ML20205G231
| ML20205G231 | |
| Person / Time | |
|---|---|
| Issue date: | 10/13/1988 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Lainas G Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8810280216 | |
| Download: ML20205G231 (19) | |
Text
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October 13, 1988 HEMORANDUM FOR:
Gus. C. Lainas, Assistant Director for Region II Division of Reactor Projects - I/II THRU:
David B. Matthews, Director Project Directorate II-3 Division of Redctor Projects - I/II FRON:
Janws C. Stone Project Manager Project Directorate II-3 Division of Reactor Projects - I/II On Wednesday, October 5,1988, NRR managesent and staff set with meshers of NUMARC to exchange information in regard to substandard electrical equipment issues. A sumanary of this meeting and a list of attendees is unclosed for f
your information. Also, a copy of the latest draft bulletin is enclosed; although it was not distributed during the meeting, it was discussed.
Original Signed By James C. Stone, Project Manager l
Project Directorate II-3 l
Division of Reactor Projects - I/II i
Enclosure f
i 1.
Meeting Susanary 1
2.
1.ist of Attendees 3.
Draft Bulletin CC:
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10/p/88 10/g/88 9T i
w DISTRIBUTION FOR SUBSTANDARD ELECTRICAL EQUIPMENT MEMORANDUM DATED: October 13, 1988 Centrele F1le PDR PDII-3 Reading J. Taylor 17-G-13 P. Gill 8-D-20
- n. Murley 12-G-18 D. Basdekas NLN344 G. Lainas 14-H-3 F. Hawkins 10-H-8
- 0. Crutchfield 13-A-2 C. Ber11nger 11-A-1 F. Miraglia 12-G-18 F. G111= spin 12-G-18 J. Sniezek 12-G-18 T. Martin 12-G-18
- 8. Grimes 9-A-2 C. Rossi 11-E-4 L. Shao 8-E-2 E. Brach 9-D-4 K. Naidu 9-D-4 F. Rosa 8-D-20 W. Lanning 11-E-22 S. Yarga 14-E-4 B. Boger 14-A-2 0, itetthews 14-H-25 M. Rood 14-H-25 J. Stone 14-H-21 OGC-WF 15-B-18 E. Jordan MNBB-3302 A. Thadani 7-E-4 H. Schechter 3-H-5 M. Rubin 7-E-4 J. Knight 8-D-20 J. Del Medico 16-G-19 S. Salomon 3-0-23 D. Muller 13-D-1 P. Shemanski 13-0-1 R. Newlin 2-G-5 K. Eccleston 14-H-3 W. Hutchison 3-E-4 E. Baker 9-D-4 S. Stein 9-A-1 F. Ccngel 10-D-4 U. Potapovs 9-D-4 J. Roe 10-H-5 W. Kane RI E. Greenman RII:
L. Rwyes RII J. Collen RIV D. Xirsch Ry T. Spets RES, NL-007 R. Bernero MNSS, 6-A-4 J. Liberman 7-H-5 S. Weiss 10-H-19 W. Haass 9-D-4 W. Bulter 14-E-21 S. Goldberg OIA, MNBB 8607 s
Summary of NRC/NUMARC Meeting on October 5.1988 Substandard Electrical Equipment On Wednesday, October 5,1988, NRR manegement ano staff met with members of NURMAC to exchange information in regard to substandard electrical equipment issues. The results are sunawrized below:
1.
NUMARC 1.
Within NUMARC the Nuclear Plant Equipment Working Group has been established with Bill Cavanaugh, President and CEO, System Energy Resource, as the chairman.
This working group is to look at the entire procurement process to address concerns in the area of mechanical and electrical equipment procurements and the dedication process.
The first meeting of the group was held on September 29, 1988, with a subsequent meeting scheduled for Occumber 1988. Frank Maraglia has been named as the NRC point of contact.
1 2.
NUMARC has obtained a sample of the Nine-Mile point circuit breakers. Some were refurbished and some had not been refurbished. NUMARC will have the breakers testea, probably by Underwriters Lab. NRC will be kept informed of test results.
3.
IN 88-46 and Supplement 1 are being reviewed by utilities and are contacting their distributors to try eno identify sources of breakers.
