ML20206C127
| ML20206C127 | |
| Person / Time | |
|---|---|
| Issue date: | 11/08/1988 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Lainas G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20206C132 | List: |
| References | |
| NUDOCS 8811160113 | |
| Download: ML20206C127 (11) | |
Text
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e' Novcabar 8, 1988 i
!!EMORANDUli FOR:
Gus C. Lainas, Assistant Director for Region 11 Division of Reactor Projects - I/II THRU:
David B. Matthews, Director Prvject Directorate 11-3 Division of Reactor Projects - I/II FROM:
Jares C. Stone, Project Manager f'roject Directorate 11-3 Jivision of Reactor Projects - 1/11 SUBS'ECT:
MEETIt'G BETWEEN NRR AND NUl9RC TO EXCHANGE INFORMATION ON SUBSTANDARD ELECTRICAL L UIPMENT 4
C On Monday, October 31, 1988, NPR man r xent and staff met with members of NUMARC
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to exchange information in regard r', substandard electrical equipment issues. A sumary of this meeting and a 01:t of attendees is enclosed for your information, llandouts and : letter that ere distributed during the meeting are also enclosed.
In addition, copies of two letters to the NRC from Underwriters Laboratories and the National Electrical Manufactures Association providing e.oenents on the draft bulletin are enclosed. These letters were not distributed at the meeting but were discussed.
Original Signed By:
James C. Stone, Project !!anager Project Directorate II-3 Division of Reactor Projects - 1/11 Office of Nuclear Regulation Enclosure 1.
l'eeting Sumary 2.
List of Attendees 3.
NUMARC Connents on Draf t Bulletin (Draf t) 4.
Letter from NEMA to National Association of Electrical Distributiers 5.
Letter from UL to NRC 6.
Letter frcm HEltA to NRC l
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DiSTPIBUTIDH FOR SUBSTANDARD ELECTRICAL EQUIP!!ENT MEMORANDUM DATED: November 8, 1988 Central! File PDR P011-3 Reading J. Taylor 17-G-13 P. Gill 8-D-20 T. Furley 12-G-18 D. Basdukas NLH344 G. Lainas 14-H-3 F. Hawkins 10-H-8 D. Crutchfield 13-A-2 C. Berlinger 11-A-1 F. Miraglia 12-G-18 H. Hiller Rlll F. Gillespie 12-G-18 J. Snierek 12-G-18 T. Martin 12-G-18 B. 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 8-0-20 W. Lanning 11-E-22 S. Varga 14-E-4 B. Boger 14-A-2 D. Matthews 14-H-25 H. Rood 14-H-2E J. Stone 14-H-21 OGC-WF 15-B-18 E. Jordan MNBB-3302 A. Thadani 7-E-4 H. Schechter 3-H-5 H. Rubin 7-E-4 J. Knight B-D-20 t
J. Del Medico 16-G-19 S. Salomon 3-D-23 D. Huller 13-D-1 P. Shemonski 13-D-1 R. Newlin 2-G-5 K. Eccleston 14-H-3 i
W. Hutchison 3-E-4 l
E. Baker 9-D-4
- 5. Stein 9-A-1 F. Congel 10-D-4 U. Potapovs 9-D-4 J. Roe 10-H-5 W. Kane R1 E. Greenren R!li L. Reyes Ri!
J. Collen RIV D. Kirsch RV l
T. Spets RES. hl-007
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R. Barnero HNSS. 6-A-4 J. Liberman 7-H-5 S. Weiss 10-H-19 W. Haass 9-D-4 W. Butter 14-E-21 S. Goldberg OIA. P"BB 8E07
Summary of NRC/NUMARC Meeting on October 31, 1988 Substandard Electrical Equipment i
On Honday, October 31, 1988, NRR management and staff met with members of l
NUHARC to exchange information ir regard to substandard electrical equipment I
issues. The results are suncarized below:
A.
NUMARC presented their draft comments (Enclosure 3) on the latest draft l
of the bulletin on substandard electrical equipment. Their comments were discussed in detail. Based on those discussions, NUMARC agread to review their comments and formally submit the revised comments to F. Haraglia, NRC by N;vember 4,1988.
NUMARC is developing an approach to dedication of ;ommerical grade components.
They expect to present their proposal to the NUMARC Executive Conmittee and I
Board of Directors on November 14, 1988. After approval, the program will be sent to the utilities. Thty expect to have the program developed early 1989.
l B.
A letter that the National Electrical Manufacturers Association sent to the National Association of Electrical Distributors (Enclosure 4) was distributed.
