ML20127A496

Summary of 900529 Meeting W/Nrr Allegation Review Board Re Allegation NRR-89-A-0023, Molded Case Circuit Breakers Adjustment Procedures

ML20127A496
Person / Time
Site:	Susquehanna
Issue date:	06/07/1990
From:	Grimes B, Jun Lee Office of Nuclear Reactor Regulation
To:	Brach W, Perkins M, Rosa F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
Shared Package
ML20126M903	List: ML20126M900 ML20126M928 ML20127A496 ML20127B427 ML20127B519
References
FOIA-92-212 IEB-88-010, IEB-88-10, NUDOCS 9301110307
Download: ML20127A496 (2)

Text

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ALLEGA110N REYlEW BOARD SUMM_AR Alligation hurber NRR-89-A-0023

1. The NRR Allegation Feview Board roet on May 29, 1990 at 1:00 p.m.

2. Present at the meeting were: B. Grires, hRR V. Potapovs NRR

5. Verga, NRR B.Letts,OI F. Rosa, NRR J. Lee, NRR W. Brach, NRR R. Brady, NRR P. Gill, NRR

3. Faci 11 tits / organizations involved: Susquehanna Steam Electric Station 4 Allegation title: Molded Case Circuit Breakers (MCCB) Adjustrrent Procedures

5. This allegation has been assigned to Vendor Inspection Branch for resolution.

6. The ARB determined the allegation to be of potential safety significance.

7 The ARB assigned this allegation a Priority Level of 3 af ter consideratic,n of its safety significance.

8. The ARB made the following decision on 01 referral: No

9. (for01 referrals) The ARB reconnends an investigation priority of (high-redium-low). N/A 10 The following resolution plan and schedule was approved by the ARB.

Activity Due Date Conf erence Call ESB/VlB/R] May 30, 1990 (complete)

Closure letter June 22, 1990

11. Additional convnents: Vendor Inspection Branch, with assistance by Electrical Systems Branch, will conduct a conference call with Region 1, to discuss technical issues for closure letter (complete May_30, 1990).

The closure letter will be coordinated by VIB with technical input from Electrical Systems Branch for the signature of the Associate Director for Inspection and Technical Assessrnent. The ARB suggested that, following developrent of the closure letter, Region I rey want to clarify with the licensee that, although the inspection related to this allegation revealed nosignificantdeficienciesinthisinstance, Bulletin 88-10appljgsfor-this type of activity and that disasserbly and adjuttEAT6f MCCB tHp I 7 units violate inoustry codes or manufacturer's specifications.. In

• suntnary, it should be nade clear to the alleger and the licensee that this practice is not one condoned by NRC.

LIMITED DISTRIBUTION 9301110307 920731 /) ..

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12. Prepared by: hbr- IL . [e!7!IO Uehigt.te;,iOfIhe Alleg tlons Coordinator Date

13. Approved by: ' A + d- I / 2-/I O Srien K. Grimes, Chairperson, ARB Date Distribution:

NI C Executive Team WBrach Director. 01 FRosa BGrires MFerkins, kl 5Varga NRR OAC WHodges R!

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, OMB No.: 3150-0011 NRCB 88-10 i i UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 l November 22, 1988 'l

\

hRC Bulletin No. 88-10: NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS  :

Addressees: i 1

All rt a holders c tors. of optrating licenses or construction pemits for nuclear power

Purpose:

The purpose of this bulletin is to request that addressees take actions to provide reasonable assurance that snolded-case circuit breakers (CBS), in.

i cluding CBs used with motor controllers, purghased for use in safety-related applications w{thout verifiable traceability to the circuit breaker manu-facturer (CBH) perfom their safety functions.

Description of Circumstances:

NRC Information Notice No. 88-46, " Licensee Report of Defective Refurbished Circuit Breakers," dated July 8,1988 and Supplement I thereto, dated July 21. I 1988, discussed a report by Pacific Gas and Electric Company that indicated

• Systems, Inc. through a local electrical distributor.that These CBs (Square D its Diablo Can ,

i cations at the Diablo Canyon NuclearSquare Power Plant. molded-case, D Company reported ty refurbished Square D Company equipnent.that an inspection and testing Furthemore, square D reported that several of the circuit breakers tested did not comply with Square D or Under-writers perfo rmed.Laboratories, Inc. (UL) specifications for all of the electrical tests Information Notice No. 88-46 also listed several California com.

panies that were involved in supplying surplus refurbished and possibly t defective refurbished electrical equipment to the nuclear industry.

