ML20236B996
| ML20236B996 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 03/16/1989 |
| From: | Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| A07666, A7666, IEB-88-010, IEB-88-10, TAC-71319, TAC-71320, NUDOCS 8903210421 | |
| Download: ML20236B996 (14) | |
Text
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NORTHEAST UTILrrtES General Offices
- Selden Street, Berlin Connecticut
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acoI E P.O. BOX 270 v
2 3) 665-5 00 March 16, 1989 Docket Nos. 50-213 50-245 50-336 50-423 A07666 Re:
NRC Bulletin No. 88-10 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555
Reference:
(1) NRC Bulletin No. 88-10: Nonconforming Molded Case Circuit Breakers, Dated November 22, 1988.
Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3 NRC Bulletin No. 88-10 Nonconforming Molded Case Circuit Breakers (TAC 71319 and 71320)
Reference (1) requested licensees to determine if any molded case circuit in certain circumstances, breakers held as safety-related spares, or, installed in safety-related systems, could have been potentially refurbished.
If documentation is not available tracing the circuit breaker back to the circuit breaker manufacturer (CBM), then the circuit breaker is suspect and must be tested or replaced.
This letter is being submitted in response to the Reference (1) requirement for a written report by April 1, 1989. The reporting requirements and Connecticut Yankee Atomic Power Company's (CYAPCO) and Northeast Nuclear Energy Company's (NNECO) responses follow:
the criteria of Item 7 of the Confirm that only molded case CBs that meet A.
actions requested are being maintained as stored spares for future use in safety-related applications.
' Item 7 - Vith the exception of actions taken in response to Items 3 and 5 of tfie actions requested, molded case CBs installed in safety-related applications after August 1, 1988 should be:
Manufactured by and procured from a CBM under a 10 CFR 50, Appendix a.
B, program; or 1
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8903210421 890316 PDR ADOCK 05000213 0
U'SNRC A07666/P ga 2 March 16, 1989 b.
Procured from a CBM or others with verifiable traceability to the CBM, in compliance with applicable industry standards, and upgraded to safety-related by the licensee or others using an acceptable dedication program. The NRC encourages addressees to significantly I
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 problems with the dedication of commercial grade equipment for safety-related use continue, the NRC will take appropriate regulatory actions.
Response
On December 8, 1988, the storerooms for our four (4) nuclear power plants were directed to only issue molded case circuit breakers, for safety-related applications, which had documentation tracing them to a CBM.
All molded case circuit breakers in stock for safety-related use which are not traceable, have been tagged to prevent inadvertent use.
Site engineering representatives dealing with this Bulletin were authorized to make the exceptions mentioned in Item 7.
Safety-related and nonsafety-related molded case circuit breakers purchased after December 8, 1988 require traceability to the CBM (safety-related CBs purchased between August 1 and December 8, 1988 vere tracked under Items 1 and 4).
Dedication of commercial grade breakers was directed to be done by testing in accordance with Reference (1) until a new corporate level procedure becomes effective. This procedure, approved on February 3, 1989, closely follows EPRI NP-5652, " Guideline for the Utilization of Commercial Grade Items in Nuclear Safety-Related Applications."
This guidance was later modified to allow installation of a non-traceable breaker which passes the Reference (1) test program in a safety-related application. This may only be done if a breaker fails in-service and no traceable breakers are available to replace it.
A No'1conformance Report will be generated in these cases to justify and track such usage until the breaker is replaced with a traceable one at the first opportunity.
This provision has not yet been used at either Haddam Neck or Millstone Station.
B.
Summarize the total number, manufacturer, model number, and to the extent possible the procurement 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/ vere installed.
If Item 4 of the actions requested has not been completed by April 1, 1989, due to the schedule for tests in Item 3 of the actions requested, this information should be updated within 30 days of the completion of Item 4 to address those additional CBs that could not be traced to the CBM.
Response
This information is contained in Attachment (1).
Details of our actions in response to Items 1 and 4 are provided below.
_a
bSNRC A07666/Page 3 March 16, 1989 C.
Confirm that Items 1, 2, 3, 4, 5, 6 and 7 of the actions requested have been completed or vill be implemented as requested.
