ML20247G933
| ML20247G933 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/31/1989 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 04690, 4690, HL-395, IEB-88-010, IEB-88-10, NUDOCS 8904040348 | |
| Download: ML20247G933 (10) | |
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04690 X7GJ17-H110 March 31, 1989 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO NRC BULLETIN NO. 88-10 NONC01 FORMING MOLDED-CASE CIRCUIT BREAKERS Gentlemen:
In response to NRC Bulletin No. 88-10, Georgia Power Company (GPC) is providing the enclosed response.
A copy of this response is being provided to NRC Region II for review.
In the enclosure, a transcription of the NRC bulletin action items precedes GPC's response.
Included in the enclosure are the status of activities performed to I
date, a projected schedule for completion of required actions, and a table of information regarding nontraceable molded-case circuit breakers discovered at Plant Hatch as requested in the Reporting Requirements of the bulletin.
Should you have any questions in this regard, please contact this office at any time.
GEORGIA POWER COMPANY it).,k gh[ x W. G. Hairston, III Senior Vice President Nuclear Operations
- ay of Wa t.c/v 1989.
Sworn to and subscribed before me this 3/
d ftm b Y Nbtary Public
- M % +c.;7;
. TEM DLM/dm (See next page.)
I 8904040348 890331 l
ADOCK 05000321 1
. Georgia Poiver1 U.S. Nuclear Regulatory Commission March 31, 1989 l
Page Two
Enclosure:
- 1.Bulletin 88-10 GPC Response
.c: Georaia Power Comoany Mr. H. C. Nix,. General Manager - Hatch
.Mr. L. T. Gucwa, Manager Engineering and Licensing - Hatch GO-NORMS U.S. Nuclear Reaulatory Commission. Washinaton. D.C.
Mr. L. P. Crocker, Licensing P.roject Manager - Hatch U.S. Nuclear Regulatory Commission. Reainn II Mr. S. D. Ebneter, Regional--Administrator.
Mr. J. E. ;Menning, Senior Resident Inspector - Hatch 04690 l
ENCLOSURE 1 RESPONSE TO IEB 88-10 NRC Reauested Action:
1.
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 (Claes it')
applications or commercial grade CBs that are being maintaintd as stored spares for future use in safety-related applications; th's includes CBs purchased from a CBM or from any other source.. If the number of these stored spare CBs is less than 50 at a nuclect plant 1111, 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 tiin.
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.
GPC Resoonse:
a.
Per item 1 of actions requested in IEB 88-10, it was determined that 121 molded-case circuit breakers (MCCBs) were being maintained as stored spares for future use in safety-related applications at Plant Hatch units 1 and 2.
b.
Per the definition of verifiable traceability listed in the bulletin, 108 breakers were traced to the circuit breaker manufacturer (CBM) by verifying the procurement chain. The procurement chain was verified by reviewing purchase orders, certificates of conformance, invoices and shipping documents on sits for CBs purchased directly from a CBM.
For CBs purchased through a supplier other than a CBM, invoices and shipping documents were obtained from the supplier which provided proof of purchase and shipping directly from the CBM.
The remaining 13 breakers were determined to be untraceable to the CBM.
This determination was made when the CB supplier purchased CBs from a subsupplier and the subsupplier could not provide documentation to support proof of purchase directly to CBM.
c.
Details requested per bulletin item 1.c concerning the untraceable MCCBs are listed in Table 1.
04690 HL-395 E-1
ENCLOSURE 1 RESPONSE TO IEB 88-10 NRC Recuested Action 1 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.
GPC Response:
No installed breakers were required te be reviewed for traceability per Item 1 above since a warehouse population of 121 breakers was established. However, upon discovery of the 13 untraceable breakers in warehouse stores, a review of breakers which had been supplied under the same purchase orders and subsequently withdrawn from the warehouse was made. This review determined that 7 untraceable CBs were installed.
Three CBs were installed in safety related applications. (Details are provided in Table 1).
These CBs were replaced within 30 days of discovery.
