ML20245L084
| ML20245L084 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/11/1989 |
| From: | Drawbridge B PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, NYN-89103, NUDOCS 8908210262 | |
| Download: ML20245L084 (9) | |
Text
e N&w Hampshire Yankee NYN-89103 August 11, 1989 United States Nuclear Regulatory Commission Washington, DC. 20555 Attention: Document Control Desh
References:
(a) Facility Operating License NPF-67. Docket No. 50-443 (b) NRC Bulletin No. 88-10: Nonconforming Molded Case Circuit Breakers (c) NUMARC Letter dated April 28, 1989, "NUMARC Initiative on Molded Case Circuit Breakers," B. Lee to NUMARC Board of Directors (d) NHY Letter NYN-89035 dated March 31, 1989, " Response to NRC Bulletin 88-10: Nonconforming Molded Case Circuit Breakers,".G. S. Thomas to USNRC (e) NHY Letter NYN-89071 dated May 31, 1989, " Response to NRC Bulletin-88-10: Nonconforming Molded Case Circuit Breakers," G. S. Thomas to USNRC
Subject:
Response to NRC Bulletin 88-10: Nonconforming Molded Case Circuit Breakers Gentlemen:
This letter presents.an updated report of the New Hampshire Yankee (NHY) actions taken in response to NRC Bulletin 88-10 (not including Supplement 1) i j'
to ensure that Class 1E molded case circuit breakers (MCCB's) in inventory l
or installed in safety-related applications at Seabrook Station are traceable to a circuit breaker manufacturer (CBM).
l i
Efforts to determine the traceability of Class 1E MCCB's within the
)
scope of the Bulletin have been completed to the extent possible. A summary of the steps taken and results obtained to date to determine the I
traceability of these MCCB's is contained in Enclosure 1 to this letter.
{
Specific traceability information pertaining to non-traceable MCCB's is presented in tabular form in Enclosure 2 to this letter, i
i 8908210262 090811 PDR ADOCK 05000443 O
PDC New Hampshire Yankee Division of Public Service Company of New Hampshire
[bk P.O. Box 300
- Seabrook, NH 03874
- Telephone (603) 474-9521 ll t
United States Nuclear Regulatory Commission August 11, 1989 Attention: Document Control Desk Page 2 As previously reported, all non-traceable Class 1E MCCB's which had been installed in safety-related applications at Seabrook Station have been replaced with traceable Class 1E MCCB's.
The replaced, non-traceable MCCB's have been returned to inventory. All non-traceable Class 1E MCCB's in inventory have been segregated and are administratively controlled to prevent their use in any application. Additionally, each non-traceable MCCB has been externally inspected for signs of refurbishment or prior use in accordance with the guidelinet af the CBM provided through the Nuclear Management and Resources Council (NUMARC) [ Reference (c)). As a result of the inspection, no MCCB was determined to have unresolved indications of refurbishment or to be otherwise non-standard.
These non-traceable MCCB's will be retained until June 30, 1990.
Subsequent to June 30, 1990, NHY will make an appropriate disposition of these MCCB's unless further notice is received from either the NRC or NUMARC.
Administrative controls pertaining to the purchase, receipt and issuance from inventory of Class 1E MCCB's have been placed in effect.
Since March 1, 1989, receipt inspections of MCCB's.have included checks for external signs of refurbishment. Since March 31, 1989, only traceable Class 1E MCCB's have been permitted to be issued from inventory to safety-related applications at Seabrook Station. Since April 30, 1969, requirements to provide a(ditional documentation have been imposed upon suppliers of MCCB's by means of an additional clause in NHY purchase orders to ensure that traceability to the CBM is provided.
New Hampshire Yankee has reviewed Supplement 1 to IEC Bulletin 88-10 l
dated August 3, 1989, and in.tends to pursue the additional required action j
and reporting within the schedule provided by the Supplement.
Should you j
require further information regarding tlas matter, please contact Mr. Geoffrey Kingston at (603) 474-9521, extension 3371.
Very tr y yours, h4%k &
Bruce L. Drawbri Executive Director -
Nuclear Production Encicsures
_g.'
_s s
p 1
^
-United States Nuclear Regulatory Commission Augus't 11, 1989-y
. Attentions-Document Control Desk Page 3-
. cc: Mr. William T.. Russell Regional Administrator.
