ML20245L295
| ML20245L295 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/01/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, LIC-89-330, NUDOCS 8905050370 | |
| Download: ML20245L295 (11) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536-4000 May 1, 1989 LIC-89-330 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P(-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
NRC Bulletin No. 88-10: Nonconforming Molded-Case Circuit Breakers dated Noveniber 22, 1988 3.
Letter from 0 PPD (K. J. Morris) to NRC (Document Control Desk) dated April 3, 1989 4.
Letter from NRC (L. J. Callan) to 0 PPD (K. J. Morris) dated January 13, 1989 5.
Letter from Byron Lee, NUMARC to NUMARC Board of Directors, dated March 9, 1989 Gentlemen:
SUBJECT:
Response to NRC Bulletin No. 88-10: Nonconforming Molded-Case Circuit Breakers.
Omaha Public Power District (0 PPD) has completed the reviews and applicable actions as requested in Reference 2.
Please find our response attached.
In Reference 3, OPPD proposed, as per Reference 2, Item 8, an alternate schedule for the submittal of the written report by May 1,1989.
The reason for the alternate submittal schedule was that during the preparation of the written report a vendor which supplied four safety related molded-case circuit breakers (CBs) for use in the Instrument Inverter System had provided verbal assurance that the CBs had been obtained from a circuit breaker manufacturer (CBM) through one of their sub-vendors.
Telephone contacts were made on February 20, February 28 and March 23, 1989 that provided verbal assurance that the CBM traceability documentation would be forwarded to OPPD. On March 31, 1989 OPPD obtained verbal information that the necessary documentation to confirm the CBM may not be available.
Subsequently it was confirmed that the documentation was not available.
OPPD has taken a conservative approach and considers these four CBs as suspect. A Safety Analysis for Operability (SA0) was prepared within the time limit prescribed by Reference 2 which provides justification for continued operation until the four CBs are replaced during the 1990 outage.
\\
455124 Employmen th Equal Opportunity
.May 1, 1989 LIC-89-330 Page 2 OPPD used the approach as described in Reference 5 with regard to CBs that were intended for safety related applications per the review guidelines of Reference 2.
Purchase orders for molded-case circuit breakers for safety related applications purchased from August 1, 1983 to August 1, 1988 were reviewed to establish traceability to the CBM.
If a safety related molded-case circuit breaker could not be traced to a qualified CBM, it was considered unacceptable and tagged so that it could not be used.
If an untraceable CB was found installed, it was either removed from service or a justification for continued operation was prepared.
The untraceable CBs will be replaced with properly qualified CBs. The CBs which were identified as unacceptable will be retained for at least 6 months per your request in Reference 4.
Of the 45 CBs identified for review per Reference 2,10 CBs could not be traced to the original manufacturer. Of the 10 untraceable CBs, one was found installed in a safety related application as a 1E/Non-1E separation device in the Reactor Coolant Pump Motor (RC-38) Space Heater Circuit.
This untraceable CB has been removed and is being replaced with a properly qualified circuit breaker. As discussed above, a SA0 has been prepared for the four untraceable CBs which are installed as output breakers in the Instrument Inverter System.
These CBs will be replaced during the 1990 outage.
Three CBs were found as storage material and were tagged as not acceptable for use.
Two of the untraceable CBs had failed and were disposed of in 1985. Molded-case circuit j
breakers currently in the CQE storage area of the warehouse meet the criteria of Reference 2, Item 7.
OPPD will review our commercial grade dedication program procedures along with a review of purchasing procedures used to obtain CQE equipment through third i
party dedication vendors. This review and if necessary, revision of the procedures, is expected to be completed by August 31, 1989.
In addition, documentation for safety related circuit breakers purchased between August 1, 1988 and August 31, 1989 will be reviewed to assure manufacturer traceability.
This response is being submitted under oath pursuant to the provisions of Section 182a of the Atomic Energy Act of 1954 as amended.
If you have any questions concerning this matter, do not hesitate to contact us.
