ML20244C720
| ML20244C720 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/14/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, NUDOCS 8904200383 | |
| Download: ML20244C720 (14) | |
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David W. Cockfield Vice President, Nuclear April 14, 1989 Trojan Nuclear Plant Docket 50-344' License NPF-1 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington DC 20555
Dear Sir:
Nuclear Regulatory Commission Bulletin (NRCB) 88-10
" Nonconforming Molded-Case Circuit Breakers"
REFERENCE:
- Portland General Electric (David W. Cockfield) to NRC (Document Control Desk) Letter. Dated March 31, 1989, NRCB 88-10 The first reporting requirement of NRCB 88-10 requests that licensees provide a written report that:
a.
Confirms that only molded-caso circuit breakers (CBs) that meet the criteria of NRCB 88-10 are available for future use in safety-related systems, b.
Provides a. summary for the CBs' that were found to not be traceable, c.
Confirms that each of the actions requested in NRCB 88-10 has been completed or will be implemented as requested.
-A report documenting the actions taken to comply with each of the above items is attached as committed in the referenced letter.
l' 8904200303 890414
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PDR ADOCK 05000344
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g PDC 121 SM SaWon Street, Portand Oregon 97204
Pbettwid W M Coiseksiy Document Control Desk' April 14, 1989 Page 2 Additional _ reports will be provided as requested by the first and second reporting requirements of NRCB 88-10 and as necessary to provide up-to-date status.
Sincerely,
/
c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State cf Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant Mr. Biff Bradley Nuclear Management and Resources Council Washington DC Subscribed and sworn to before me this
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day of 14.
Su / $4A>u Notary Public of Oregon My Commission Expires:
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.1 aTrojcn Nucisse Plant Documint Control DnskJ M
1 Docket 50-344:
' Attachment?
License ~NPF April 14, 1989 Page 1 of'7!
1 INITIAL RESPONSE TO NUCLEAR' REGULATORY COMMISSION BULLETIN.(NRCB) 88-10,-
-NONCONFORMING MOLDED-CASE' CIRCUIT BREAKERS l
- This report is previded in accordance with the ir>itial reporting requirements of NRCB.88-10 to describe the status of actions being taken n
by Portland General' Electric Company (PGE) to comply with NRCB.88-10 requests.
A '. ' FUTURE USE OF' STORED SPARE CIRCUIT BREAKERS REPORTING REQUIREMENT 1.a:
" Confirm that only' molded-case circuid breakers (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."
PGE RESPONSE:
The fo'llowing actions have been taken to ensure that only CBs that-either meet the criteria of NRCB 88-10, Item 7 of the actions requested, or have been acceptably dedicated. are being maintained as storedfspares for' future use in safety-related' applications.
1..
All' stored spare CBs available for' safety-related applications
.have been; physically inspected and had their' traceability'to the circuit breaker manufacturer (CBM) verified. rAny CB lacking
. traceability to the.CBM has been tagged to preclude use and documented on a Nonconformance' Report (NCR).
2.
PGE procedures require a material engineering evaluation of all:
indeterminate l safety-related materials-prior to issuance from the warehouse.. Molded-case circuit breakers have been identified as indeterminate ~until. reviewed per Action Item 7 of NRCB 88-10.
CBs will be acceptably dedicated or meet the Item 7 action requirements of NRCB 88-10 prior to issuance.
B.
SUMMARY
OF NONTRACEABLE CIRCUIT BREAKERS REPORTING REQUIREMENT 1.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 Item 1 and 4 of the actions requested. For
' installed CBs, also identify each system in which they are/were installed.
If. Item 4 of the actions requested has not been completed l
1 4
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Trojtn Nuclear Plant' Docum:nt Control'DAsk l
j Docket 50-344 Attachment.
License NPF-1 April 14, 1989
'i Page 2 of 7 "by' April'1, 1989, due to the schedule for tests 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."
l f
PGE RESPONSE:
A summary of the stored spare CBs that could not be traced to the CBM, as requested in Item 1 of the actions, is included as Appendix A to this report.
The results of the Item-1. actions are as follows:
Spare CB Population.
. 232 Traceable CBs.
. 177 (76%)
Nontraceable CBs.
55 (24%)
Identification.of the installed CBs procured between August 1, 1983
-and August 1, 1988 that cannot be traced to the CBM is being performed. Reviews of warehouse issue history, maintenance machinery
-history, and design changes are identifying those CBs.
A summary of the results of this review will be provided in a followup report within 30 days of completing the action requested for Item 4.
C.