United' States Nuclear Regulatory Commission Region-I-475 Allendale Road
[,
King.of Prussia, PA 19406
- Mr. Victor'Nerses. Project Manager
~
Project Directorate I-3 United States Nucicar Regulatory Commission Division of Reactor. Projects l-Washington, DC 20555 NRC Senior Resident Inspector P.O. Box 1149'
~ Seabrook Station, NH 03874 l
l l
STATE OF NEW HAMPSHIRE Rockingham, ss.-
-August 11, 1989 l-Then personally appeared before me. the above-named Bruce L. Drawbridge.
I being duly sworn, did state that he is Executive Director - Nuclear Production IL of.New Hampshire Yankee Division of Public Service Company of New' Hampshire, that he is duly authorized to execute and file the foregoing information in the-name and on the behalf of New Hampshire Yankee Division of the Public Service p
Company of New Hampshire and that the statements therein are true to the best of I.
his knowledge and belief.
Eneb b bShru, Beverly E.9 111oway NotaryJPublic My Commission Expires: March 6, 1990 l
l' 1:
I 4-p New Hampshire Yankee August 11, 1989 l'
L ENCLOSURE 1 TO NYN-89103
~
Detailed Description of Actions Completed in Response to NRC Bulletin 88-10 y
L For the' purposes of this' letter, the term " traceable" shall mean having
' verifiable; traceability as defined by NRC Bulletin 88-10. _Similarly the term "non-traceable" shall mean not having verifiable traceability as defined by the Bulletin.- However, as Enclosure 2 demonstrates, considerable traceability information has been obtained for each non-traceable Class 1E MCCB.
The firsc phase of the New Hampshire Yankee (NHY) response to NRC Bulletin 88-10 applied to the Class 1E MCCB's in Seabrook Station Unit 1 spare part inventory.- The objective of this first phase of the response was to complete Requested-Action No. 1 of the Bulletin.
This action _ requested a verification that the Class 1E MCCB's in inventory purchased prior to August 1, 1988, were traceable to a circuit breaker manufacturer (CBM). In order to perform this action, Seabrook Station Unit 1 inventory system records were reviewed to identify the number of Class 1E MCCB's in inventory as_offJanuary 30, 1989. The August 1, 1988 target date requested by the Bulletin was extended to January 30, 1989 in order to identify as many Class 1E 'MCCB's in' inventory as possible. Inventory records indicated that 306 Class 1E MCCB's were in inventory as of January 30, 1989. On-site purchase order records for the 306 MCCB's were then reviewed to determine to the extent possible.their procurement chain. During the first quarter of 1989
' additional information was requested from suppliers of these MCCB's as necessary to supplement the on-site information regarding traceability.
Additionally, during a vendor surveillance conducted on the premises of Telemecanique. Westminster, MD, NHY reviewed the Telemecanique procurement records directly related to NHY purchase orders to Telemecanique for Class 1E MCCB's.
The_ result of the above actions, reported in Reference (d), was that 244 of the 306 Class 1E MCCB's were' traceable to the CBM.
Traceability to the CBM of 243'of the 244 MCCB's was verified by means of the vendor surveillance at Telemecanique. The remaining MCCB (supplied by COMSIP Inc.)
was initially determined to be traceable on the basis of available documentation.
After submitting Reference (d) NHY reviewed accumulated documentation relating to the procurement chain of the 306 Class 1E MCCB's identified in inventory as of January 30, 1989. The reviewed documentation included supplier responses to the NHY requests for additional information and the detailed report of the vendor surveillance at Telemecanique. As a result of this review, minor revisions to the figures reported in Reference (d) were umde.
1
e New Hampshire Yankee August 11, 1989 The total number of Class 1E MCCB's identified in inventory as of January 30, 1989, was revised from 306 to 309, 243 of which were traceable and sixty-six (66) of which were non-traceable. The number of traceable MCCB's decreased from 244 to 243 as a result of a revised determination that the COMSIP-supplied MCCB was non-traceable.
Concurrent with the effort to determine the procurement chain of the Class 1E MCCB's in inventory, additional administrative controls related to the purchase, receipt and issuance from inventory.of Class 1E MCCB's were placed in effect. As of March 1, 1989, MCCB receipt inspections included checks for external signs of refurbishment. As of March 31, 1989, only traceable Class 1E MCCB's could be issued from inventory to safety-related applications at Seabrook Station. As of April 30, 1989, requirements to provide additional documentation were imposed upon suppliers of MCCB's by means of an additional clause in NHY purchase orders to ensure traceability to the CBM.