Item 1 - All addressees are requested to perform the following review by MarcF 1, 1989:
Identify all molded case CBs purchased prior to August 1, 1988, that a.
are being maintained as stored spares for safety-related (Class 1E) applications; this includes CDs purchased from a CBM or from any other source. If the number of these stored spare CBs is less than 50 at a nuclear plant site, then randomly select CBs purchased between August 1, 1983 and August 1, 1988 that have been installed in safety-related applications as replacements or modifications to form a minimum sample of 50 CBs per nuclear plant site.
b.
Verify the traceability of these CBs.
Identify the number, manufacturer, model number, and to the extent c.
possible the procurement chain for all those CDs identified in (la) that cannot be traced to the CBH.
For installed CBs, also idenfity each system in which they are/ vere installed.
Response
j The Millstone varehouses have 199 such breakers in stock, the Haddam Neck varehouse has 113 such breakers in stock, and the Great Neck varehouse has 3 such breakers in stock. The Great Neck varehouse is common to both sites and stores material planned for installation under capital projects. Therefore, no installed breakers were revitsed under this Item.
In-house documentation was reviewed to determine traceability. An Item is considered traceable if documentation (i.e., certificate of Compliance or a Test Report) is available which originated from the CBM and refers directly (e.g., by serial number) to the Item.
Items which were not traceable in this way were tagged to prevent issuance.
Further reviews were done by requesting the applicable suppliers to provide this documen-tation. When available this documentation is verified either by audit or review of submitted documentation.
Many responses are still outstanding due to numerous requests from other licensees. All Items which are still being researched are considered non-traceable for the purpose of issuance from the varehouse. These are listed in Attachment 1.
Item 2 - All holders of operating licenses who identify installed 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 completion of each Item, an analysis justifying continued operation until Items 1 through 5 of the actions requested in this Bulletin have been completed.
OSNRC A07666/Page 4 March 16, 1989
- Response, See response to Item 4 below.
Item 3 - All addressees who identify 80 percent or more CBs traceable to the CHH 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-.
Any installed CBs that fail any of these. tests should be l
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-after March 1, 1989.
Holders of construction permits are requested to complete this testing program before fuel load.
l
Response
Since less than 80 percent of in-stock CBs are traceable to the CBM with information available to date, NNECO and CYAPC0 have proceeded directly to Item 4.
This decision was reached in mid-January, 1989 with NRC Staff concurrence.
Item 4 - All addresses who identify less than 80 percent of the CBs traciable to the CBM per Item 1 above or who identify a failure rate of more than 10 percent for the CBs tested per Item 3 above are requested to perform the following actions:
a.
Identify all molded case CBs that have been purchased between August 1, 1983 and August 1, 1988, and installed in safety-related applications as replacements or installed during modifications.
b.
Verify the traceability of these CBs.
i c.
Identify the number, manufacturer, model number, system in which they are/ vere installed, and to the extent possible, the procurement chain for all those CBs identified in (4a) that cannot be traced to the CBM.
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Response
There are several ways breakers could have been installed:
- 1) A safety-related breaker could have been issued from the varehouse to replace a failed breaker; 2) a commercial grade breaker could have been issued and upgraded for safety-related use; or 3) a breaker could have l
been installed as part of a plant modification.
Identification of installed Items is essentially complete, except for those installed by i
the second method.
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U'SNRC A07666/Page 5 March 16, 1989 Although records exist documenting all installations, they are not stored in a format which allows for easy retrieval when one is looking for all safety-related molded case CBs. Therefore, a priority search was used.
'Most CBs installed in the last five years were done by the first method.
All such CBs have been identified.
At Millstone Unit Nos. 1, 2, and 3, it is not (and has not been) the practice to use the second method for CBs. At Haddam Neck, the record search fer CBs installed by the second method is in progress and vill be completed during March 1989.
All~CBs installed by the third method have been identified.
In many cases, location cannot be determined without further research. This will be done if the CB is determined not to be traceable.
Traceability is determined as in Item 1.
Again, information from suppliers is still pending.
Information on breakers which have not yet been traced is included in Attachment 1.
CYAPC0 and NNECO do not consider'these CBs to be "non-traceable" at this time. They will be considered non-traceable when reasonable efforts have failed to turn up the required documentation.
Previous to receipt of Reference (1), CBs were routinely tested before installation. describes this testing.
It is CYAPCO's and NNECO's position that, for the short term, no action need be taken on installed CBs until non-traceability is determined more conclusively.