During recent NRC inspections, additional examples were identified that to nuclear power plants.indicata a potential safety concern regarding electrical{ e 1he NRC is concerned that equipment being procured original manufacturer's specifications may, in fact, not confom requirements and specifications, l

1.  !

Refer to Attachmer.t 2 for Definition of Tems 't p ill80315-- ] k [

gglg PDRT$E M e;h 9 0 010 '

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hRCB 88-10 November 22, 1988 Page 2 of 7 The actions requested in this bulletin are limited to molded case CBs. Holded-case CBs are tested and calibrated at the manufacturer's plant in accordance with recognized industry standards, such as VL-489, "Holded Case Circuit Breakers and Circuit Breaker Enclosures." and National Electrical Manu. ytyr,ers Associ- ~

ation(NEMA)-ABl.'MoldedCaseCircuitBreakers. nh %old geELbs factory-calibrated and sealed..slisttAth '. '

furbishing of these CBs could jeopard'ze. e r design capa 4 04U ca t p o or. ,re ..,1 ,

,lity and reliability. ,

The NRC is concerned that the reliability and capabilities of refurbished CBs purchased as corrercial grade (non-Class 1E) for later upgrading to safety-related (Class IE) applications cuy r.ot reet the minimum comercial grade standards.

bilities of comercial grade CBs upgraded to safety-related because of so -

observed inadequacies in the dedication process and numerous failures found .

during the testing of some of these CBs. In order to properly dedicate ciectrical items procured as cornercial grade for subsequent use in grade quality, include a proper evaluation of seismic and environmental quali-fication, confim critical parameters, and include testing as appropriate.

Molded-case CBs purchased frce the CBM or that can be traced to the CBM are -

of lesser concern than other rnolded-case CBs because CBs from the CBM, whether safety-related or comercial grade, are manufactured under controlled conditions to confom to a proven design. Safety-related CBs ,

the CBM are controlled under quality assurance (QA) purchased as Class IE tofrom i Appendix B of 10 CFR Part 50. programs that conform 4 the controls exercised by the CBM over the manufacturing activities provideWh reasonable assurance that improperly refurbished components have not been in-troduced and passed through the upgrading process. j of safety systems and the in-service use of CBs provide a reasonable basis forFurtherinor  ;

accepting installed replacement CBs that have been procured from the CBM or that can be traced to the CBM.

The NRC currently believes that the concerns addressed in this bulletin do not apply installedto electrical in plants. equipment (safety-related and comercial grade) originally construction from CBMs with full certification.This The large equipment appears to have been procu quantities of electrical assemblies or components procured under bid packages during plant plied by vendors doing refurbishing. construction reduce the possibility of any i original Although the actions requested in this bulletin only apply to safety-related molded-case CBs, the NRC intends to monitor industry programs to ensure that '

other molded-case CBs, which may have been installed as replacements, installed during modifications, or are being maintained as stored spares, are suitable '

for their intended service. Addressees are encouraged to participate in a joint program.

additional regulatory actions will be taken, as appropriate.If industry programs a n1

i NRCB 88-10 November 22, 1988 Page 3 of 7

~ The NRC requested and received coments from the Nuclear Management and Resources

- Council (NUMARC), the National Electrical Manufacturers Association (NEMA), and the Underwriters Laboratories, Inc. (UL), during the preparation cf this bulletin.

These coments were considered and some were appropriately incorporated into this bulletin.

NEMA has cocrnented to the NRC that determination of the critical perfomance characteristics of durability and short-circuit capabilities of CBs requires destructive testing of selected breakers that are representative of CBs to be placed in service. Because a refurbished breaker may not have been refurbished uMer controlled conditions to conforn to a proven design, destructively testing iected breakers will not infer anything about a refurbished CB. UL provided specific cocrnents on the tests in Attachment 1 of this bulletin, in addition,

{ they stated that, "it is UL's opinion that the test program is not adequate to provide assurance that the tested, non-traceable, circuit breakers would h be suitable for their intended purpose." Although the test program described 5 in Attachment 1 of this bulletin does not provide complete verification of all E

the performance requirements and characteristics of molded case CBs (such as seismicity or fault clearing capability), the NRC considers the test program E to provide a reasonable assurance of performance requirements and characteristics most important to ensuring reactor safety. This, considered in conjunction with (1) the limited number of nonconformir.g CBs that may remain installed in safety-related systems following implementation of the actions requested by this L bulletin, (2) the existence of redundant safety-related systems in nuclear power reactors that are required by NRC regulations (3) the license required in-service testing of installed CBs performed to demonstrate the CB's functional

_ performance, and (4) the low frequency of occurrence of seismic events and uvere electrical faults, provides a reasonable assurance that nuclear power reactors can be operated without undue risk to the health and safety of the public. ,

The NRC investigation of this issue is not complete. A supplement to this bulletin may be issued to include other electrical equipment or a longer pro-curement review period if warranted by the results of the ongoing evaluations or the results o' testing requested in this bulletin.

