ML20246E609
| ML20246E609 | |
| Person / Time | |
|---|---|
| Issue date: | 06/14/1989 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Boger B Office of Nuclear Reactor Regulation |
| References | |
| IEB-88-010, IEB-88-10, NUDOCS 8907120316 | |
| Download: ML20246E609 (8) | |
Text
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June 14,.1989
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' MEMORANDUM.FOR: _ Bruce A. Boger, Assistant Director y'
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- Walter R. Butler, Director
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James C. Stone, Project Manager i
Project Directorate I-2 a
Division of Reactor Projects I/II
SUBJECT:
-MEETING BETWEEN NRR AND NUMARC'TO DISCUSS NUMARC'S COMMENTS 1
ON BULLETIN 88-10, SUPPLEMENT l' j
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E 10n Wednesday, June-7,:1989, NRR management and staff. met with members'of-NUMARC to discuss NUMARC's comments on Bulletin 88-10, Supplement 1.
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comments were forwarded to the NRC by letter dated May 19,1989. - A summary of
, this-meeting' and. a list of.' attendees is. enclosed for your information. A copy of the NUMARC~ letter is-also enclosed.
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1 James C. Stone, Project Manager E
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Division of Reactor Projects I/II Ebclosures:
l '. Meeting Summary 2.
List'of Attendees J
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NUMARC's May 19, 1989 Letter.'
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Draft Supplement to Bulletin 88-10
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June 14, 1989 MEMORANDUM FOR: Bruce A. Boger, Assistant Director for Region I Reactors Division of Reactor Projects I/II THRU:
Walter R. Butler, Director l j,,
Project Directorate I-2 W
Division of Reactor Projects I/II FROM:
James C. Stone, Project Manager Project Directorate I-2 Division of Reactor Projects I/II c
SUBJECT:
MEETING BETWEEN NRR AND NUMARC TO DISCUSS NUMARC'S COMMENTS ON BULLETIN 88-10, SUPPLEMENT 1 On Wednesday, June 7, 1989, NRR management and staff met with members of NUMARC to discuss NUMARC's comments on Bulletin 88-10, Supplement 1.
The comments were forwarded to the NRC by letter dated May 19, 1989. A summary of this meeting and a list of attendees is enclosed for your information. A copy of the NUPARC letter is also enclosed.
b James C. Stone, Project Manager Project Directorate I-2 Division of Reactor Projects I/II
Enclosures:
1.
Meeting Summary 2.
List of Attendees 3.
NUMARC's May 19, 1989 Letter 4
Draft Supplement to Bulletin 88-10 1
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ENCLOSURE 1
SUMMARY
OF NRC/NUMARC MEETING ON JUNE 7, 1989 NUMARC COMMENTS ON BULLETIN 88-10, SUPPLEMENT 1 On Wednesday, June 7, 1989, members of NRR Management and staff met with members of NUMARC to discuss their comments on draft Bulletin 88-10, Supplement 1.
The comments had been provided to NRC by letter dated May 19, 1989. Below is a summary of the meeting:
DISCUSSION Note, item numbers below correspond to the item numbers in the NUMARC's May 19, 1989 letter and the draft supplement to Bulletin 88-10 (copies attached).
Item 1.
The original intent of Bulletin 88-10 was to include in the sample all molded case circuit breakers (MCC8) behg held or purchased as spares for safety related-applications. This would include those held in stores purchased as part of the original plant. However, recognizing that some of these breakers may be quite old, this will be changed to specify that MCCBs purchased as part of the original plant and delivered before August, 1983 will not be required to have traceability to the CBM established or be subject the testing requirements of the Bu11etir.
Item 2.
The suggestion that the second sentence be deleted will not be incorporated. Staff believes the second sentence provides clarification on the limitations of visual examinations of non-traceable breakers.
Item 3.
For the narrow case of MCCBs, verifiable traceability is a key condition for determining the suitability of the MCCB.
If traceability cannot be established to the manufacturer then the breaker is of unknown quality. The licensee's quality program should require full correction of the deficient condition by looking at all breakers in the non-traceable procurement and their use, not just the ones in stores, and take the action prescribed in the bulletin. The staff feels this is the normal i
operation of the licensee quality programs currently required under Criterion XVI of Appendix 8.
This item will be revised to request that only those breakers that were procured on the same purchase order be subject to the acceptability review.
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l4 Item 4.
-The staff will further consider the NUMARC suggestion to exclude use of MCCBs in any application that have come from known refurbishes.-
Item 5.
'The staff will incorporate NUMARC's comment.
Item 6.