From their reviews some possible Part 21 issues have been identified.
4 NUMARC is attempting to get other organizations involved in the issue of substand6rd equipnent.
They will be meeting with CASE and the Nuclear Supplier Quality Assurance Committ==.
5.
NUMARC felt that the focus on replacement breakers was appropriate, however, even that would be a large burden. One utility reported 1500 purchase orders for replac=uent circuit breakers in a 3-5 year period. Another utility reported about 1000 breakers / plant were replaced in a 3-5 year period.
In order to determine end use of breakers, a manual search of the files (work orcers) would be required.
II. NRC 1.
Continuing vendor inspections have identified some additional components and utilities that received equipment from the five-corpanies identified in IN 88-46.
This information will be made available to NUMARC and the industry. Also, some information suggests that purchases made from original equipment manufacturer (OEM) distributors may not provide assurance against receipt of refurbished breakers. However, purchases from the nuclear divisions of OEMs ao provide reasonable assurance that suitable breakers have been supplied.
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-2 2.
NRChasredraftedthebulletinthatdealswithonhand(speres)and instelled breakers.
Breakers that came from OEM as IE certified are dermed to be satisfactory. The suitability of breakers bought from other sources will depend on the utilities' dedication process. For breakers used in IE applications the bulletin will ask for:
a.
A records search b.
Replace / test breaker that came from sources other than OEM and certified for 1E.
Breakers originally supplied during construction will be exempt.
c.
A joint industry progr m for 80P is acceptable.
t d.
Required testing will be specified in the bulletin and is along the lines of tests in NEMA AB-2.
3.
NUMARC was encourdged tu move forward on the generic aspects of this issue (i.e., improve procurement practices and dedication processes).
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Enclousre 2 ATTENDEES NRC/NUMARC MEETING October 5, 1988 NAME ORGANIZATION t
Jim Stone NRR/PD I-2 Bob Eaird NEMA Russ Bell NUMARC Alex Marion NUMARC 1
Bill Brach NRC-Yendor Insp Branch Faust Rosa NRC/NRR/SEL8 Paul Gill NRC/NRR/SELB IJ1 dis Pota>uvs NRC/NRR/SELB David Mattiews NRC/NRR/PD11-3 i
Demetrots Basdekes NRC/RES/RPSIB Frank Hawkins NRC/NRR/PQEB-Ken Ecclestion NRC/NRR/TA-ADRS i
Carl H. Berlinger NRC/NRR/00EA/0GCB l
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Enclocuro 3 10/1?/68 DRAFT SELB r
i UNITED STATES fiUCLEAR REGULATORY C(M4!SSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON D.C. 20555 October xx. 1988 Addressees:
All holders of operating licenses or construction permits for nuclear power reactors.
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Purpose:
l The purpose of this bulletin is to request that addressees take actions to assure that molded case circuit breakers (CBs) including CBs used with motor l
controllers which have been installed as replacements for original plant aquipment, installed during modifications, or are being maintained as stored spares comply with plant design requirements such as IEEE. Underwriters l
Laborator.v (UL), National Electrical Manufacturers Associatien (NEMA) or orig-i inal manufacturer's specifications. The scope of requested actions is limited to molded case CBs that were procured from any source without verifiable trace-l ability to the original equipment Manufacturer (OEM)I as comercial grade and l
l later upgraded to safety grade, or that were procured as safety grade but without f
verifiable traceability to OEM from a source other than the original manufacturer, items procured as safety related from OEM or fron a source other than the OEM but l
I with verifiable traceability to OEM and dedicated for safety related applications f
are excluded from the scope of this Bulletin.
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Description of Circumstances:
NRC Infomation Notice No. 88-46, "Licensee Report of Defective Refurbished Circuit Breakers," dated July 8, 1988 and its Supplerent 1, dated July 21, 1988, l
1.
refer to attachment 2 for Definitier ef Tems
10/12/B5 OPAFT SELB 2-discussed a report by Pacific Gas and Electric which indicated that the Diablo Canyon Nuclear Power Plant had been supplied 30 CBs by Anti-Theft Systems, Inc.
through a local electrical distributor. These CBs (Square D molded case, type KHL 36125) were intended for use in non-safety-grade applications at the Diablo Canyon Nuclear Power Plant. Square D Company reported that the inspection and testing of these breakers determined that the C8s were refurbished Square D Company equipment.