Actions Requested:

1. All addressees are requested to perform the following review by March 1,1989:

a. Identify all molded-case CBs purchased prior to August 1,1988, tha t s

are being maintained as stored spares for safety-related (Class IE)

[ applications or cocinercial grade CBs that are being maintained as t- stored spares for future use in safety-related applications; this includes CBs purchased from a CBM or from any other source. If the i

number of these stored spare CBs is less than 50 at a nuclear plant li site, then randomly select CBs purchased between August 1,1983 end i

August 1,1988 that have been installed in safety-related applica-tions as replacements or modifications to form a minimum saniple of 50 CBs per nuclear plant Li_te.

i

- NRCB 88-10 November 22, 1988 Page 4 of 7

b. Verify the traceability of these CBs.

c. Identify the number .

manufacturer, model number, and to the extent possible the procure, ment chain for all those CBs identified in (la) that cannot be traced to the CBM.

each system in which they are/were installed.For installed CBs, also identify 2.

All holders of operating licenses who identify insttlled CBs per item 1 above or item 4 below that cannot be traced to a CBM are requested to prepare, within 30 days of the ccepletion of each item, an analysis justifying continued operation until items.1 through 5 of the actions requested in this bulletin have been completed.

3.

All addressees who identify 80 percent or anore CBs traceable to the CBM per item 1 above are requested to test the CBs that are not traceable to the CBM in accordance with the test program described in Attachment 1.

Any installed CBs that fail any of these tests should be replaced with CBs that meet the criteria of item 7 of the actions requested or CBs that pass all tests in accordance with the testing program described in Attachment 1.

If more than 10 percent of the CBs tested fail any of the tests described in Attachment 1, continue with item 4; otherwise, proceed to item 6 of the actions requested.

Holders of operating licenses are requested to complete this testing program before startup from the first refueling outage beginning af ter March 1,1989.

Holders of construction program before fuel load. permits are requested to complete this testing 4

All addressees who identify less than 80 percent of the CBs traceable to the CBM per item 1 above or who identify a failure rate of more than 10 percent followingforactions:

the CBs tested per item 3 above are requested to perform the

a. Identify all molded-case CBS that have 4 1983 and August 1,1988, and installed,been purchased between August 1, i in safety-related applications I as replacements or installed during modifications.

b. Verify the traceability of these CBs.

c.

Identify the number, manufacturer, model number, system in which they are/were installed, and to the extent possible, the procurement chain '

5.

for all those CBs identified in (4a) that cannot be traced to the CBM All addressees who identify installed CBs that cannot be traced to the CBM per item 4 above are requested to replace these CBs with components that meet the criteria of item 7 of the actions requested or to test them in

of these tests should be replaced with CBs that meet the criter i item 7 of the actions requested or CBs that pass all tests in accordance with the test program described in Attachment 1.

l l

- - = - - , - . . . . _. .. - _- . - -

NRCB 88-10 November 22, 1988 Page 5 of 7 Holders of operating licenses are requested to replace or to test at least one-half, or all if the total number is less than 75, of these installed after March CBs before startup from the first refueling outage beginning 1, 1989. The remaining CBs should be replaced or tested before March 1, 1989. startup from the second refueling outage beginning after Holders of construction permits are requested to replace or to test these installed CBs before fuel load.

6.

Information generated while performing the actions requested in items 1, 2, 3, 4, and 5 above should be documented and maintained for a period of 5 years after the completion of all requested actions.

7.

With the exception of actions taken in response to items 3 and 5 of the actions requested above, molded-case CBs installed in safety-related ap-plications af ter August 1,1988 should be:

a.

Manufactured by and procured from a CBM under a 10 CFR 50, Appendix B, program; or b.

Procured from a CBM or others with verifiable traceability to the CBH, in compliance with applicable industry standards, and upgraded to safety-related by the licensee or others using an acceptable dedi-cation program.