The item will be revised to incorporate manufacturer controlled warehouses as equivalent to the manufacturer for traceability purposes.
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- v L' O ENCLOSURE 2 NRC/NUMARC MEETING JUNE 7, 1989 ATTENDEES NAME ORGANIZATION Jim Stone NRR/PDI-2 Uldis'Potapovs NRR/DRIS/VIB Bill Brach NRR/DRIS/VIB Alex Marion NUMARC Russ Bell NUMARC R. W. Borchardt OED0 Kathryn 0. Greene GPA/CA Carl H.- Berlinger NRR/0GCB Max J. Clausen NRR/DRIS Jaime Guillen NRR/00EA Jim Knight NRR/ DEST Charles Ader NRR/DRIS/VIB I
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NUCLEAR MANAGEMENT AND RESOURCES COUNCIL 1776 Eye Street. N W
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- WesNngton. DC 20006 2496 L
(202) 872-1280 May 19, 1989 j
Mr._ Frank J. Miraglia Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation l
U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Miraglia:
l On Thursday May 11, 1989, NUMARC met with members of the NRC Staff to discuss overall industry responses to Bulletin 88-10, " Nonconforming Molded Case Circuit Breakers." We appreciate such opportunities for continued dialogue with the Staff toward resolving concerns about fraudulent molded case circuit breakers (MCCBs).
The Staff provided for discussion draft Supplement 1 to Bulletin 88-10.
With roughly half of utilities in the process of preparing follow-up responses to Bulletin 88-10, we agree that a Bulletin supplement at this time would be an effective method for the Staff to re-emphasize the original intent of the Bulletin and address major inconsistencies in utility responses where it appears.the original intent may not'be understood. We do, however, have significant reservations about the content of the draft supplement.
Our major concerns are summarized below and specific comments on individual supplement items are provided in Attachment 1.
We find that the supplement presents additional requirements not suggested by Bulletin 88-10 that represent significant'new burden to many utilities.
NUMARC acknowledges that Bulletin 88-10 results could, in the final analysis, suggest that additional efforts may be necessary for industry to definitively resolve concern over nonconforming MCCBs.
However, we believe that it is inappropriate to present new requirements at this time since,
- 1) results of Bulletin 88-10 are not yet complete, and
- 2) results to date do not appear to provide a basis for further action.
Rather, Supplement I should be directed at ensuring existing Bulletin requirements are fully understood by all silities.
We are concerned that the supplement attempts to alter the Staff's original focus for Bulletin 88-10 and expand its scope without clear justification. Establishing traceability to the CBM was the course chosen by the Staff for providing assurance that replacement MCCBs purchased for safety-related service during the identified period of primary concern (August, 1983 to August,1988) were not refurbished or previously used.
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May 19, 1989 Page 2 The proposed supplement alters this focus in two critical areas. First, the Bulletin acknowledged that MCCBs purchased during original plant construction were purchased from the circuit breaker manufacturer (CBM) and concluded that such " original" MCCBs were not a concern of this Bulletin.
The supplement, in a clear expansion of Bulletin requirements, requires l
utilities to establish traceability to the CBM for MCCBs purchased as original plant equipment or be required to replace or successfully test them. As noted in Bulletin 88-10, original plant equipment for safety-related service was manufactured and purchased under programs conforming to 10CFR50 Appendix B which provided reasonable assurance that purchased material and equipment conform to the procurement documents. Traceability to the extent it is required by Bulletin 88-10 goes beyond " adequate confidence" as intended by Appendix B, and we feel it is inappropriate to require traceability of original plant MCCBs to their CBM.
Secondly, the Bulletin established a five year review period for installed MCCBs based on anticipated availability of procurement records.
The supplement, however, indicates Staff expectation that installed non-traceable MCCBs be subject to Bulletin requirements regardless of purchase date. We must re-emphasize that lack of traceability does not imply that a MCCB is improper. Furthermore, lack of traceability for MCCBs ordered more than five years ago is likely due to the' unavailability of records for these type of components not because of the involvement of suspect suppliers.
Our review of industry Bulletin 88-10 responses concludes that the expanded Bulletin requirements contained in the proposed supplement are not warranted.
It appears the Staff is concerned about the shortcomings of relatively few utility responses. We believe it mon appropriate for the NRC Staff to address the few deficient responses directly with individual utilities rather than issue new generic requirements on the entire industry.
We request you carefully consider these and our specific comments contained in Attachment 1, particularly those addressing items 1, 3 and 4 of the draft supplement. We are willing to meet with NRC Staff to further articulate these concerns.