This is due to:
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- Adequate pre-installation testing of CBs
- Lov number of installed, potentially suspect, CBs (compared to the total population)
- No significant past reliability problems
- Routine surveillance testing
- Low probability of seismic events or severe electrical faults in the near future Traceability determinations are expected to be complete in time to support replacement, if required, in accordance with Item 5.
A summary report will be submitted by July 1, 1989.
Item 5 - 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 accordance with the program described in Attachment 1; 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 test program described in Attachment 1.
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 CBs before startup from the first refueling outage beginning j
after March 1, 1989. The remaining CBs should be replaced or tested before startup from the second refueling outage beginning after March 1, 1989.
USNRC A07666/Paga 6 March 16, 1989
Response
l No such breakers have been identified to date. Attachment 2 describes CYAPCO's and NNECO's test program. CYAPC0 and NNECO have taken the position that any installed safety-related molded case circuit breaker which cannot be traced to a CBM will be replaced with a traceable breaker as soon as possible, but no later than the schedule required by this Item.
Item 6 - Information generated while performing the actions requested in 1
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.
Response
NNECO and CYAPC0 vill comply with this Item, and also with the require-ment to retain all breakers identified as unacceptable stated in the V. F. Kane letter dated January 10, 1989.i i
Item 7 - Addressed above.
Item 8 - Addressees that cannot meet the schedule for the actions requested above and/or the corresponding reporting requirements belov, should justify to the NRC their proposed alternative schedule.
Response
As discussed above, CYAPCO and NNEC0 vill submit a report by July 1, 1989 updating the Staff on this issue.
If there are any questions, do not hesitate to contact my staff directly.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY CONNECTICUT YANKEE ATOMIC POWER COMPANY Mc E. 4.'Mfo~czka #
Senior Vice President
(*'V. F. Kane letter to E. J. Mroczka, " Licensee Actions in Response to Bulletin 88 Nonconforming Molded Case Circuit Breakers", dated January 10, 1989.
1
.. USNRC-A07666/Paga 7 l
March 16, 1989 j
cc:
V. T. Russell, Region I Administrator f
(
M. L. Boyle,. NRC Project Manager, Millstone Unit No.1 -
G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 D. H. Jaffe, NRC Project Manager, Mi}lstone Unit.No. 3 A. B. Vang, NRC Project Manager, Haddam Neck Plant V. J. Raymond, Senior Resident Inspector, Millstone Unit Nos.1, 2 and 3 J. T. Shedlosky, Senior Resident Inspector, Haddata Neck Plant 6
STATE OF CONNECTICUT. )) ss. Berlin l
COUNTY OF HARTFORD
)
Then personally appeared before me, E.
J.
Mroczka, who being duly sworn did state that he is Senior Vice President of Northeast Nuclear Enersy Company and Connecticut Yankee Atomic Power Company, Licensees herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein, and that the statements contained in said information are true and correct to the best of his knowledge and belief.
)h{1Ad msth
$otary Pub ~
QC0mmt.2n ",J;VS1/ arch 31,1993 l
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.-1h; Docket Nos. 50-213 50-245-50-336 50-423 A07666
.y 1-ATTACHMENT NO. 1 HADDAM NECK PLANT MILLSTONE UNIT NOS, 1, 2, AND 3
RESPONSE
TO-NRC BULLETIN NO. 88-10 MARCH 1989 I
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n Attachment'l A07666/Page 1 1'
IN STOCK ITEMS-3 x'
y
/
,0TY.
SUPPLIER MANUFACTURER MODEL NO.
CHAIN TRACEABILITY 1
.1 1
.Harnischfeger Corp.