The NRC encourages addressees to significantly upgrade their dedication programs through a joint industry effort to ensure their adequacy and consistency. The NRC will monitor these industry 1

initiatives and if they are not sufficient or not timely, or if prob- '

lems with the dedication of comercial grade equipment for safety-related use continue, the NRC will take appropriate regulatory actions. i 8.

Addressees that cannot meet the schedule for the actions requested above and/or the corresponding reporting requirements below, should justify to l the NRC their proposed alternative schedule.

Reporting Requirements:

1.

All holders of operating licenses are required to provide a written '

report by April 1,1989, that:

l a.

Confirms that only molded-case CBs that meet the criteria of item 7 l j

of the actions requested are being maintained as stored spares for future use in safety-related applications. .

b.

Sumarizes the total number manufacturer, model number, and to the extent possible the procurem,ent chain of those CBs that could not be traced to the CBM in items 1 and 4 of the actions requested. For i stalled. CBs, also identify each system in which they are/were in-installed If item 4 of the actions requested has not been completed i

i p --

NRCB 88-10 November 22, 1988 Page 5 of 7 Holders of operating licenses are requested to replace or to test at least one-half, or all if the total number is less than 75, of these installed after March CBs before startup from the first refueling outage beginning 1, 1989. The remaining CBs should be replaced or tested before1,startup March 1989. frca the second refueling outage beginning after Holders of construction permits are requested to replace or to test these installed CBs before fuel load.

6.

Information generated while performing the actions requested in items 1, 2, 3, 4, and 5 above should be documented and maintained for a period of 5 years af ter the completion of all requested actions.

7.

With the exception of actions taken in response to items 3 and 5 of the actions requested above, molded-case CBs installed in safety-related ap-plications af ter August 1,1988 should be:

a.

Manufactured by and procured from a CBM under a 10 CFR 50, Appendix B, program; or b.

Procured from a CBM or others with verifiable traceability to the CBM, in compliance with applicable industry standards, and upgraded to safety-related cation program. by the licensee or others using an acceptable dedi-The NRC encourages addressees to significantly upgrade their dedication programs through a joint industry effort to ensure their adequacy and consistency. The NRC will monitor these industry -

initiatives and if they are not sufficient or not timely, or if prob-lems with the dedication of comercial grade equipment for safety-related use continue, the NRC will take appropriate regulatory actions.

8.

Addressees that cannot meet the schedule for the actions requested above and/or the corresponding reporting requirements below, should justify to .

the NRC their proposed alternative schedule. j i

Reporting Requirements:  !

1.

All holders of operating licenses are required to provide a written report by April 1,1989, that:

a.

Confirms that only molded-case CBs that meet the criteria of item 7 of the actions requested are being maintained as stored spares for future use in safety-related applications, b.

Sumarizes the total number manufacturer, model number, and to the extent possible the procurem,ent chain of those CBs that could not be traced to the CBM in items 1 and 4 of the actions requested. For installed CBs, also identify each system in which they are/were in-stalled. if item 4 of the actions requested has not been completed i

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NRCD 88 10 November 22, 1988 Page 6 of 7 i

by April 1  ;

actions req,uested, this infomation should be updated within 3C i days of the Coesletion of item 4 to address those additional CBs that could not be traced to the CBM.

c.

Confirms that items 1, 2, 3, 4, 5, 6 and 7 of the actions requested have been completed or will be implemented as requested.

2.

All holders of operating licenses are required to submit a report that sumarizes available results of tests conducted in accordance with items 3 and 5 of the actions requested within 30 days after startup from the first and second refueling outages beginning after March 1,1989. For CBs that pass these tests, the only information required is the number.

manufacturer, model number, and to the extent possible the procurement  :

cht.in of CBs tested (sumary report fomat is acceptable). for CBs that fail these test (s), these re values of test parameter as the corresponding manu(s) at which ports the failure should as (s) occurred, indicate well the testj! (

the procurement chain. facturer, model number, and to the extent possible. l 3.

All holders of construction pemits are required to provide a written report by April 1, 1989, that:

a.

Confims that only molded-case CBs that meet the criteria of item 7 of the actions requested are being maintained as stored spares for future use in safety-related applications.

b.

Sumarizes the total number manufacturer, model number, and to the extent possible the procurem,ent chein of those CBs that could not be traced to the CBM in items 1 and 4 of the actions requested. For it. stalled CBs also identify each system in which they are/were l installed. If item 4 of the actions requested has not _been com-pleted by April 1,1989, due to the schedule for tests in item 3 {

i of the actions. requested, this infomation should be updated within 30 days of the completion of item 4 to address those additional CBs l that could not be traced to the CBM. t c.

