental information should be requested.
d.
Confirm that information is being retained for 5 years.
If 80% or more are traceable to the CPM and less than 10% of the untraceable MCCBs fail test then the response should a.
Include infonnation of A.I.a and A.I b above, and for the traceable MCCBs information of A.I.c.
b.
Sumarize information for all MCCRs that could not be traced to the CBN (See November 30, 1988 memo for example).
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c.
Provide test results for MCCRs that fail testing (See Nov. 30, 1988 memo for example).
If testing is not completed licensee should confim that testing will be completed before startup from the first refueling outage beginning after March 1,1989 The test results should be submitted within 30 days of startup from that refueling outage,
^
d.
Confirm that for installed MCCRs that could not be traced to the CBM, a justification for continued operationTJCO) was prepared, or the MCCB was replaced with either a traceable one or one that Tiad passed the bulletin tests.
e.
Confim that infomation. is being retained for 5 years.
III. If (11 less than 80t were traceable to the CBM, or (2) more than 80%
were traceable to the CBM but more than 10% of the untraceable MCCBs i
failed the bulletin test, or (3) less than 100% were traceable to the CBM and the utility chose to do no testing, then the response should a.
Ccnfirm that the sample size was all MCCBs purchased between August 1983 and Auaust 1988 that Me intended for use or were used as replacements or installed during modifications in safety related applications, b.
Include information of A.I b. above and for traceable MCCBs infomation of A.I.c.
c.
Sumartre infomation for MCCBs that could not be traced to the CBM (See Nov. 30, 1988 memo for example),
d.
Confim that for installed MCCBs that could n t be traced to the A
CBM, a JC0 was prepared, or the MCCB was replaced with either a traceable one or one that passed the bulletin tests.
e.
For any testing of MCCBs:
1.
Provide test results for MCC8s that failed the bulletin tests (See Nov. 30, 1988 memo for example).
2.
Provide a schedule for completion, if testing was not completed at the time of the report. The schedule should show completion of testing before startup from the first refueling outage beginning after March 1,1989 if the total number of untraceable MCCBs was less than 75 or the-second refueling outage beginning after March 1,198Tif the total number of untraceable breakers was 75 or more.
The test results should be submitted within 30 days of startup from
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the applicable refueling outage.
f.
Confim that information is being retained for 5 years.
l
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!Y. Implementation of corrective action.
4.
If the total number of untraceable MCCBs installed in the plant is less than 75, then these MCCBs should either be (1) tested in accordance with Attachment 1 of the bulletin and any that fail are to be replaced or (2) replaced with either traceable MCCBs or MCCBs that have pa'ssed the tests of Attachment 1 of the bulletin. This action is to be completed before startup from s
the first refueling outage beginning after March 1.1989.
'i b.
If the total number of untraceable MCCBs installed in the plant is 75 or more then the actions of A.IV.a. above should be completed for at least one half of the untraceable MCCBs before startup from the first refueling outage beginning after March 1.
1989. For the remainder of the untraceable MCCBs, the action of A.IV.a. above should be completed before startup from the second refueling outage beginning after March 1. 1989.
c.
In either case a JC0 must be prepared for each untraceable MCCB that is installed and not replaced within M'" days of identification.
B.
Pemit Holders Use the same criteria as Ot. Holders except:
a.
JCOs are not required, b_
Test results should be submitted within 30 days after fuel load, c.
All items should be completed and corrective action implemented.
before fuel load.
C.
I have included a flow diagram of the Actions Requested in Bulletin 88 that you may find useful in reviewing the actions taken by the licensee.
D.
Some utilities may request relief from some bulletin requests. These should be handled on a case-by-case basis in concert with the appropriate technical branch. Please send me a copy of your response.
l
ENCLOSURE 2 Licensee Name and Address Category 1 Letter All items satisfactory
Dear:
SUBJECT:
RESPONSE TO BULLETIN 88-10 On November 22, 1988, the NRC staff issued Bulletin 88-10. " Nonconforming Molded-Case Circuit Breakers", requesting certain actions to be taken in regard to molded-case circuit breakers (MCCB) used in safety-related applications. The bulletin requested that, by April 1,1989, licensees provide a written response confirining that actions requested by the bulletin l
had been taken, sumarizing the results of those actions and if not completed, j
a schedule for completion, j
By letters dated (
) you responded to Bulletin 88-10. The NRC staff has completed a review of your response (s) and find the actions i
taken by you to be in confonnance with the bulletin requests.
No further action is required at this time.
This fulfills your requirement in responding to Bulletin 88-10.
As discussed in Bulletin 88-10 you should maintain the documentation associated with this bulletin for at least five years. These records may i
subject to future inspections.
Sincerely.
Project Manager l
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ENCLOSURE 3 Licensee Name and Address Category 2 Lettgr items open but schedule satisfactory
Dear:
-l
SUBJECT:
RESPONSE TO BULLETIN 88-10 1
On November 22, 1988, the NRC staff issued Bulletin 88-10, ' Nonconforming Molded-Case Circuit Breakers", requesting certain actions to be taken in i
regard to molded-case circuit breakers (MCCB) used in safety-related i
applications. The bulletin requested that, by April 1, 1989, licensees provide a written response confirming that actions requested by the bulletin j
had been taken, summarizing the results of those actions and if not completed, a schedule for completion.
J By. letter (s) dated (
) you responded to Bulletin 88-10.
l The NRC staff has completed a review of your response (s) and find the actions taken to be in conformance with the bulletin requests and the schedule for completion of the following actions (List actions remaining to be completed) to be acceptable.
Please provide the results of those actions (use either the licensees comittment or the schedule in the bulletin).
Sincerely, Project Manager l
l
ENCLOSURE 4 Licensee Name and Address Category 3 Letter Open items
Dear:
SUBJECT:
RESPONSE TO BULLETIN 88-10 On November 22, 1988, the NRC staff issued Bulletin 8810, *Noncentoming Molded-Case Circuit Breakers" requesting certain actions to be taken in regard to molded-case circuit breakers (RCCB) used in safety-related applications. The bulletin requested that, by April 1, 1989, licensees provide a written response confiming that actions requested by the bulletin l
had been taken, sumarizing the results of those actions and if not completed,
,a schedule for completion.
By letter (s) dated (
) you responded to Bulletin 88-10.
The NRC staff has completed a review of your response and find th3t you did not provide the following requested infomation:
[PM to provide details of information needed to close out the issue].
Within 30 days of receipt of this letter we request you respond to the above items.
s Sincerely, Project Manager i
'