CONFIRMATION OF COMPLIANCE WITH REQUESTED ACTIONS
-REPORTING REQUIREMENT 1.c:
" Confirm that Items 1, 2, 3, 4, 5, 6, and 7 of the actions requested have been completed or'will be implemented as requested."~
PCE RESPONSE:
Each of the reque?ted actions is being performed for safety-related CBs at the Trojan Nuclear Plant. A description of the actions requested, results achieved and actions to be performed for each NRCB 88-10 action item, is as follows:
Item 1: Actions Requested "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, that are being maintained as stored spares for safety-related (class 1E) applications or commercial-grade CBs that are being maintained as stored spares for future use in safety-related
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Trejcn Nuc1cir Pltnt Document Control Deck Docket 50-344 Attachment License NPF-1 April 14 1989 Page 3'of 7 l
" applications; this includes CBs procured 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 i
sample of 50 CBr per nuclear plant site.
"b.
Verify the traceability of these CBs.
"c.
Identify the number, manufacturer, model number, and to the extent possible, the procurement chain for all those CBs identified in (la) that cannot be traced to the CBM.
For installed CBs, also identify each system in which they are/were installed."
Results CBs procured prior to August 1, 1988 that were being maintained as stored spares for safety-related use have been identified and traceability verification performed as requested. A summary of the nontraceable CBs is' provided as Appendix A.
Creater than'50 stored spare CBs were identified.
Therefore, no random selection of installed CBs was' necessary.
l Item 2: Actions Requested "All holders of operating licenses who' identify installed CBs per Item 1 ebove 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 thcough 5 of the actions requested in this bulletin have been completed."
Results An analysis justifying continued operation will be prepared within 30 days of completing the actions requested per Item 4 for all nontraceable, installed, safety-related CBs that will not be replaced with acceptable breakers during the current refueling outage.
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+ Trojcn Nuclear Plent Document Control ungk Docket 50-344'
-Attachment License NPF-1 April 14, 1989 Page 4 of 7 i
. Item 3: Actions Requested "All addressees Who identify 80 percent or more 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 Attach-ment 1 (to NRCB 88-10).
Any installed CBs that fail any of these tests should be replaced with CBs that meet the criteria of Item.7fof the actions requested, or CBs that pass all tests in accordance with the testing program described in Attachment 1 (to NRCB:88-10).
If more than 10 percent of the.CBs tested fail any of the tests described in Attachment 1 continue with Item 4; other-wise, proceed to. Item 6 of'the actions requested."
Results PGE identified less than 80 percent of the stored spare CBs as traceable to the CBM.
The nontraceable, stored spare CBs are being quarantined for a period'of one year for possible NRC review as requested in an NRC letter (F. J. Miraglia) to Nuclear Management and Resources Council (W. H. Rasin) dated February 17, 1989, " Clarification of NRCB 88-10 Requirements".
After the ono-year quarantine period, the CBs will be salvaged.
Item 4: Actions Requested "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 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-rolated applications as replacement or installed during modifications.
l "b.
Verify the traceability of these CBs.
i "c.
Identify the number, manufacturer, model number, l
system in which they are/were installed, and to the extent possible, the procurement chain for all
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those CBs ideratified in (Item 4a) that cannot be traced to the CBM."
s
Trojcn Nuclcir Plant Document Control Disk I
Docket 50-344 Attachment' License NPF-1
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April 14, 1989 Page 5 of 7 q
Results CBs procured between August 1, 1983 and August 1,_1988 that are installed in safety-related applications are being identified and a traceability review is being performed as requested. The traceability review of installed CBs will be completed by June 1, 1989. A summary of the nontraceable CBs will be provided 30 days l
after completion of the traceability review.
Item 5: Actions Requested "All addressees who identify installed CBs that cannot he 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 as described in Attachment 1 (to NRCB 88-10), 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 wit') the test program described in (to NRCB 88-10).
" Holders of operating licenses are requested to replace or to test at least 1/2, or all, if the total number is less than 75, of these installed CBs before startup from the first refueling outage,'beginning after March 1, 1989. The remaining CBs should be replaced or tested before startup from the second refueling outage, beginning after March 1, 1989."
Results Nontraceable CBs identified per Item 4 above will either be (a) replaced with CBs that meet the criteria of Item 7 or have been acceptably dedicated, or (b) tested in accordance with manufacturer's recommendations as allowed in an NRC letter (F. J. Miraglia) to Nuclear Management and Resources Council (W. H. Rasin) dated February 17, 1989, " Clarification of NRCB 88-10 Requirements". Testing will'only be performed on obsolete CBs for which the CB design cannot be upgraded prior to the secord refueling after March 1, 1989.
If acceptable CBs are available, replacement will be done during the current refueling outage. All replace-ment / testing will be completed before startup from the second refueling outage beginning after March 1, 1989 and reported 30 days thereafter.