Confirms that items 1, 3, 4, 5, 6 and 7 have been completed or will be implemented before fuel load.

4 All holders of construction pemits are required to submit a report that  !

sumarizes of the actions therequested results ofwithin tests 30 conducted days afterinfuel accordance load. Forwith items 3 and 5- i CBs that pass these tetts, the only information required is the number, manufacturer, model number, and to the extent possible, the procurement chain (sumary report fomat is tbfacceptable), for CBs that fail these test (s), the report , ,

should indicate test (s) and the values of test parameter (s) at which i

the fatlure(s) occurred, as well as the corresponding manuf3cturer, model number, and to the extent possible, the procurement chain. , i l

l

NRCB 88.10 November 22, 1988 Page 7 of 7 The written reports re R$gulatory Coanission. quired ATTH: above shall Document beDesk, Control addressed to the0.C.

Washington. U. 20555, S. Nuclear ender oath or affinnat(on under the provisions of Section 182a. Atomic Energy Act of 1954, as amende6 -In addition, a copy shall be submitted to the ap-proplate Regional Administrator. .

This requesti is evared b;r Office of Management ar.d Sudget Clearance Number 3150-0011 whteli easirn; Deeember 31, 1989. The estimated burden hour is 1000 to 10.000 manahours ter plant response including asset:.sant of these require-ments. searching data sources, testing, and analyzing the data, and preparing the required reports. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget.

Room 3208. New Executive Office Building. Washington. 0.C. 20503, and to the U.S. Nuclear Regulatory Coenission. Records and Reports Management Branch.

Of fice of Administration and Resource Management. Washington, D.C., 20555.- '

If you 1: ave any questions regarding this matter, please contact one of the technical NRC regional contacts office.lif ted below or the Regional Administrator of the appropriate

( -17 $

Charles E. Rossi. Director Division of Operational Events Assessment Of fice of Nuclear Reactor Regulation Technical Contacts: Paul Gill NRR (301)492-0811 Jaime Guillen. NRR (301)492-1170 Attachments:

1. Test Program for Molded Case Circuit Breakers

2. Definition of Tenns

3. List of Recently Issued NRC Bulletins

. &,&), ?b?

.77 .y" Attachment 1

'- NRCB 88-10 November 22, 1988 Page 1 of 4 TEST PROGRAM FOR MOLDED-CASE CIRCU!T BREAKERS 1.0 Test Program Objectives The objective of this proposed test program is to verify the reli-ability and capabilities of molded-case circuit breakers (CBs).

For the safety of personnel and others involved with the activities related to these proposed tests, appropriate safety practices, such as ANSI /HFPA 70E, " Electrical Safety Requirements for Employee Workplaces,' Part II, should be followed.

These proposed tests have been based on tests described in industry standards, such as HEMA AB-1. " Molded-Case Circuit Breakers." NEMA AB-2, " Procedures for Field Inspection and Perfomance Verification of Molded-Case Circuit Breakers Used in Comercial and Industrial Applications," UL 489 " Molded Case Circuit Breakers and Circuit Breaker Enclosures,* and HETA STD ATS-1987 " National Electrical Testing Association Acceptance Testing Specifications."

2.0 Test Procedures for CBs The following tests should be perfomed in the sequence listed. CBs j failing any of these tests should be considued unacceptable for safety-related applications.

2.1 Hechanical Test '

The CB should be operated, reset, and closed a minimum of five times, to ensure that the latching surfaces are free of any binding.

2.2 Individual Pole Resistance or M1111 volt Drop Test IRef. hETA STD~ATT~llB7 A HEMA AB-2)

The contact resistance of each pole of the CB should be measured at ambient temperature. Three readings of each pole should be taken with the CB operated without load between each reading. The average of three readings for each pole should be calculated and compared ,

with the manufacturer's contact resistance data or with those values of similar CBs from the same manufacturer. Also, the average value for each pole should be compared with the average of the other poles and the difference between the pole values should not exceed 50 percent of the lowest value; or  !

A millivolt drop test may be perfomed by applying a direct current across the closed CB contacts and measuring the voltage drop due to the contact resistance. The millivolt drop test should be perfomed at room temperature. Direct current should be applied across each i

j.N:h;hk Attachment 1 hRCB 88-10 November 22, 1988 Page 2 of 4 pole and the millivolt drop and test current recorded for each pole.

Three readings of each pole should be taken with the CB operated with-out load between each reading. The average of the three readings for each pole should be calculated and ccapared with the manufacturer's value for acceptance of the breaker.