We think it important that NUMARC and NRC continue to work together on the MCCB issue.
Please call Alex Marion or Russell Bell at any time for further discussion of our questions on the Bulletin supplement or the attached comments.
Sincerely,
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I William H. Rasin
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Director, Technical Division WHR/ sal 4
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-l NUMARC COMENTS ON BULLETIN 88-10, SUPPLEMENT 1 (DRAFT)-
Item 1.
The language of Bulletin 88-10 reflects the important understanding reached last year between NUMARC and NRC Staff that replacement MCCBs'are of primary concern, not MCCBs ordered as part of original plant equipment. The Bulletin appropriately states, "This (original) equipment appears to have been procured during plant construction from CBMs with full certification.
The large quantities'of electrical assemblies or components
. procured under bid packages during plant construction reduce.
the possibility of any original plant equipment being supplied by vendors doing refurbishing."
With this language, the Staff acknowledged the low likelihood that MCCBs procured during plant construction were supplied by 4
refurbishes and concluded, " concerns addressed in this Bulletin do not apply to (original equipment)." The' supplement reverses this position by requiring original MCCBs to meet fully the traceability requirements of Bulletin 88-10.
We find the original position of the Staff expressed _in the Bulletin-to be sound, and we find it inappropriate for the Staff to expand the scope of Bulletin 88-10.
We suggest deletiofs of item I in its entirety.
Item 2.
Delete the second sentence. The first sentence appropriately addresses the Staff's concern ~regarding unacceptability of visual inspection by itself as.an alternative to verifiable traceability. -
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Item 3.
This item represents.a clear expansion of Bulletin 88-10 scope-which is inappropriate at this time. The Bulletin states,
"...a-Supplement may be issued to include...a longer procurement review-period if warranted by the results of...this Bulletin." Five years was selected as a reasonable period of review by the Staff due to:
- 1) likelihood that records would be available to establish traceability, and
- 2) evidence that MCCB refurbishment was more prevalent in the last five years.
The five year review of industry MCCBs required by Bulletin 88-10 is not yet complete, and results to date do not suggest the need for additional review.
t However, independent of the requirements of Bulletin 88-10, we believe that utilities would continue investigating installed MCCBs associated with clearly susoect MCCBs (e.g. those from a known suspect supplier or exhibiting signs of refurbishment). Lack of traceability, in our view, does not by itself provide sufficient cause for expanded actions.
.7 traceability, in our view, does not by itself provide sufficient cause for expanded actions.
We are greatly concerned by the implications of supplement item 3 when viewed in conjunction with item 1.
The result of these two new requirements is that a utility which cannot establish verifiable traceability per Bulletin 88-10 for original equipment MCCB spares, may, by association, be required to consider as non-traceable large numbers (perhaps all) originally installed MCCBs.
Based on our review of Bulletin responses, an increase in the scope of Bulletin 88-10 is not justified at this time. We believe, therefore, that supplement item 3 should be deleted completely.
The first sentence of item 4 offers a useful clarification of Item 4.
We suggest adding the phrase "neither supplied by Bulletin 88-10.
after known refurbishes nor exhibiting evidence of refurbishment" "CBs" in the first line. Also, after "Bulletin 88-10" in line 3, the phrase "or equivalent manufacturer recommended evaluation / test program" should be inserted.
However, we must caution against reliance placed on the test program detailed in Attachment 1 of the Bulletin given the positions of i
the National Electrical Manufacturers Association and Underwriters
- 1. laboratories regarding the inadequacy of such testing.
We feel the second sentence of item 4 is inappropriate and should be deleted.
We find this item appropriate and suggest the first sentence be Item 5.
rewritten as follows, "Regardless of the number of CBs stored..."
The Staff has acknowledged that traceability of MCCBs to corporate i
Item 6.
facilities of the CBM such as controlled warehouses, distribution centers or production facilities is sufficient for tho purpose of Bulletin 88-10. We therefore suggest the following replacement language for item 6:
"CBs demonstrated traceable to the CBM by test report, certificate of compliance, purchase documents, shipping records or other procurement records are acceptable for safety-related The CBM is considered to include all corporate service.
controlled facilities including controlled warehouses, distribution centers and production facilities.
1 l
Specifically, a certificate of compliance from other than the CBM (e.g. equipment supplier) would not constitute adequate traceability of MCCBs without such procurement records as suggested above demonstrating the traceability of each individual procurement to the CBM. Traceability s' /uld be demonstrated by documents in the utility's possession or verified by audit or other appropriate means. Telephone discussions with vendors are not acceptable basis for establishing traceability."