Four CBs were installed in nonsafety-related applications.
These four breakers are still installed. At this time, no action will be taken pending the development of GPC's program for addressing non-safety related CBs.
NRC Reauested Action:
3.
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 Attachment 1.
Any installed 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 testing program described in.
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.
GPC Response:
Georgia Power Company is presently pursuing testing of the untraceable breakers identified per bulletin item 1.
It is anticipated that testing will be completed by May 30, 1989.
Should the failure rate be greater than 10 percent, a documentation search will be performed to locate any untraceable breakers purchased between August 1,1983 and August 1,1988 that are installed in safety-related applications per bulletin item 4.
04690 HL-395 E-2
ENCLOSURE 1 RESPONSE TO IEB 88-1Q NRC Reauested Action:
4.
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-related applications as replacements or installed during modifications.
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 (4a) that cannot be traced to the CBM.
For installed CBs, also identify each system in which they are/were installed.
GPC Resoonse:
The projected. schedule for this search (if necessary) is as follows:
Reauired Action Comoletion date Complete documentation search August 1, 1989 for unit 2.
Prepare JCOs if necessary August 30, 1989 Replace or test any untraceable December 1, 1989 MCCBs found installed ' t safety-(projectedoutage related applications in unit 2 end date)
(if less than 75)
Complete documentation search March 1, 1990 for unit 1.
Prepare JCOs if necessary March 30, 1990 04690 HL-395 E-3
ENCLOSURE 1 (Continued) l RESPONSE TO IEB 88-1_Q 1-Replace or test any untraceable June 1, 1990 MCCBs found installed in safety-(projected outage related applications in unit 1 end date)
(if less than 75)
Replace remaining untraceable June 1, 1991 MCCBs in unit 2 (projected outage end date)
Replace remaining untraceable December 1, 1991 MCCBs in unit 1 (projected outage end date)
NRC Reauested Action:
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 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 after March 1, 1989.
The remaining CBs should be replaced or tested before startup from the second refueling outage beginning after March 1, 1989.
GPC Response:
See response to item 4 above.
04690 HL-395 E-4
1 ENCLOSURE 1 (Continued) t RESPONSE TO IEB 88-10 NRC Reauested Action:
6.
Information generated while performing the actions requested in 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.
GPC ResDonse:
GPC will retain the information as required by item 6.
NRC Reauested Action:
7.
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 the CBM, in compliance with applicable industry standards, and upgraded to safety-related by the licensee or others using an acceptable dedication program.
GPC Resoonse:
As a result of the traceability search for stored MCCBs per bulletin item 1, all MCCBs being maintained as stored spares for future use in safety-related applications meet the the intent of the requirements of bulletin item 7.
All future purchase orders for MCCBs will be made directly to the CBM or will request documented proof of traceability to the CBM from the supplier. Along with the current procurement review program, this will provide additional assurance that MCCBs received will meet the intent of the criteria specified in bulletin item 7 (i.e., audits of suppliers will be conducted in accordance with GPC's Qualified Suppliers Program rather than on a per purchase order basis as referenced in the clarifications to NRCB 88-10).
Georgia Power Company is closely following industry efforts to address procurement issues similar to those described in this bulletin.
04690 HL-395 E-5 l
ENCLOSURE 1 (Continued)
RESPONSE TO IEB 88-10 NRC Reguested Action:
8.
Addressees that cannot meet the schedule for the actions requested above and/or the corresponding reporting requirements below, should justify to the NRC their proposed alternative schedule.
GPC Resopnie;.
GPC will meet the bulletin schedule as reflected in the response to bulletin item 4.
Mditional Information:
A conference call was held on March 13, 1989 with Ms. Deanna McCombs and Mr. Jeff Branum of Georgia Power Company and Mr. Paul Gill of the NRC to discuss:
1.) The possibility of an alternate testing plan for the MCCBs identified as untraceable in the warehouse search per bulletin item 1 and 2.) For clarification of bulletin item 2 concerning the time frame to initiate JCOs for untraceable breakers.