2.3 Rated Current Hold-in Test (Ref. NEMA AB-1 & UL 489)

This test should be% conducted at 100% rated current and at an ambient air temperature of 25'C 13*C, and followed by a test at 135% rated current and at an ambient temperature of 25'C 13'C.

. ,3 Equal 100% rated currents should be applied to all poles of the CB.

The CB must not trip within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for CBs rated 50 amperes or below or within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for CBs rated over 50 amperes during this test. At the end of the 100% rated current test, the current should be increased to 135% and the CB should trip within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for CBs rated 50 amperes or below or within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for CBs rated over 50 amperes.

2.4 _0verload Test (Ref. NEMA AB-1 & UL 489)

This test consists of one operating cycle (i.e.. closing action followed by an opening action) of the CB at 600% rated current.

This test ra3y be conducted at low voltage. There should be no electrical or mechanical breakdown of the CB during this test.

2.5 Instantaneous Trip Test (Ref. NEMA AB-1 & UL 489) 2.5.1 fixed instantan_eous Setting CBs Each pole of the CB should be tested for pickup of the instantaneous uni t . Each pole must be between 75% and 125% of the instantaneous  !

trip rating. The trip time should not exceed 0.1 seconds (6 cycles).  !

2.5.2 Adjustable Instantaneous Setting CBI This test is the same as that in Section 2.5.1 except that each pole must be tested at the lowest and highest settings.

The trip value for the lowest setting should be between 75% and 125%

of the lowest setting, and the highest setting should be between 80%

and 120% of the highest setting, 2.5.3 Short-Time Trip Setting Test This test is applicable only if the CB is equipped with the short-time delay trip. This test should be conducted at an ambient air temperature of 25'C 2 3*C. The operation of the short-time delay unit should be within 90% and 125% of the overcurrent setting of the CB as shown on the manufacturer's tirt-current curves, t

3'..l . Q,, } :Q'/-it@'f N '

' "* Attachnent 1

' NRCB 88-10 November 22, 1988

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. Page 3 of 4 2.6 Time Delay Overcurrent Trip (Ref. NERA AB-2)

This test should be conducted at an ambient air temperature of' 25'C i 3'C. .. .e

..-s A current of 3005 (at low voltage) of the marked rating should be arylled to each pole of ete G. The trfy time for eseft poTe should be compared with the time shown in the CB manufacturer's time-current curves. If the test trip times obtained for each pole are not within the time band shown on the CB manufacturer's time-current curves, then the test trip must not exceed the time specified in Table 1 and the acceptance of the CBs must be evaluated with the criteria listed below:

TABLE 1 VALUES FOR OvDTURTNT TRIP TFST

{ AT 300% OF RATED CONTINUOUS CURRENT OF CIRCULI BREAKER)

]REF. NEMA AB-2)

Breaker Range of Rated Voltage Continuous Current

_Vol ts Maximum Tripping Amperes Time in Seconds 240 15-45 240 .50 50-100 70 600 15-45 600 70 50-100 125 240 110-225 240 200 250-400 300 a

600 110-225 600 250 250-400 300-600 450-600 600 350 700-1200 500 600 s 1400-2500 600 600 l 4- 3000-5000 650 Minimum Tripping Time: If the minimum tripping times are lower than indicated by the manufacturer's time-current curves for the CB under test, the CB should be retested after it has been cooled.

to 25'C. If the values obtained are still lower after retest, the coordination with upstream and downstream CB should be evaluated.

If no problem with coordination is indicated, then the CB is ac-ceptable, i

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.m- Attachment 1

W NRCB 08-10

.' Nov sber 22, 1988 Page 4 of 4 Maximum Trt'p ping Timet.

If the tripping time exceeds the maximum tripping time shcwn on the manufacturer's time-current curves but is below the time 'shown in Table 1. check the CB time against the protecticn require 1nents of the circuit (such as cable, penetration, etc.) to ensure that the CB provides the protection, as well as the coordination with upstream and downstream CBs. If the CB provides the necessary protection and coordination, then the CB is acceptable.

Maximum Allowable Time: If the tripping time of the CB exceeds the trip time shown app 1tcations. in Table 1, the breaker is unacceptable for Class IE 2.7 Dielectric Tests (Ref. NEMA AB-1 & UL-489)

I The dielectric test should be conducted at an ac test voltage of 1760 volts (80% x [2 x rated voltage + 1000 volts]), or at 2500 volts de for line (1) 1 minute to loadwithstand.

temilials with TheCB dielectric open, (2)test lineshould be conducted for to line teminals with groundCBwith closed, and (3) pole to ground with CB open, and (4) pole to CB closed.