Sincerely, J
. J. Morris Division Manager Nuclear Operations KJM/jak Attachment c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector NUMARC
3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
l In the Matter of
)
)
Omaha Public Power District
)
Docket No. 50-285 (Fort Calhoun Station
)
Unit No. 1)
)
AFFIDAVIT K. J. Morris, being duly sworn, hereby deposes and says that he is the Division 4
Manager - Nuclear Optrations of the Omaha Public Power District; that as such he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached information concerning the response to NRC Bulletin No. 88-10:
)
"Non-Confirming Molded-Case Circuit Breakers"; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information, and belief.
K'4f. H6r~is r
Division Manager Nuclear Operations STATE OF NEBRASKA)
)
ss COUNTY OF DOUGLAS)
Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this
/sr day of May, 1989.
LD/L
/ Notafy Public
' ka*wmun,,,,g h
AIa GLEASON b g k 8 Cama 4 wy a r m 7
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RESPONSE TO NRC Bulletin No. 88-10: NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS REPORTING REQUIREMENT: 1.a Confirm that only molded-case Circuit 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, i
0 PPD Resoonse OPPD confirms that molded-case circuit breakers that have been purchased for installation in safety related applications between August 1,1983 and August 1, 1988 and those that are currently being maintained as stored spares for future use in safety-related applications meet the following criteria of l
Actions Requested, Item 7 of NRC Bulletin No. 88-10:
1.
Manufactured by and procured from a circuit breaker manufacturer (CBM) under a 10 CFR 50 Appendix B program; or 2.
Procured from a CBM or others with a verifiable traceability to the CBM, in compliance with applicable industry standards, and upgraded to i
safety related by 0 PPD or others using an acceptable dedication program.
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 items 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 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.
[
OPPD Response Table 1 provides the results of the review for CBs that were considered under the NRC Bulletin No. 88-10 guidelines.
The 10 CBs that could not be traced to the CBM can be found in Table 1, Reference Item Nos. 4, 6, 8 and 10.
Additional discussion regarding these CBs can be found in the response to Reporting Requirement 1.c; Action Request Items completion summary below.
Page 1 J
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1 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.
OPPD Resoonse l
The following summarizes and confirms the completion of the actions in regard i
to NRC Bulletin No. 88-10 Actions Requested:
Items 1 through 8.
Action Reauest Item 1.a j
A review of known. molded case circuit breakers stored for future use as safety related devices at the Fort Calhoun Station was performed. These CBs can be found in Table 1 (Reference Item Nos. 5, 6, 7, 8, 9, 11 and 12).
A review of installed CBs purchased during the period from August 1,1983, J
through August 1,1988, meeting the review guidelines of NRC Bulletin 88-10 i
are listed in Table 1 (Reference Item Nos.1, ?, 3, 4, 6, 9 and 10).
This J
represents a t.otal of 33 molded case breakers.
if these 33 CBs, two are no longer in service (Table 1, Reference Item No.10) and one breaker'is installed as a non-safety related device, but purchased as safety related (Table 1, Reference Item No. 9).
Since a total of only 45 molded case circuit breakers stored and/or j
installed as safety related devices were found, the minimum sample of 50 could not be obtained and no provision was made for random sampling. All 45 molded case circuit breakers meeting the NRC Bulletin 88-10 criteria were evaluated for traceability to the CBM.
Action Recuest Item 1.b The safety related molded case circuit breakers, obtained from Action Request Item 1.a above, were traced to their purchase orders. Using the purchase order information the CBs were then traced back to the original manufacturer. All Table 1 items, except Reference Item Nos. 4, 6, 8 and 10 have been traced to the original manufacturer.
The untraced CBs are i
addressed in the response to Action Request Items 1.c, 2 and 3 below.
i Action Reauest Item 1.c The information for CBs that could not be traced to the CBM can be found in Table 1, Reference Item Nos. 4, 6, 8 and 10.
Action Reauest Item 2 l
One molded-case circuit breaker (Table 1, Reference Item No. 6) which was installed in the Reactor Coolant Pump (RC-3B) Motor Space Heater Circuit as a 1E/Non-1E separation device has been removed and is being replaced with a properly qualified CB.
Since this untraceable CB has been removed from service a justification for continued operation is not required.