Furthe, Square D reported that many of the circuit breakers tested did not comply with Square D or UL specifications for all of the elec-trical tests ptrformed.
Information Notice No. 88-46 also listed several California c.ompanies that were involved in supplying surplus and possibly defective refurbished electrical equipment to the nuclear industry.
NRC Information Notice No. 88-19. "Questionable Certification of Class 1E Com-ponents" dated April 26, 1988 discussed a 10 CFR Part 21 notification, submitted on April 1,1988 by the Wolf Creek Nuclear Operating Corporation (WCNOC), which brought into question the validity of Certificates of Compliance issued by Planned Maintenance Systems, Inc. (PMS) for Class IE fuses.
In response to this notification, the NRC staff inspected PMS. Components supplied by PMS with questioncble certification included circuit breakers, fuses and relays.
These examples indicate a potential safety concern regarding electrical equip-ment supplied to ruclear power plants. The NRC is concerned that the equipment procured as being new and assumed to meet all applicable plant design recuire-ments and/or original manufacturer's specifications may, in fact, not conform to these requirements and specifications.
The actions requested in this bulletin are only related to rolded case CBS due to their widespread use and applications and the potential impact of their failure. Molded case CBs are tested and calibrated at the manufacturer's plant in accordance with recognized industry standards (UL-489-Molded Case Circuit Breakers and Circuit Breaker Enclosures and NEMA-AB1-Molded-Case Circuit Breakers).
Since molded case CBs have factory-calibrated and sealed elements, s
10/12/88 DRAFT SELB any unauthorized modification or refurbishing of the CBs jeopardize their capa-bility and reliability, as well as the manufacturer's warranty. Therefore, re-liable operation of refurbished molded case CBs installed in nuclear power plants cannot be relied upon, due to lack of assurance of unifomity of parts, materials and workmanship used in unauthorized refurbishing activities.
The NRC is concerned about refurbished CBs pure.hased as comercial grade (non.
Class 1E) for later upgrading to safety-grade (Class 1E) applications, because these CBs may not meet the minimum comercial grade standards.
In addition, the NRC is concerned about coreercial grade breakers that are upgraded to safety-grade because of observed inadequacies in the dedication process and the significant number of failures found during testing of these breakers.
In order to dedicate electrical items procured as cortreercial grade and subsequently used in safety-grade systems, the dedication process should build from the comercial grade quality, and include proper evaluation of seismic and environmental qualification, as well as confimation of critical operating parameters and functional testing as appropriate.
When CBs are upgraded to safety-grade applications, the NRC is concerned that the observed dedication pro:ess as currently used by licei. sees and others may not be adequate for properly evaluating the acceptability of the components for safety-grade service.
The safety-grade electrical equipment purchased as Class 1E from the original nanufacturer (OEM) or a corporate civision associated with the OEM is of lesser concern, since this equipment is controlled under quality assurance (QA) prograns which confor1n with Appendix B of 10 CFR 50.
The controls imposed by these QA progrates are more stringent than the controls exercised in procurerent of correr-ciel grade equiprent. While the upgrading prograns of OEM or a corporate division associated with the OEM may vary in quality, the controls exercised over the pro-L curerent and reanufacturing provide reascnable assurance that irproperly refurbished
10/12/88 DRAFT SELS l
.4 components have not been introcuced and passed through the upgrading process.
Further, the redundancy of safety systems and the in-service use of these com-ponents provide a reasonable basis for accepting installed replacement components that have been procured as safety grade from the OEM or from a corporate division associated with the OEM.