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i This letter recommends that distributors review their stocks to determine if they have purchased any circuit breakers from sources other than the original l
equipment manufacturer (OEM). Further, they recommend that customets be advised if they received equipment that was purchased, by the distributor, from sources other than the OEH.
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List of Attendees Name Organization Jim Stone flRC/flRR/DRP!/II/PDI-2 Paul (iill NRC/NRR/SELB Bob Baird HEMA Russ Bell NUttARC Alex Harion ItVMARC Jaime Guillen NRC/NRR/CGCB Ben B. Hayes 0.1.
Faust Rosa NRC/NRR/SELB Ashok Thadani NRR George Hubbard Nh0/OSP Ken Hooks flRC/NRR/DLPQ Jqhn Jankovich i;RC/tiRR/DOEA Uldis Potapovs IIRC/NRR/DRIS Bill Brach NRC/NRR/DRIS/VIB Hargo Barron STS. Inc.
David B. itatthews tiRC/NRR James Bradford Eechtel Brian Grtres
!!RR/DRIS/flRC P
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Enclocuro 3 s
fiUMARC COMMENTS Oft DRAFT BULLETIfi The Ad Hoc Advisory Committee (AHAC) reviewed the document at the 10/14/88 meeting and developed various comments as noted below, p.1 PURPOSE Second line: Delete, "... including CBs used with motor controllers..."
[It is not clear as to what is intended by this phrase.
The purpose of the bulletin focuses on molded case circuit breakers and the noted phrase appears redundant.
Suggest this phrase be deleted.)
Fifth line:
Delete the word "plant" and replace with "utility specific", so now this reads, "... spares comply with utility specific design requirements..."
[As noted in our co = ents to the earlier draft, utilities or their agents specify requirements in procurement documents as necessary to satisfy the design application of Class IE components.
These requirements may reference any combination of industry standards such as IEEE, fiEMA, UL, etc. that are needed to establish design requirements are met.]
p.2 First paragraph. seventh line, sentence beginning " Further,...", replace the word "...many..."
with "...several...".
[lt is our understanding that several of the suspect circuit breakers were actually tested. Additionally, we reported, as the result of surveying the utilities identified in IN 88-46 and its supplement, a small number of CBs (approximately 12 out of 200) that were upgraded to SR.
Although we acknowledge this issue presents a potential problem, there is uncertainty based upon the data presented thusfar that a generic safety concern exists.)
Delete the second paragraph.
[We clearly noted during previous discussions that the concerns detailed in Ifi 88-19 represent records falsification only, not component refurbishment.
Furthermore, we noted the potential concerns weie not of a generic nature to warrant action via a bulletin.)
Third paragraph:
Suggest the first sentence begin, " This example indicates a...".
(With the deletion of references to Ill 88-19, only one example supports tne potential problem. Of course, if there exist additional examples then, they clearly should be noted to provide an appropriate basis for the bulletin.]
Second sentence, fourth line, delete "...and/or original manufacturer's specifications..".
(See coments p. 1 on Purpose.)
Last line, delete "...and specifications."
(See co ment p. I on Purpose.]
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Fourth paragraph:
Second line, delete the phrase, "...and the potential impact of their failure." so the second line reads, "...due to their wide spread use and applications."
(The potential impact of the failure of a refurbished molded case CB has yet to be established based on the evidence provided. Once a safety related application is found then the specific functional characteristic needs to be assessed, it may be that for certain applications, the CB must retain a SR function similar to that of a switch, ie, no trip or isolating characteristic is required.
For other applications, the tripping function may be necessary.
Regardless, these assessments will define safety impact once suspect CBs are identified.)
Third line, suggest a clarification regarding CB testing.
[It is our understanding from conversations with representatives of NEMA and VL that prototype testing and sample verification testing is conducted by manu'acturers and UL.
All CBs produced are not tested to the noted standards because certain tests are destructive.)
p.3 First paragraph:
First line, add the word "could", between
"..C8..." and "... jeopardize..."
so the line reads "...any unauthorized modification or refurbishing of the CBs could jeopardize their...".
[The performance capability of refurbished CBs can be established by inspection and testing.
Until this is established, any speculation of CB capability and reliability is premature.)
Second line, delete "...as well as the manufacturer's warranty." so that the sentence ends with the word "... reliability."
[ Utilities do not include warranties as part of safety related design considerations.
Violation of a warranty does not impact typical design considerations.)
Fourth line, suggest changing "...cannot be relied upon..."
to "...needs to be verified...".
[As noted N rlier, inspection and testing should be conducted to ensure the refurbished CBs can perform as designed.]