Justification for this alternative schedule is as follows:
. Traj2n Nucisar Plcnt Docum:nt Control Dmsk.
Docket 50-344 Attachment
- License NPF April'14, 1989 Page 6 of i.
a.
.The:first refueling outage beginning after March 1, 1989 commenced on April 6,.1989.
Since Item 4 will inot be completed until June'1, sufficient time may-
.not be available to procure and schedule replacement for nontraceable CBs.
- b.
JustificationsIfor Continued' Operation-(JCOs) will be. initiated within.30 days of completion of Item 4 for all nontraceable CBs identified in Item 4 that are not replaced during the current refueling outage, c.
A program has been established and procedures imple-mented to' periodically test safety-related CBs for individual pole resistance, rated current hold-in, long time delay, and instantaneous trip.
This testing is commonly. performed prior-to CB installa-tion as well.
Item 6: Actions Roquested "Information generated whilo performing actions requested.
in Items 1, 2, 3,.4, and 5 should be documented'and maintained for a period of five years after the comple-tion of all requested actions."
Results The information generated while performing the actions requested will>be documented and maintained for at least five years after the completion of all requested items.
Item 7:
Actions Requested
'"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 applications after 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 tl.a CBM in compliance with applicable industry standards, and upgraded to safety-related by the licensee or others using an
(..
acceptable dedication program."
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. ~ Trajcn L Nuc103r, Plint Docum2nt' Control Desk gt
-Docket 50-344-
' ; License ~ NPF-1 April'14,11989:
.Page(7 of<7 i
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Results CBs issued after March 20,21989Iwill'aither meet the.
criteria of Item:7 Lor be acceptably dedicated. 'The-J dedication.shall: ensure that'the CB will perform its L
intended.. safety-related: function.under all analyzed design conditions.
CBs issued between August 1, 1988'and March 20,1989, will be evaluated for traceability:in accordance with Item 4 above. If CBs are found not to be traceable,7the CBs;will be replaced or' qualified by testingiin accord.?
ance with Item 5 ab'ove, and Justifications for Continued-Operation'(JCOs) will.be written per Item 2 above for-
'e those nontraceable.CBs not: replaced during:the current refueling' outage.
A schedule summarizing the dates When each of the items will-be.
completed is.provided as Appendix B.
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(Tr' jan Nuclasr. Plant:
DocumInt Control Dask-c, '
Docket 50-344.
' Appendix A of' Attachment ~
"Ltcense.NPF-1 April 14, 1989-Page 1 of 4
'o SUNMARY OF STORED SPARE
' CIRCUIT BREAKERS'(CBs) LACKING TRACEABILITY Stores Manu-a
. Quantity Purchase
. Code No. ^factu{gy Model in Stores ~
Order [2]
(SCN)'
.(CBM)
Number (Oty)_
(PO)
Comments [3]
'1001381 ITE-
.BQ1-B020 1
N-01034' HardLeopy of PO cannot1 be found.'
4 N-22218 Traceable only to loca1' distributor.
1001401 GE-TED 124030-2 No PO Stock card identifies N-08021 and EXTURN as-the two P0s'.
11001402 GE TED'124040 3
No PO Stock card identifies.
N08021 and.EXTURN as the two POs.
l 1001405-GE
'TEF 124015 1
No PO Stock card identifies EXTURN as the only PO.
1001406 CE TFJ226225' 5
N-08021
' Referenced PO only procures one each CB.
Stock card refers to-N-08021 and EXTURN as the two Pos.
1001414 ITE-~
FJ3B150L 1
No PO.
Stock' card identifies' Could EXTURN as-the only P0; 1001415 ITE FJ3B225 3
U-000248 Stock card references:
U-000248 to'EXTURN PO.
1 N-01886 Traceable only to-local distributor.
NOTES:
-[1]- ITE: ITE-Imperial Corporation ITE-Siemens
'GE:
General Electric Company
[2]' Purchase Order column refers to both Purchase Order (N or NQ) and Upgrade' forms'(U).
[3) EXTURN (Extra Turnover) refers to material turned over to PGE in the time frame of initial-Plant startup. Further review to verify
~ traceability to the CBM for these CBs is continuing.
c..
Tr3jin Nuclsar Plent Document Control Disk Docket 50-344 Appendix A of Attachment License NPF-1 April 14, 1989 Page 2 of 4 Stores Manu-Quantity Purchase Code No.
factu{gy Model in Stores Order [2]
Comments [3]
(!GN)
(CBM)
Number (Oty)
(PO) 1001415 ITE FJ3B225
'l N-00289 PO lacks necessary information referencing this model number.
1001418 ITE HE3A003 1
U-000743 U-000743 does not reference a PO.