The NRC believes that the actions described in this bulletin need not extend to the electrical equipeent (Class 1E and non Class IE) originally installed, at this time. This equipment appears to have been procured during plant construction from original manufacturers with full certification. The large quantities of electrical assemblies or components procured under bid packages minimizes the possibility of small vendors doing refurbishing business having supplied original equipment.
t The actions requested in this bulletin apply only to molded case CBs procured within the last five years from the date of this bulletin for replacement for plant equipment, for plant modifications, or for maintaining as stored spares, as indicated in action item 1 below. However, the NPC investigation of this issue is not complete. A supplement to the bulletin may be issued to include other electrical equipment or a longer review period for procurement if war-ranted by the results of the ongoing evaluation or the results of testing called for by this bulletin.
i Actions Requested t
1.
All addressees are requested to review their records of purchases for the last 5 years frem the date of this bulletin to identify the number, types and applications of rolded case CBs which have been installed as replace-
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ments for plant equipeent, installed during modifications, or are being l
l maintained as stored spares, that were:
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i 10/12/8B DRAFT SCLB 5-a.
procured from any source as coccercial grade without verifiable traceability to OEM cnd later upgraded for safety rciated applica-tion or b.
procured as safety related from any source other than OEM without verifiable traceability to OEM.
This review should be completed by February 1, 1989, 2.
All holders of operating licenses that identify installed CBs per item 1 above are requested to replace these CBs with fully qualified canponents, or to test (and replace failed components) in accordance with the test program described in Attachment 1.
The replacement or testing program, whichever is selected, should be completed prior to startup after the second refueling outage after March 1,1989 with 1/2 but no less than a total of 50 of the identified CBs replaced or tested at each refueling shutdown after March 1989 (for all holders of cps, the C8 replacement or testing should be completed prior to fuel load). Within 30 days of the identification of the location of suspect breakers, but no later faan March 1, 1989, holders of operating licenses should complete a justift-cation for continued operations (JCO) for the interim period until such time that the suspect CBs are replaced or tested in accordance with the testing program described in attachrent 1.
3.
All addressees that identify stored spare CBs per item 1 above are requested to take appropriato actions innediately to ensure that these CBs are not used for safety-grade service until they have been tested in accordance with the testing program describet in attachment 1.
4 All addressees are recuested to develop a program for non-safety-grade colded case CBs which have been installed as replacements for plant
10/12/88 CRAFT SELB equipment, installed during modifications, or are being maintained as stored spares, that were not procured from the original manufacturers or whose original source has not been determined, to assure that they are suitable for the intended service. A joint industry program which attains this objective is encouraged.
5.
Infomation generated during the completion of items 1,2,3 and 4 above shall be documented and maintained for possible NRC audit.
6.
Molded case CBs installed after the date of this Bulletin in safety related applications should be:
a.
manufactured by and procur6d from an OEM under a 10 CFr. 50 Apptndix B program; or b,
procured from an OEM or others with verifiable traceability to the OEM, meeting applicable industry standards and upgraded to Class 1E by the licensee or others using tests equivalent to those of Attach-ment 1.
However, it should be noted that Attachment I does not ad-dress seismic or environmental qualification requirements and that this would require additional testing or analysis based on plant-specific considerations.
Repor_ ting Rtquirements:
1.
All holders of operating licenses are required by March 1, 1989 to provide a written report that:
a.
confirms that no molded case CBs have been procured or upgraded as described in action ittm 1, or forwards the infcmation described in action item 1.
10/12/88 DRAFT SELB 7
b, confims that the CB replacement or testing actions requested in action item 2 have been completed, or confims that the schedule iri action item 2 will be adhered tc. and confims that a justi-fication for continued operation hes been completed and is being retained for possible NRC audit, c.
confirms action item 3 has been completed, d.
confims action item 6 will be followed.
i e,
reports the final results of and all conclusions of trssts conducted in response to items 2 and 3 above in accordance with attachment 1 within 30 days of such tests.
2.
All holders of construction pemits are required by March 1.1989 to provide a written report that:
a, confims that no molded case CBs have been procured or upgraded as described in action item 1. or forwards the infomation described in action item 1.
b, confirms that the CB and MC replacement or testing actions requested j
in action item 2 will be completed prior to fuel load.
j c.
confirms action item 3 his been coepleted.
d.
confirms action item 6 will be followed.
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e, reports the final results and conclusions of tests conducted in I
response to items 2 and 3 above in acccrdance with attachment I within 30 days of such tests.