Page 2 l
i s
l The four molded-case circuit breakers (Table 1, Reference Item No. 4) which l
are installed as output breakers for the safety related Instrument Inverter i
System will be replaced during the 1990 outage.
In the interim, a Safety Analysis for Operability (SA0) has been prepared which provides the l
justification for continued operation.
Action Reauest Item 3 A total of 35 (78%) of the 45 molded-case circuit breakers reviewed per NRC Bulletin No. 88-10 have been traced to the original manufacturer.
Of I
the 10 CBs that could not be traced, two of them were disposed of in 1985 (Table 1, Reference Item No.10) after one failed while in-service and the other failed during pre-installation testing. One CB (Table 1, Reference No. 8) was a spare CB for an obsolete system that has been replaced.
The CB has been removed from the CQE storage area and tagged as unacceptable j
for use. The four breakers installed in the Instrument Inverter System j
(Table 1, Reference Item No. 4) have had a Safety Analysis for Operability (SAO) prepared to justify continued operation until they are replaced 1
during the 1990 outage.
Three breakers (Table 1, Reference Item No. 6) have been declared unacceptable for safety related use.
No testing is plawed for these untraceable CBs, however they will be retained for a minin:7 of six months per NRC request (L. J. Callan, NRC to K. J. Morris, OPPD dated January 13,1989).
ection Reauest Item 4 As discussed in Action Request Item 1, CBs which were purchased between August 1,1983 and August 1,1988 which were intended for safety related i
applications were reviewed for traceability to the CBM.
This information j
can be found in Table 1.
Action Reauest Item 5 As discussed in the response to Action Request Items 2 and 3 above, five CBs were found currently installed in safety related applications (Table 1, Reference Item Nos. 4 and 6) that could not be traced to the original manufacturer. The one CB for the Reactor Coolant Pump Space Heater Circuit has been removed from service and is being replaced with a CB meeting the criteria of Action Request Item 7.
The four CBs installed in the Instrument Inverter System will be replaced during the 1990 outage with CBs meeting the criteria of Action Request Item 7.
Action Reauest Item 6 OPPD will document and m.intain for a minimum period of 5 years (from 3-31-89) the information generated while performing the work associated with Action Request Items 1, 2, 3, 4 and 5 of NRC Bulletin No. 88-10.
Page 3
7 Action Reauest Item 7 A review has been completed of purchase orders for molded-case circuit breakers purchased from August 1, 1983 through August 1, 1988.
CBs purchased during this period were found to be be traceable to the original manufacturer except as noted above (Table 1, Reference Item Nos. 4, 6, 8 and 10).
OPPD has received NUMARC's " Industry Initiative on Substandard NSR Molded Case Circuit Breakers" dated March 8, 1989 and will review its applicability to our material receipt inspection program.
OPPD is reviewing the adequacy of procedures for purchase specifications, commercial grade dedication and receipt inspection for equipment not 1
purchased from a manufacturer who has an approved 10 CFR 50 Appendix B QA program.
The results of this review effort and revised procedures, if applicable, will be completed by August 31, 1989.
During this interim period individuals involved in the specification, procurement, receipt inspection, storage and installation of molded-case circuit breakers have been notified to be aware of the need to assure traceability to the CBM.
In addition, safety related molded-case circuit breakers purchased from August 1, 1988 through August 31, 1989 will be
)
reviewed to assure traceability to the CBM.
Action Reauest Item 8 OPPD completed the reviews by March 1,1989 per Action Request Item 1 and submitted a written report by May 1, 1989 per the alternate submittal j
schedule, as required by NRC Bulletin No. 88,10 Reporting Requirements.
REPORTING REQUIREMENT 2 OPPD has elected to take the conservative approach and to declare any CB that J
cannot be traced to a CBM as unacceptable for safety related use.
Therefore we i
have no plans to test CBs, however we will retain untraceable CBs as
)
nonconforming items for a minimum of 6 months.
REPORTING REQUIREMENT 3 This is for holders of construction permits and is not applicable to OPPD.
REPORTING RE0VIREMENT 4 This is for holders of construction permits and is not applicable to OPPD.
I l
Page 4
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