These items were discussed as follows:
1.
Mr. Gill stated that utilizing the option given in 2.4 of a low voltage was considered by the NRC as a nondestructive test.
However, GPC has received input from Westinghouse that the overload test listed as item 2.4 in the bulletin test program was used in MCCB production as a destructive test. GPC has, therefore, concerns regarding inclusion of this test in the bulletin testing plan.
2.
Bulletin item 2 concerning JCOs to be prepared for untraceable MCCBs identified per bulletin items 1 or 4 has been interpreted by Georgia Power Company to state that a JC0 should be prepared within 30 days of the completion of item 1 or item 4 as opposed to 30 days from the identification of each individual breaker.
This interpretation is consistent with the option for successfully testing a sample of untraceable breakers precluding any further identification of installed MCCBs and the extended schedule given by the NRC for completion of corrective action. Mr. Gill concurred with this interpretation.
A full report of all action related to IEB 88-10 will be submitted to NRC in accordance with the reporting requirements listed in Item 2, page 6 of the bulletin.
04690 I
HL-395 E-6
l 1
TABLE 1 IEB 88 NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS HATRIX OF UNTRACEABLE MCCBs MODEL # : Westinghouse HFB3110ML PURCHASE ORDER : E58095 PROCUREMENT CHAIN:
Supplier :
Golden Isle Supply Sub-Supplier :
HLC Electric Supply Company QTY Location Comments
~
1 MCC 2R24-S013 NONSAFETY - Powers chemical drain sump pump, 2G11-C101. (SMI # 88102416, MHO #
2-87-4627) 1 MCC 1R24-S014 NONSAFETY - Powers reactor building equipment drain sump pulp 1Gil-C007A (SMI #
88103862, MHO # l-88-1649) 1 Corp. office SAFETY - Previously installed in 1R24-S011, powered Core Spray Jockey Pump, IE21-C002A.
Has replaced with traceable breaker. Taken to Corporate office to await possible testing.
1 Corp. office Harehouse stock previously located in stores. Taken to Corporate office to await possible testing.
MODEL # : liestinghouse HFB3150 PURCHASE ORDER : E50332 PROCUREMENT CHAIN:
Supplier :
Golden Isle Supply Sub-Supplier :
California Breaker, Inc.
QTY Location Comments
-_=
. = _. _. _
_ = = = = = _ -_
_===
_=
3 Corp. office Harehouse stock previously located in stores. Taken to Corporate office to await possible testing.
04690 HL-395 E-7
TABLE 1 (Continued)
IEB 88 NONCONFORMING M0LDED-CASE CIRCUIT BREAKERS-MATRIX OF UNTRACEABLE MCCBs-M0CEL # : Westinghouse HFB3190MRL PURCHASE ORDER : E50344 PROCUREMENT CHAIN:
Supplier :
Golden Isle Supply Sub-Supplier :
California Breakers, Inc.
QTY Location Comments 1
MCC 1R24-S043 NONSAFETY - Powers condensate demineralized bypass valve IN21-F254. (SHI # 88111697, MHO # 1-88-7483) 8 Corp. office Harehouse stock previously located in stores. Taken to Corporate office to await possible testing.
MODEL # : Westinghouse HFB3050L PURCHASE ORDER : B41679 PROCUREMENT CHAIN:
Supplier :
B & S Electric Sub-Supplier :
General Magnetic / Electric Wholesale QTY Location Comments 1
MCC 1R24-S017 NONSAFETY - Spare breaker per Maintenance Work Order and Design Drawing H-17019. (SMI
- 88112103, MHO # 1-88-5309) 2 Corp. office SAFETY - Previously installed in 1R24-S026, powered Diesel Generator Battery Chargers, 1R42-S032B & D.
Has replaced with traceable breaker.
Taken to Corporate office to await possible testing.
1 Corp. office Harehouse stock previously located in stores. Taken to Corporate office to await possible testing.
04690 HL-395 E-8
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