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10/12/88 DRAFT SELB 8-3.
All addressees are required to provide a report, within 180 days of receipt of this bulletin, that confirms that no molded case CBs have been procured for non-safety-grade applications as described in action item 4, or that describes the program requested under action item 4 The written reports required above shall be addressed to the L/. S. Nuclear Regulatory Comission. ATTN: Document Control Desk Washington, D.C. 20555, under oath or affirmation under the provisions of Section 1824, Atomic Energy Act of 1954, as amended.
In addition, a copy shall be submitted to the i
appropriate Regional Administrator.
This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989.
The estimated average burden hour is 1000 man-hours per plant response, including assessment of these require-rents, searching data sources, gathering and analyzing the data, and preparing l
the required reports.
Coments on the accuracy of this estimate and suggestions f
to reduce the burden may be directed to t t Office of Management and Budget, Room 3208, New Executive Office Building,..ashington. 0.C., 20503, and to the i
U.S. Nuclear Regulatory Comission, Records and Reports Management Branch. Office of Administration and Resource Management, Washington 0.C., 20555, i
Charles E. Rossi Director Division of Operatonal Events Assessment Office of Nuclear Reactor Regulation l
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Technical Contacts:
Paul Gill, NRR (301) 492-0811 l
Jaime Guillen, NRR (301) 492-1170 Attachments:
1.
Test program for Folded Case Circuit Breakers and Noter Controllers 2.
Definitions of Terrs
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List of Recently Issued NRC Bulletins
t ATTACHMENT 1 TEST PROGRAM FOR MOLDE0-CASE CIRCUIT BREAr.ERS 1.0 Test Program Objectives The objective of this proposed test program is to verify the performance of molded-case circuit breakers (CBs) that were procured as commercial grade (non-class 1E) and later upgraded to safety grade (class IE), or that were procured as safety grade in a manner described in Bulletin No.
88-XX such as to bring into question their safety grade classification.
All such CBs that are installed in class 1E systems should be tested in l
accordance with this program. Also, all such CBs that are in storage f
should be tested in accordance with this program before they are installed in class 1E systems.
The purpose of the proposed tests is to provide a reasonable assurance that the testea CBs are suitable for the intended service.
A minimum of one-half (1/2)ofsuchCBsbutnotlessthan50CBs(pro-rated)shouldbe j
tested every refueling outage until all CBs have been tested as outlined in this program.
For the safety of personnel and others involved with the activities re-lated to these proposed tests, appropriate safety practices (such as AN5!/NFPA 70E, Part II) should be followed.
The below listed tests proposed for the CBs have been based on tests described in industry standards, such as NERA AB-1 (Molded Case Circuit Breakers), NEMA AB-2 (Procedures for Field Inspection and Performance Verification of Molded Case Circuit Breakers Used in Commercial and Industrial Applications), and UL 489 (Molded Case Circuit Breakurs and j
Circuit Breaker Enclosures).
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2.0 Test Procedures for CBs The following tests should be perforred in the order of sequence listed.
2.1 Mechanic,a1 Test The CB should be tripped, reset and closed a minimum of five times to insure that the latching surfaces are free of any binding.
2.2 Time-Overcurrent Trip Test 2.2.1 Rated Current Hold-in Test This test should be conducted at 1005 rated current and at an ambient air temperature of 40'c 2 3'c, or at 1351 rated current and at an ambient temperature of 25'c 2 3'c.
t Equal current should be applied to all poles of the CB; and CB must not trip within I hour for CBs rated 50 amperes or below and within 2 heurs for CBs rated over 50 arperes.
l 2.2.2 Overload test i
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This test consists of 1 operating cycle (i.e., closing action followed by an opening action) of the CB at 6005 rated current. There shall l
be no electrical or mechanical breakdown of the CB during this test.
I 2.2.3 Tire Celay Overcurrent Trip i
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This test should be conducted at an ambient air temperature of f
25 degrees c : 3* degrees c.
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3-A current of 300 percent of the marked rating should be applied to each pole of the CB. The trip time for each pole should be com-pared against the time shown in the CB manufacturer's time-cu.* rent curves.