W FB2015 1
.. N 4
Elec. Wholesalers U
FB3050L
'2 N
3
.Elec. Wholesalers V'
FB3070-2 N'
5 Elec. Wholesalers V
FB3025L 2'
N 2
Elec. Wholesalers V
FB3020L' 2
N 5
Elec. Wholesalers
- V HFB3015L 2
N 1
Elec. Wholesalers V
EFB3100 2
iN 1
Elec. Wholesalers V
FB3100 2
N 3
Economy Electric V
FB3030 l'
N
'l Economy Electric
'V FB3070 1
N
~12' Economy Electric-V HFD3020 1
N
.l 3
Economy Electric V
HFD3020 1
.N.
l 4
Newark Electronics
-Heinemann AM1-A3-A-5-3 1
N' 1
Comsip ITE P1515 U
7 Gould ITE'
-HE43B070 U
7 Gould ITE' HE43B070 U
2 Gould ITE HE43B070 U
1 Gould ITE HE43B100 U
5
-Gould ITE HE43HB100 U-9 Gould ITE HE43B015 U
U 1
Gould 1TE HE43B050 1
Gould ITE HE43B030 U
1 Gould-ITE HE43B100 U
4 Gould ITE HE43B030 U
3 Gould ITE HE43B100 U
l' Gould ITE HE43B030 U
4 Gould ITE FJ3B150L U
1 Gould ITE HE43B070 U
11 Telemecanique, Inc.
ITE HE43B030
.U 1
Telemecanique, Inc.
ITE HE43B040 U
'r 1
Telemecanique, Inc.
ITE HE43B060 U
1 Telemecanique, Inc.
ITE HE43B100 U
1 Telemecanique, Inc.
ITE HE43B100 U
4 Telemecanique, Inc.
ITE HE43B030 U
1 Telemecanique, Inc.
ITE HE43B100 U
1 C&D Charter Pyr. Sys.
V EHB3070 U
1 Energy, Inc.
V EHB3050-3P U
1 Energy, Inc.
V EHB3015-3P U
1 Energy, Inc.
V EHB3020-3P U
1 Energy, Inc.
V EHB3015-2P U
1 Brown Boveri Z-K16003 U
1 Brown Boveri ITE FJ2B175 U
4 1
i
=
L LA07666/Page 2 OTY.
, SUPPLIER MANUFACTURER MODEL NO.
CHAIN TRACEABILITY 1
Brown Boveri ITE FJ2B175 U
S Morrison-Knudsen Square "D" 8412521 U
1 Morrison-Knudsen V
FB3040L U
! 4 Morrison-Knudsen U
HFB3030L U
5 Morrison-Knudsen V
HFB3100L U
4
-Morrison-Knudsen U
HFB3070L U
6' Westinghouse U
EB3020 U
1 Westinghouse V
HFB3030 U
4 Westinghouse V
FB3100L' U
1 Westinghouse V
EB2050 U
3 General Electric V
TED134Y100 U
2 VESCO V
EHB2020 U
1 VESCO V
FB3025 U
1 VESCO S
FB3020L U
1 VESCO V
FB3020L U
J 1
VESCO V
FB3020L U
5 VESCO V
U l
7 VESCO P
EH2015 U
4 VESCO 9
EH?02f-U 4
VESCO V
EH2030 U
2 VESCO V
FB3040L U
4 WESCO V
HFB3040 U
1 WESCO V
HFB3040 U
4 VESCO Z-EA3035 U
2 VESCO V
EB2020 U
1 Combustion Engr'g.
Heinemann AM2-A3A-10-2 3
N" 1
Combustion Engr'g Heinemann AM2-A34-10-2 3
N Key Notes: N - Non-traceable 1
U = Undetermined - Supplier records still being researched 1:
Vendor procurement records no longer available.
Procurement chain could not be determined.
2:
Cutler Hammer 3:
Electro-Mechanics, Inc. from L. E. Whelan Co.
{
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4 1
A07666/Page 3 I
INSTALLRn ITEMS HADDAM NECK TRACE-OTY.
SUPPLIER MANUFACTURER MODEL NO.
APPLICATION ABILITY j
1 Westinghouse y
EB2050 Spare GSU Trans-U former i
Westinghouse E.