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ENCLOSURE 4 1
DNT-NRC Bulletin No. 88-10, Supplement 1: NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS Addressees:
4 All holders of operating licenses or construction permits for nuclear power reactors.
Purpose:
1 The purpose of this bulletin is to inform addressees that based on a cursory review of responses to NRC Bulletin 88-10, the NRC staff has determined that many responses do not adequately satisfy the provisions of Bulletin 88-10 and that some addressees may need to take additional actions. This supplement also provides specific examples of common deficiencies identified during the cursory review of responses.
Description of Circumstances:
NRC Bulletin 88-10 was issued on November 22, 1988, to request that addressees
'take actions to provide a reasonable assurance that molded-case circuit breakers (CBs) purchased for use in safety-related applications perform their safety functions.
In addition, the bulletin requested that addressees submit certain information to the NRC regarding CBs that could not be traced to the circuit breaker manufacturer (CBM).
The NRC staff has been screening written reports submitted by addressees in accordance with Bulletin 88-10 and has identified several common deficiencies.
In addition, the NRC staff has received requests for positions on specific issues that were not explicitly addressed in Bulletin 88-10. The NRC analyses and positions on these issues are sumarized herein.
1.
If CBs are traceable to an original plant construction order and the order was procured directly from the CBM, there is reasonable assurance that the CBs are acceptable and no additional traceability is i
required. However, if the CB purchase orders were procured from intermediate suppliers, such as panel or motor control center manufacturers, traceability must be established to the CBM in accordance with Bulletin 88-10.
2.
Visual inspection and physical examination of CBs by the CBM is not I
considered adequate to meet the traceability requirements of Bulletin 88-10. Although visual inspection and physical examination by the CBM may provide a reasonable basis that the CBs have not been opened or altered in a substantial way, there is not a reasonable assurance that the CBs have not been previously used or subjected to service conditions that may have adversely affected the performance capabilities of the CBs.
3.
Item 4 of the actions requested applies only to CBs that were purchased and installed after August 1, 1983. However, it is expected that addressees will review the acceptability of installed CBs, regardless of their purchase date, that were procured from the same sources or purchase
1 1
i h, *..,W 3L;in orders as CBs that are identified as nontraceable during the review of Bulletin 88-10.
i-with the provisions of item 2 of the actions requested (i.e.
justifications for continued operation) for any installed nontraceable CBs, regardless of how the CBs were identified as nontraceable.
4 Nontraceable CBs that are currently installed or in stores as of August 1, 1988, and that successfully pass all tests specified in Attachment 1 of Bulletin 88-10 are considered acceptable for current and future use in safety-related applications. This includes CBs that have been procured from companies identified as suppliers of refurbished CBs, provided that detailed visual inspections and physical examinations of the CBs reveals no evidence of tampering.
S.
In cases where a large number of CBs are stored as spaces, each individual CB stored for future use in safety-related applications must be reviewed in order to establish proper traceability. Traceability for all CBs is not considered to have been established if traceability is performed on a sample basis.
6.
All safety-related CBs from the same procurement order are considered traceable if the order was procured directly from a CBM h CFR Appendix B, or equivalent, Quality Assurance program,aving a 10 of compliance has been furnished, and if the CBM has been audited inif a certifica accordance with Appendix B.
However, if safety-related CBs were procured from a vendor other than the CBM, a certificate of compliance by itself is not considered an adequate basis for establishing traceability.
In such cases, traceability of individual ' rocurement orders must be established p
through the review of procurement / shipping records btek to the CSM.
a basis for traceability. Telephone discussions with the vendor are no Actions Requested:
In response to the aforementioned circumstances, addressees are requested to perform the following actions within 30 days from the receipt of this bulletin:
1.
Review written reports submitted to the N E in accordance with Bulletin 88-10 and verify that the responses meet the bulletin provisions and are consistent with the above NRC positions.
2.
Prepare and retain documentation for possible audit that indicates that item 1 of the actions requested has been performed as requested.
Reporting Requirements:
No written reports are required to be submitted to the NRC by this supplement; however, addressees are required to provide any appropriate corrections to previous responses to Bulletin 88-10.
The NRC will conduct inspections at selected nuclear power plant sites in order to verfify that issues associated with Bulletin 88-10 and this supplement have been adequately resolved.
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If you h' ave any questions regarding this matter, please contact one of the technical contacts listed below or the Regional Administrator of the appropriate NRC regional office.
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Charles E. Rossi Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: Uldis Potapovs, NRR (301) 492-0984 Jaime Guillen, NRR (301)492-1170 e
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