If the test trip timas obtained for each pole are nct with-in the time band shown or, the CB manufacturer's time-current curves, then the test trio must not exceed the time specified in table 1 and the acceptance of CB evaluated with the criteria as listed below:
TABLE 1 VALUES FOR OV UCU RfNT TRIP TEST (AT 300% OF RATED CONTINUOU5 CURRENT OF CIRCUIT BREAKER)
(REF. NEMA AB-2)
Breaker Range of Rated Voltage Continuous Current Maximum Trip Time Volts Amperes In Seconds 240 15-45 50 240 50-100 70 600 15-45 70 600 50-100 125 240 110-225 200 240 250-500 300 600 110-225 250 600 250-400 300 600 450 600 350 600 700-1200 500 600 1400-2500 600 COO 3000-E000 650 Minimum trip times:
If the minimum tripping times are lower than indi-cated by the manufacturer's time-current curves for the breaker under test. the breaker 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 breakers should be evaluated.
If no mis-ecordination is indicated, then the CB is acceptable.
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t Maxtr um tripping time?
If the tripping time exceeds the maximum tripping time shown on the manufacturer's time-current curves but is below the time shown in table 1 above, check the breaker time against the protection re-quirements of the circuit (such as cable, penetration, etc.) to ensure that the CB provides the protection, as well as the coordination with up-stream and downstream C8s.
If the CB provides the necessary protection f
and ceordination, then the CB is acceptable, Maximum allowable time:
If the tripping time of the CB exceeds the trip time shown in the table 1 above, the breaker is unacceptable for class 1E
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applications.
2.3 Instantaneous Trio Test i
j 2.3.1 Fixed Ins,tantaneous Setting CBs i
Each pole of the CB should be tested for pickup of the instan-l taneous unit. The average of the three readings for each pole riust I
i be between 80s and 120% of the instantaneous trip setting as shown i
on the manufacturer time-current curves. The trip time should not
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exceed.05 seconds (3 cycles).
P 2.3.2 Adjustable Instantaneous Setting CBs l
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Same as 2.3.1 except that each pole must be tested 66 the lowest
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and highest setting.
The average trip value for the lowest setting should be between 75 i
percent and 125 percent, and the highest setting should be between
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80 percent and 120 percent of the setting value shown on the j
j manufacturer's tire-current curves.
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5-2.3.3 Short time trip setting test i
l This test is applicable only if the C8 is equipped with the short-time delay trio. This test should be conductat at en ambient air
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i 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 L
the CB as shown on the manufacturer's time current curves.
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2.4 Individual Pole Resistance Test I
The contact resistance of each pole of the CB should be measured at ambient temperature. The average of 3 readings for each pole shov1d be calculated and compared with the manufacturer's data or with those f
of similar CBs of the same manufacturer. Also, the average reading of
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each pole should be compared with each other and the difference between l
th? pole readings should not exceed fifty percent.
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2.5 Dielectric Tests The dielectric test should be conducted at ar, ac test voltage of 1760 volts (0.8 x (2 x Rated Voltage + 1000 volts]) or 2500 '.olts DC for j
l 1 minute withstand. The dielectric test should be conducted for l
(1) line to load terminals with C8 open, (2) line to line terininals with 46 closed, and (3) pole to ground with C8 open and closed.
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ATTACHMENT 2
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CEFIN: TION OF TERMS 1.
ORIGINAL EQUIPPENT MANUFACTURER (OEM):
The manufacturing facility which actually produced the equipment being purchased.
2.
VERIFIABLE TRACEABILITY:
Documented evidence such as certificate of compliance that establishes traceability of purchased equ pment to the OEM.
If the certificate of compliance is provided by any party other than the OEM, the validity of such certificate must be verified by the purchaser through an audit or other appropriate means.
3.
DEDICATION PROCESS:
The process by which commercial grade (non-Class 1E) equipment is upgraded to safety-grade (Class 1E) and is thereby considered qualified for use in nuclear safety related applications.
The dedication process must include:
a)
A technical evaluation to determine the characteristics critical to fulfilling the safety function (s) and b)
An acceptance process to assure that those critical characteristics are met.
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