FB3020L Trash Basket U
Lj
'Holst i
EH2015 DC Panel A U
CKT 16 1
EH2015 DC Panel B U
CKT19 1
Economy Electric V
FB3040L DH-MOV-310 U
1 Electric. Wholesalers V
FB3040L FH-MOV-508 U
1 Electric Wholesalers V
FA3030 RCP Bearing Lift U
Pump 1
Electric Wholesalers V
FB3040L RC-MOV-512 U
1 Westinghouse U
HEB3040 RC-MOV-510 U
1 Westinghouse U
FB3040L DH-MOV-544 U
1 Westinghouse U
HEB3040 SV-MOV-1 U
1 Electric Wholesalers U
FHA 3040 CD-MOV-10 0
1 Westinghouse U
1 Electric Wholesalers U
FB3015 SS Transformer fans U 1
MC3800F MCC3 Tie Breaker U
1 Westinghouse U
MC3800F MCC4. Tie Breaker U
1 Westinghouse U
MC3800F' MCC8 Tie Breaker U
l 1
EB2020 U
2 VESCO V
MILLSTONE UNIT NO. 1 1
GE GE TEB122015VL U
2 GE GE TED(30A/IP)
U 2
GE GE TED(15A/IP)
U 1
GE GE THED(20A/3P)
U j
1 GE GE THED (15A/3P)
- U l
1 Nutherm International GE TJC36600H DC-1A U
j 1
Nutherm International GE THFK236125VL HCC C-2 U
1 1
Nutherm International GE THFK236200VL MCC E-4 U
l V
A07666/Page 4 Millstone Unit 1 (continued)
TRACE-OTY.
SUPPLIER MANUFACTURER MODEL NO.
APPLICATION ABILITY 2
Brown Boveri Electric Gould-ITE FJZ-B175 U
2 Nutherm International GE THED136040VL U
1-Nutherm International GE THED124040VL U
1 Nutherm International GE THED124050VL-
- U 6
Nutherm International GE THED136030VL U
2 Nutherm International GE THED136015VL U
MILLSTONE UNIT NO. 2 4
VESCO V
EHB3030 U-6 VESCO V
EHB1030 U
2 VESCO U
EHB2030.
U 2
EHB2100 U
4 Westinghouse U
EHB2(30A/2P)
U l
4
. Westinghouse U
EHB2(15A/2P)
U 4
EHB2(20A/2P)
U MILLSTONE UNIT NO. 3 8
Telemecanique ITE HE43B100 U
18 Telemecanique ITE HE43B015 U
1 Telemecanique ITE E21B015 U
i
- Although these breakers can be associated with specific capital projects, determination of exact location requires more research. This will be done if the breakers are declared "non-traceable."
i 1
Docket Nos. 50-213-50-245 50-336 50-423 K0T666 I
l ATTACHMENT NO. 2 HADDAM NECK PLANT ii MILLSTONE UNIT NOS. 1, 2, AND 3
RESPONSE
'I TO i
NRC BULLLTIN NO. 88-10 i
MARCH 1989
..___.._______J
'I c'
^
A07666/Page 1 1
Prior to the issuance of Reference (1), CYAPCO and NNECO had procedures in place to ensure a high degree of confidence that molded case circuit breakers, either upon initial installation or when tested as part of ongoing surveillance programs, vould properly perform their design functions. These procedures are based upon the requirements of the National Electrical Manufacturers Association's (f'EMA) Standard AB2, Procedures for Field Inspection and Performance Verification of Molded Case Circuit Breakers Used in Commercial and Industrial Applications.-
The testing prescribed within these procedures is considered to be minimally different from that required in Attachment (1) of Reference (1).
The rated current hold-in test is not required by the procedures; however, Section (6) of NEMA AB2-1984 indicates this test should be performed only if the circuit breaker has been tripping under normal load conditions.
Neither CYAPC0 nor NNEC0 have experienced problems involving tripping under normal full load.
The overload test specified in Attachment (1) of Reference (1) is also not included within the procedures, but the test, as performed in accordance with Attachment (1) of Reference (1), is essentially encompassed within the procedures by instantaneous trip setting testing. The final difference is that while Attachment (1) of Reference (1) requires a dielectric test, the existing procedures, consistent with NEMA AB2, require an insulation resistance (IR) test which is performed with a 500 or 1,000 volt megger.
Historically, at the low voltages at which molded case circuit breakers are applied, dielectric stress is not a significant factor in equipment failures, provided the equipment is kept clean. The procedures require the breakers to be cleaned, as necessary, to insure their dielectric integrity.
Also the IR testing is performed in the same manner, i.e.,
line to load terminals with the breaker open, etc., as that prescribed for the dielectric testing.
In connection with Reference (1), test procedures have been written which fully meet the testing regimen specified in Attachment (1) of Reference (1).
Any testing required as a result of the Reference (1) reviews will be carried i
out in accordance with the requirements of Reference (1), and the results, as required, vill be submitted to the Staff.
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