It was recognized that, during the time interval between the initial January 30, 1989, inventory records review and the April 30, 1989, establishment of MCCB-related administrative controls, the number of Class 1E MCCB's in inventory could have changed due to receipt or issuance activity. Therefore, inventory records were again reviewed to determine the number of Class 1E MCCB's in inventory as of May 8, 1989.
384 Class 1E MCCB's were identified in inventory as of May 8, 1989, 316 of which were traceable and sixty-eight (68) of which were non-traceable. Please note that sixty-six (66) traceable MCCB's were inadvertently omitted from the l
traceable and total figures reported in inventory as of May 8, 1989, by l
Reference (d).
(Reference (d) reported a total of 318 Class 1E MCCB's in inventory as of May 8, 1989, 250 of which were traceable.)
The sixty-eight (68) non-traceable MCCB's identified in inventory as of May 8, 1989, were segregated in the warehouse and administratively restricted from being used in any equipment or discarded. Additionally, an external visual inspection was performed on each of the sixty-eight (68) non-traceable MCCB's.
The external inspection was based upon guidance from the CBM provided through the NUMARC Industry Initiative on Molded Case Circuit Breakers [ Reference (c)) and had the objective of identifying any external signs of refurbishment, prior use, or alteration from the as-new condition.
The inspection of the sixty-eight (68) non-traceable MCCB's did not identify any MCCB as having unresolved indications of refurbishment or l
being otherwise suspect.
2
New Hampshire Yankee August 11, 1989 Based upon the results of the procurement chain determination for Class IE MCCB's in inventory, it was determined that the appropriate follow-up action was to proceed with Requested Action No. 4 of the Bulletin, the five-year review of Class 1E MCCB in-plant replacement activity. The Bulletin requested that this review focus upon MCCB's purchased between August 1, 1983, and August 1, 1988 and installed in safety-related applications as replacements or as part of modifications. To ensure identification of all such MCCB's installed at Seabrook Station prior to the establishment of applicable MCCB-related administrative controls, the end date of the specified five-year interval was extended to May 3, 1989.
Inventory system records and work control program documentation were reviewed to identify I
Class 1E MCCB's issued from inventory for use in safety-related applications at Seabrook Station during this five and three-quarter year interval. As of May 3, 1989, twenty-three (23) Class 1E MCCB's were identified as issued from inventory to safety-related applications in the Station. Of the twenty-three (23), eight (8) were determined to be non-traceable.
Each of the eight (8) non-traceable MCCB's was replaced with a traceable Class 1E MCCB. The replaced non-traceable MCCB's were returned to inventory, and were segregated, restricted from use and inspected in accordance with CBM guidelines as described above for the sixty eight (68) non-traceable MCCB's identified in inventory. The inspection did not am ident.fy any MCCB as having unresolved indications of refurbishment or being 4
l otherwise non-standard. The addition of the eight (8) previously installed, non-traceable MCCB's to the sixty-eight (68) non-traceable MCCB's segregated in inventory resulted in the current total of seventy-six (76) non-traceable MCCB's segregated in inventory. The seventy-six (76) MCCB's will be retained until June 30, 1990.
Subsequent to June 30, 1990, NHY will make an appropriate disposition of these MCCB's unless further notice is received frcm either the NRC or NUMARC.
Specific traceability information l
pertaining to the seventy-six (76) non-traceable MCCB's is presented in tabular form in Enclosure 2 to this letter.
As committed to in Reference (e) a physical verification of Class 1E MCCB's in inventory has been performed.
Inventory system records were reviewed to identify all Class 1E MCCB's in inventory as of June 5, 1989.
h A physical check of Class 1E MCCB's in inventory was then performed.
The result of the above verification was complete reconciliation between the inventory records count and the physical count of Class 1E MCCB's in inventory as of June 5, 1989.
The final numerical result of this physical verification was 312 traceable Class 1E MCCB's and seventy-six (76) non-traceable Class 1E MCCB's in inventory as of June 5, 1989. There is a difference between the June 5, 1989, figure (312) and the May 8, 1989, figure (316) of traceable Class 1E MCCB's in inventory. This difference represents a net reduction of four traceable Class 1 MCCB's in inventory as a result of receipt and issue transactions between the two dates. There was no change in the number of non-traceable Class 1E MCCB's in inventory between these same dates.
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