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I'- Attachment 2 NRCB 88-10 l

.j;@'('4 November 22, 1988

....A 16 ,

E71 IT'!ON OF TERMS b

.b($ 17: .

CIRCUIT BRFAKER HANUFACT1JRER (CBM)j.id. ,

The manufacturing purchased. facility thaNetually produced the circuit breaker being VERIFIABLE TRACEABILITY Documented evidence such as a certificate of compliance that establishes traceability of purchased equipment to the CBM. If the certificate of compliance is provided by any party other than the CBM. the validity of such an certificate audit or other must be verified appropriate means.by the Itcensee or permit holder through DEDICATION PROCESS The process by which commercial grade (non-Class 1E) equipment is upgraded 1 to safety-related safety-related (Class 1E) and is thereby considered qualified for use in applications. The dedication process must include:

a.

A to technical evaluation fulfilling the to determine safety function (s). the characteristics critical b.

An acceptance process to ensure that those critical characteristics are met.

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h, I OMB-No.: 3150 0011 liRCB 8810, Supplement I h"

UNITED STATES

. NUCLEAR REGULATORY C0leIISSION

.. OTTICE OF NUCLEAR REACTOR REGULATION pv WASHINGTON, D.C. 20555 August 3, 1989

.S IIRC BULLETIN NO. 88-10, SUPPLEMENT 1: NONCONFORMING MOLDED-CASE

. CIRCUlf BREAKERS

Addressees

All holders of operating licenses or construction permits for nuclear power reactors.

.urpose:

p The purpose of this bulletin is to inform addressees that based on a prelimi-i nary review of responses to NRC Bulletin llo. 88-10, the NRC staff has deter-

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No. 88-10 and that some addressees may necdThis to take add during the preliminary review of responses. supplement also provide Description of Circumstances:

HRC Bulletin No. 88-10 was issued on November 22, 1988, to request that-ad-breakers safety functions.(CBs) purchased for use in safety-related appl In addition, the bulletin required that at:.iressees submit certain information to the NRC regarding CBS that could not be traced to the circuit breaker canufacturer (CBM).

An NRC staff review of the written reports submitted by addressees in ac-cordance addition, thewith NRC Bulletin flo. 88-10 staff has received revealed requests several for positions oncommon In specific deficien issues that were-not explicitly addressed in Bulletin N o. 88-10 analyses and positions on these issues are provided in this The NRC supplement.- t

" l During the preparation of this supplement, the NRC received comments from liational and Resources Electrical Manufacturers Association (NEMA) and the Nuclear fia Council-(NUMARC).

tests delineated in Bulletin No. 88-10, a-visual inspection,L t.or a of testing traccable CBs.and inspection, are adequate to ensure the performance of-non-the usc of nontraceable CBs from known refurbishers, rega

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w; NRCB 88-10, Supplement 1 August 3, 1989 Page 2 of 4 or not they have passed the tests delineated in Bulletin No. 80-10.

,l the NRC judgement on the adequacy of bulletin testing to justify continuedHowever,

- use of nontraceable CBs remains as stated in Bulletin No. 08 10.

NRC positions:

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.

2.

, . Visual inspection and physical examination of the CBs by the CBM is not t

considered adequate to meet the requested traceability provisions of Bulletin No. BB-10. Although visual inspection and physical examination by the CBH may provide a reasonable basis that the CDs have not been opened or altered in a substantial way, there is no reasonable assurance i that the CBs have not been previously used or subjected to service con- '

of the CBs.ditions that may have adversely affected the performance capabilities 3.

Item 4 of the actions requested in Bulletin No. 88-10 applies only to CBs that were purchased and installed after August 1, 1983. -

4.

If an addressee identifies any CBs as nontraceable during the review 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 addressces to assess the acceptability of all installed safety-related CBs that were procured under the scme purchase orders as the nantraceable CBs.

5.

In an effort to limit the number of ~ nonconforming CBs in safety-related systems, stored nontraceable spares CBs1 that were installed or are being maintained as as of August 1988, and that suc specified in Attachment 1 of, Bulletin No. 6B-10 cessfully pass all tests are considered acceptable for use only as replacements for safety-related CBs that are found to be nontraceable during the review requested by Bulletin No. 88-10. These breakers may not be used as safety-related replacements during other activities such as planned plant modifications or routine maintenance.