Second paragraph, suggest it be deleted.
[It is not clear as to the reason for noting, "... observed inadequacies in the dedication process..." without presenting examples of such inadequacies that in turn support action via a bulletin.
It is our understanding that failures, as the result of utility testing, identified many of the improperly refurbished CBs.
Absent specific examples of inadequacies, we believe discussion of the dedication process inappropriate.
However, the NUMARC Nuclear Plant Equipment Procurement Working Group is reviewing EPRI NP-5652, Guideline for the Utilization of Co-ercial Grade items in Nuclear Safety Related Aeolications (NCIG-Qll, issued March, 1988, to assess its use by a broader segment of the nuclear utility industry.
We belive any action in the area of dedication i
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programs prior to assessing industry impact would be counter productive to our efforts in resolving the larger issue of the impact of fraud and product misrepresentation to the overall procurement process.
Therefore, we suggest this paragraph be deleted.)
- p. 4 First paragraph At the end of the sentence ending at the first line add a new sentence, "Testing as part of utility dedication programs has also prevented improperly refurbished CBs from being introduced into safety related service."
(Most of the data presented thusfar suggest that for the most part utility dedication programs are an effective screen for the improperly refurbished CBs.
However, additional inspection and testing may be warranted to further minimize any influx of suspect CBs.)
Second paragraph:
Second line, delete the terms "..and non-Class IE..." and "...at this time."
(As noted in our comments to the previous draft bulletin, we suggest the discussion of non Class IE and non safety related application be removed from the bulletin since the industry is undertaking an effort to resolve concerns in this arena.)
Sixth line, clarify the reference to "...small vendors...".
[There is a concern that legitimate businesses (non OEM) may be implicated without cause.
There are businesses that legitimately refurbish products for utilities under an Appendix B program.)
Fourth line, suggest the remainder of the paragraph be deleted beginning with the sentence, "However, the NRC investigation...".
(We believe that with the proper focus of this bulletin on safety related applications combined with the proposed industry initiative, the confidence level in utility procurement of molded case circuit breakers will be established. As noted earlier current utility dedication programs are screening suspect breakers and additional procurement controls will evolve to minimize the impact of improperly refurbished CBs. Suggesting a supplement seems inappropriate based upon the data presented thusfar and the industry commitment to resolve this issue.
We further suggest the results of testing as a process for establishing the performance capability of a CB is appropriate, but not as a basis for a supplement tc this bulletin.
As noted earlier, the specific evidence of a general wide spread infiltration of improperly refurbished CBs has not been established.
We do not believe that after utilities review their procurement activities such a widespread distribution will be established.)
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f ACTIONS REQUESTED p.5 Item Ib. Please clarify the intent of this action.
(Recognizing that many non OEM suppliers have an acceptable Appendix B program, it is not clear as to the purpose for verifying traceability as requested.)
Item 2 e
Second line, replace the words "... fully qualified..." with the word "acceptable".
(The use of the term "fully qualified" suggests this is a qualification issue within the context of 10CFR50.49.
Based on discussions with the RC Staff it is our understanding that there is no evidence to suggest this is the case.)
'enth line, add the word "installed" before the word "... location..."
Jo that the line now reads, "... identification of the installed location of...".
(This is suggested for a proper focus on installed CBs as opposed to those located in a warehouse or a holding area.]
Eleventh line, suggest a clarification for the requirement that utilities complete a JC0 for the interim until suspect CBs are replaced or tested.
[We believe this needs to be raconsidered since it suggests that suspect breakers are those which are not traceable to the OEM and a JC0 is required once a location is established.
It is not clear as to what improvement in safety wouid be had by this action as suggested. We believe a JC0 is appropriate after the utility establishes a CB in safety "91ated service in the plant and subsequent inspection or testing indicates the breaker inct.ptble of performing its required safety related function.]
4 Item 4, suggest this item be deleted in its entirety.
(The action requested by this item is inconsistent with the stated purpose of the bulletin.
Furthermore, NUMARC has agreed to pursue a proposed industry initiative that will address concerns of improperly refurbished molded case CBs in non safety related applications.]
p.6 Item 5, delete the reference to item 4.
(See discussion above, p. 5, item 4.]
i Item 6b, third line after the word "...using..." add the following "...an acceptable dedication program." and (elete the remainder of the sentence as well as the balance of the paragraph.
(We believe there are dedication programs that are effective in screening improperly refurbished molded case CBs. These programs are currently being implemented by both utilities and other organizations, not necestarily the OEM. We believe that a combined inspection / testing process supported by manufacturers will provide reasonable assurance of CB performance capability. To that end we are developing such a process and propose it as an alternative to Attachment 1.