Stock card refers to N-08084, N-08286 and EXTURN as the three P0s.
5 U-000248 Stock card references U-000248 to EXTURN PO.
1 N-08048 Wrong PO number marked on CB.
N-08048 does not order CBs.
1001419 ITE HE3A005.
1 N-03195.58MC Traceable only to local distributor.
4 U-000245 Stock card references U-000245 to N-08084 and EXTURN as the two P0s.
1001422 ITE HE3A025 8
U-000743 U-000743 does not reference a PO.
Stock card refers to N-08160, N-00289, N-18735, N-08084 and EXTURN as the five POs.
NOTES:
[1]
ITE: ITE-Imperial Corporation ITE-Siemens GE: General Electric Company (2) Purchase Order column refers to both Purchase Order (N or NQ) and Upgrade forms (U).
[3] EXTURN (Extra Turnover) refers to material turned over to PGE in the time frame of initial Plant startup. Further review to verify 4
traceability to the CBM for these CBs is continuing.
I
)
- Tr2jtn Nusiscr Plant.
'Documrnt Control Dask.
f-Docket 50-344 Appendix A of Attachment License NPF-11
. April 14,'1989 p
Pago 3 of 4 s'
Stores-.
Manu-Quantity Purchase Code No.
factu{gy Model in Stores Order [2]
Comments [3)-
(SCN)
(CBM)
Number
'(Oty)'
(PO)-
1001425' ITE-
/HE3B030 1
NQ-3349.28 Traceable only to1 local' distributor.
1 NQ-3349.80-Traceable only from local distributor to a California CB distributor 43 1
N-28821 Traceable only to Llocal distributor.
1 No PO Stock card' identifies N-00289, N-10927, N-20123, N-25375 and
- KITURN as the'five Pos.
1001429 ITE HE3B060 1
U-000249 CB is in wrong' stores' location; actual model number HE3B020, which is not identified on U-000249.
1001431-ITE HE3B090 1
U-000249 Stock card references U-000249 to EXTURN PO.
NOTES:
[1] ITE: ITE-Imperial Corporation ITE-Siemens 1
GE: General Electric Company
-[2]
Purchase Order column refers to both Purchase Order (N or NQ) and
(
Upgrade forms (U).
[3] EXTURN (Extra Turnover) refers to material turned over to PGE in the time frame of initial Plant startup.
Further review to verify traceability to the CBM for these CBs is continuing.
[4] Not a CB distributor specifically referenced in NRC Information Notice
.(IN) 88-46..
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.TrajCn Nucisse Plcnt Document Control Disk:
L ocket 50-344-Appendix A of Attachment D
. License NPF-1 April 14,.1989 Page 4 of 4
- Stores Manu-Quantity 1 Purchase-Model' in Stores Order [2]
Code No. -factu{gy
-(SCN)'
(CBM)
Number
-(Oty)
(PO)
Comments [3]
[
1001432-ITE HE3B100 1-No PO CB'in wrong stores location; actual j
.model number-HE3A100. HE3A100'
. stock card refers t'a N-08084,,N-00084 and' f
EXTURN as the three
.Pos.
1 i
1 U-000743 CB in wrong stores.
location; actual 4
model number HE3B090. HE3B090 stock card refers to EXTURN Po.
2 NQ-3541.26 Traceable only from local' distributor to Molded Case Circuit Breakers,-Temple-City, California.
.1001433' ITE HE3H050 3
U-000743 U-000743 does not' reference a PO.
Stock card refers to PO N-08275 which orders three each CBs.
One of those three was already accounted for as traceable.
NOTES:
[1] ITE: ITE-Imperial Corporation ITE-Siemens GE:
General Electric Company
[2]. Purchase Order colunn refers to both Purchase Order (N or NQ) and Upgrade i
forms (U).
[3] EXTURN (Extra Turnover) refers to material turned over to PGE in the time frame of initial Plant startup. Further review to verify traceability to the CBM for theso CBs is continuing.
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,.Tr23r.n Nuclear P1Ent_
Docum:nt. Control Desk f
Docket'50-344 Appendix ~B of. Attachment-License NPF-1 April 14, 1989 LPage 1 of l' i-
.NRCB 88-10-ACTION ITEM SCHEDULE Item No.
' Scheduled Completion Date Item 1-Complete.
Item 2 July 1, 1599 (30 days after completion of Item 4).
Item 3 No action required.
Item 4
~ June'1, 1989 -' Report due July 1, 1989.
Item 5 June 1, 1990 ' Report due July 1, 1990.
~ Item 6 No specific schedule required (records retention).
Item 7 See Iteme 2, 4, and 5 schedule for CBs installed
'between August 1, 1988 and March 20,:1989.
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