6.

each individual CD should be reviewed in order to estab traceability, regardless of the number of CBs. -

-7 LAll safety-related CBs from the same procurement order are considered "

traceable having provided that 1) the order was procured directly from a CBM a qualit Appendix B, 2) y assurance program in accordance with 10 CFR Part 50, 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

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NRCB 88-10, Supplement 1 August 3, 1989

' Page 3 of 4

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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 es-tablished through the review of procurement or shipping records back to the CBM. Telephone discussions with the CBM or vendor are not acceptable-for establishing a basis for traceability. Traceability to a warehcuse facility controlled by the.CBM is considered equivalent to traceability to the CBM.

Actions Recuested:

In response to the aforementioned circumstances, addressees are requested to perform the following actions within 90 days from the receipt of this bulletin:

1. Review written reports submitted to the NRC in accordance with Dulletin No. 88-10 and verify that the responses meet the bulletin provisions as clarified by this supplement.

2. Prepare and retain documentation for possible audit that indicates that item 1 of the actions requested has been performed as requested.

Reporting Requirements:

Addressees are required to provide a written report documenting any appropriate corrections to previous responses to Bulletin No. 88-10.

The NRC may conduct inspections at selected nuclear power plant sites in order I to verify that issues associated with Bulletin No. 88-10, and as clarified by this supplenent, have been adequately resolved.

The written reports required above shall be addressed to the U.S. Nuclear Regulatory Comission, ATTH: Document Control Desk, Washington, D.C. 20555, under Act oath or of 1954, as affirmation amended. under the provisions of Section 18?a, Atomic Energy priate Regional Administrator.In addition, a copy shall be submitted to the appro-This request is covered by Office of Hanagement and Budget Clearance Humber 3150-0011, which expires December 31, 1989. The estimted burden hours, which includes the original bulletin requests,.is 1,000 to 10,000 person-hours per plant response, including assessment of these requirements, searching data sources, testing, analyzing the data, and preparing the required reports.

Send coments regarding this burden estimate or any other aspect of this-collection of information, including suggestions for reducing this burden, to the Records and Reports Management Branch, Division of Information support Services, Office of Information Resources Management, U.-S. Nuclear Regulatory i Comission, Washington, D.C. 20555; and to the Paperwork Reduction Project -!

(3150-0011), Office of Management and Budget, Washington, D.C. 20503.

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NACB 88-10, Supplement 1 AuDust 3, 1989 Page 4 of 4 If you have any questions regarding this r.atter please contact one of the technical priate llRC contacts regionalItsted below or the Regional, Administrator of the appro-officb.

SoAnko (

Charles E..Rossi Director i Division of Opera,tional Events Assessment '

Office of Nuclear Reactor Regulation Technical Contacts: Uldis Potapoys, NRR (301) 492-0984 Jaime Guillen,llRR  ;

(301)4921170

Attachment:

List of Recently Issued NRC Bulletins i

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ALLEGATION FILE DOCUMENT CONTROL FORM ALLEGATION NO, RI- $9 -A- 00 71 l Data Entry Sheet (AMS Computer Printout) l Original Allegation (Technical / Safety Issues  ; H&I  ; Other Referred from: (Circle if applicable) )

NMSS / / RII / RIII / RIV / RV Reference No. NM- 9f- A"Op2,7 l~_l Saniti:ed Copy of Allegation (if applicable) l[AllegationPanelDecisions

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l_ l Referral of Allegation to: NMSS / NRR / RII / RIII / RIV / RV (if applicable) -

Reference No. .

1[100LCorresooncence(ifapplicable) l[] Request for 01:RI Investigation (if applicable)

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l_l Closecut of 01:RI Investigation (if applicable) l[] Acknowledgement Letter to Alleger (if necessary) <

l~l letter to Licensee (Action Chilling Effect ) (if necessary)

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l_l Update Letter to Alleger (if necessary) l Inspection Report l[l Other Closecut Documentation (NOTE:

l Closecut letter to Alleger (if name/ address available)

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l_l Closecut Memo to OAC (use if alleger is anonymous or in conjunction with closecut letter to alleger)

CONFIDENTIALITY l~_l Justification Memo from NRC Staff Member Who Granted Confidentiality

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l_l Signed Confidentiality Agreement-

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l_l Cover Placed on File and Stamped Appropriately CLOSE00T REVIE' FOR COMPLETENESS / ACCURACY

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AOC

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~~ 3 l4-Oate 8 REGION I FORM 309 (August 1989)

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