As noted earlier we t
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are not aware of any indication that this is a qualification issue and suggest that reference to seismic and environmental requirements is inappropriate. We believe that utilies upon discovery of CBs that must meet these requirements will do so in accordance with the regulatory guidance currently available.)
REPORTING REQVIREMENTS Item la, clarify what information is required.
(Referring to p.4, Actions Requested, Item 1, the suggestion is to identify numbers, types and application of molded case CDs.
It 15 not clear as to wha'. benefit this information offers.]
p.7 Item Ib, clarify.
(Referring to p.5. Actions Requested, Iter 2, it is not clear what benefit this information offers.)
Item le, delete in its entirety and add "status reports of inspections or test conducted in response to item 2 above shall be provided on a quarterly basis after Barch 1,1999."
(We believe this an appropriate reporting schedule for item 2 which addresses the installed location, specific safety related ap)lication, inspection / testing, and JC0 if necessary.
It is not clear w1at improvement in safety is achieved by reporting specific details on C9s found in the warehouse which will not be used in the plant.
It is sufficient to report inspections of stock safety related CBs have been completed.)
Item 2, delete the entire section.
(This reporting requirement for holders of construction permits is inconsistent with the focus of the draft bulletin, replacement molded case CBs as noted on p. 3, third paragraph.
It is our belief these plants order new equipment directly from tiie OEM. Unless the NRC has evidence to the contrary, we believe this section should be deleted.)
l p.8 Item 3, delete in its entirety.
(See discussion p.5, item 4)
Third paragraph.
[We believe the estimate of burden is low by as much as an order of magnitude since it does not irclude testing or replacement actions.
Since the bulletin is struttured for utility actions on the basis of plant units, the estimate should be on a plant unit basis.
Furthermore, l
we believe for some utilities, which do not have computerized management systems with retrieval / reporting capability, the actions required t'y this bulletin may be comparable in resource commitment as that required by Bulletin 88-05.
This seems likely since the assum) tion in this draft bulletin is that all replacemerit molded case circuit
)reakers are suspect and traceability to OEM must be verified. Absent this verification.
then replacement or testing is required. The efforts anticipated by utilities in implementing the requirements of the draft bulletin as currently written are extensive.)
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Enclocuro 4 National Electrical ttanufacturers Assocializi
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2101 L Street N W SJe 300
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J Washington. D C 20037 (202) 457 8400 Te'ex 904077 NE',M WSH October 24, 1988 Mr. Marvin Schylling President National Association of Electrical Distributors 28 Cross Street Norwalk, CT 06851
SUBJECT:
REBUILT CIRCUIT BREAKTEg Daar Mr. Schylling:
As you know, recent investigations by the Nuclear Regulatory Connission ("NRC") and nolded case circu.t breaker manufacturers have brought forward evidence that a number of electrical companies have been selling used, rebuilt, and reconditioned circuit breakers of various manufacturers without disclosing that they were not new.
Often that condition of the breakers is concealed by the use of counterfnit labels that mirror those applied to the breakers by their original manufacturer.
It appears taat many electrical distributors have purchased such breakers and, however unwittingly, have resold then to third parties.
The abovc investigations have also revealed that, at least in many instances, the used and rebuilt breakers that are being marketed as new fail to noot origine,1 perfernance specifications established by the manufacturer and by Ur..'e rwr iters ' Labora-tories. In sore instances, the breakers nav nerforn far below such standards and, for this reason or.other reasons, rav prosent serious health and safety concerns t in view of the above evidence, we strongly reconnend that all electrical distributors review their stocks and purchase and sales records to determine whether they have purchased any circui*. breakers as new from any source other than the original manuracturer.
Any breaker that can not be traced directly to the original manufacturer may be a used, rebuilt, or remanu-factured product, even though the brea':er appears new.
NEMA also believes that it is essential that individuals or conpanies that have purchased such breakers fron electrical distributors be advised of the above facts and of the potential hazard to their safety and asks that distributors pass thd.s information on to their customers.
NEMA's 1988 Annual Meeting
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Pesofgh, Pennsyi.asa f((#7#kt No.embe' 13-16
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i We hope that you will arrange to have this information disseminated to your members as soon as possible.
If you have i
any questions regarding the above matters, or if I may be of any further assistance, please give me a call, i
Sincerely,
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Robert W. Baird I
Divisi,n Staff Executive o
cc Task Force on Rebuilt I
circuit Breakers 5-AB, Molded Case Breaker Section i
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