ML20247Q870
| ML20247Q870 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/31/1989 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, NYN-89071, NUDOCS 8906070070 | |
| Download: ML20247Q870 (9) | |
Text
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.t George S. Thomas New Hampshire weenecoen = c*a - n Yankee NYN-89071 May 31, 1989 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk
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) PSNH Letter NYN-89035 dated March 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 update report describing the New Hampshire Yankee'(NHY) ongoing and planned actions, in response to NRC Bulletin 88-10, to ensure that Class 1E molded case circuit breakers (MCCB's) installed or in inventory at Seabrook Station Unit 1 were procured from a circuit breaker manufacturer (CBM).
As of May 8, 1989, a total of three hundred eighteen (318) Class 1E MCCB's had been identified in the Seabrook Station Unit 1 inventory system.
Of these, two hundred fifty (250) are supported by documentation sufficient to establish verifiable traceability as defined by the Bulletin, The remaining sixty-eight (68) Class 1E MCCB's in inventory have been segregated and are administratively controlled to prevent their use in any application.
These segregated MCCB's will be retained for at least one year or until further notice from either the NRC or the Nuclear Management and Resources Council (NUMARC). The sixty-eight (68) segregated MCCB's have been externally inspected for signs of refurbishment or prior use in accordance with the guidelines of the CBM provided through NUMARC [Refere,nce (c)). To date no suspect MCCB's have been identified as a result of this external inspection.
8906070070 890531 ADOCK0500gj3 PDR 0
New Hampshire Yankee Division of Public Service Company of New Hampshire
/
P.O. Box 300
- Seabrook, NH 03874
- Telephone (603) 474-9521
[I
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United States Nuclear Regulatory Commission May 31, 1989 Attention: Document Control Desk Page 2 As of May 3, 1989, a total of twenty-three (13) Class 1E MCCB's had been identified as issued from inventory to safety-related applications in Seabrook Station Unit 1.
Of these, fifteen (15) are supported by documentation sufficient to establish verifiable traceability.
The remaining eight have been replaced with Class 1E MCCB's having verifiable traceability. Each of the eight replaced MCCB's will be segregated in inventory, retained for a year, and externally inspected as described above.
Class 1E MCCB's within the scope of NRC Bulletin 88-10 were purchased from nine different suppliers. Of a total of three hundred forty-one (341)
MCCB's purchased from these nine suppliers, two hundred sixty-five (265), or approximately 78 percent, have been determined to be verifiably traceable.
However, based upon letters received from four suppliers, NHY has a high degree of confidence that at least 308, or over 90 percent, of the total Class 1E MCCB's have been purchesed from a CBM. A detailed summary of procurement chain information established to date for the seventy-six (76)
Class 1E MCCB's not having verifiable traceability is provided in tabular form in Enclosure 2 to this letter. to this letter provides a more detailed explanation of the actions taken to date and planned by New Hampshire Yankee in order to complete the requests of NRC Bulletin 88-10.
An update report on these actions will be provided by August 11, 1989.
Should you require further information regarding this matter, please contact Mr. Geoffrey Kingston at (603) 474-9521, extension 2371.
Very truly yours, l
Georg S. Thomas Enclosures 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 Nuclear Regulatory Commission l
Division of Reactor Projects Washington, DC 20555 NRC Senior Resident Inspector P.O. Box 1149 Seabrook Station, NH 03874
.. j
. United States Nuclear Regulatory Commission May 31, 1989 Attention: Document Control Desk Page 3-STATE OF NEW HAMPSHIRE l'
Rockingham, ss.
May 31, 1989 Then percenally appeared before me. the above-named George S. Thomas who, being duiy sworn, did state that he is Vice President - Nuclear Production 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 Public Service Company of New Hampshire, and that the statements therein are true to the best of his knowledge and belief.-
D M b b b eu4 Beverly E. '51110way, Notary Egblic My Commission Expires: March 6, 1990 l
1'
1 ENCLOSURE 1 TO NYN-89071 Detailed Description of Actions Taken and Planned in Response to Bulletin 88-10 The first 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 Raquested 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, had been purchased new from a circuit breaker manufacturer (CBM).
In order to perform this action, a search of the Unit 1 inventory system records was performed to identify the number of Class 1E MCCB's in inventory Le Of January 30, 1989. The August 1, 3988 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 poscible.
The results of this records search indicated 306 Class 1E MCCB's in Unit 1 inventory cs of January 30, 1989. On-site purchase order records for these 306 MCCB'c were then checked to determine, to the extent possible, their procurement chain.
During the first quarter of 1989, letters were initiated to suppliers of these MCCB's as necessary to supplement the on-site information regarding traceability to the CBM. Additionally, during a vendor surveillance performed on the premises of Telemecanique, Westminster, MD., NHY reviewed the Telemecanique procurement records directly related to NHY purchase orders to Telemecanique for Class lE MCCB's.
The result of the above actions, reported in Reference (d), was that 244 of the 306 Class IE MCCB's were traceable to the CBM.
Traceability to the CBM of 243 of these 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 to the CBM on the basis of available documentation.
Subsequent to March 31, 1989, a review was conducted of 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 report of the vendor surveillance at Telemecanique. As a result of this review, minor revisions to the figures reported in Reference (d) were made. 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 to a CBM.
The reduction in the number of MCCB's traceable to the CBM from 244 to 243 was the result of a revised determination that the COMSIP-supplied MCCB did not have verifiable traceability. _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _
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, receipt inspections of MCCB's included checks for external signs of refurbishment. As of March 31, 1989, L
only Class 1E MCCB's having verifiable traceability could be issued from inventory to safety-related applications in Seabrook Station Unit 1.
As of April 30, 1989, requirements to provide additional 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 verifiable.
7 L
It was recognized that, during the interval between the initial January 30, 1989, inventory records search and the April 30, 1989, establishment of all MCCB-related administrative controls, the number of Class 1E MCCB's in inventory could have changed due to receipt or issuance activity.
Therefore, to ensure that all potentially non-traceable Class 1E MCCB's in inventory were identified, the inventory records search was updated to May 8, 1989.
This update identified 318 Class 1E MCCB's in inventory as of May 8, 1989, 250 of which were traceable to a CBM.
Sixty-eight (68) Class 1E MCCB's not having verifiable traceability were identified in inventory.
These sixty-eight (68) MCCB's not having verifiable traceability have been segregated in the warehouse and will not be issued for use in any equipment or discarded for at least one year or until further notice from either NRC or NUMARC. Additionally, an external visual inspection was performed on each.of these sixty-eight (68) and will be performed on any subsequently-segregated MCCB's.
The external inspection is based upon guidance from the CBM provided through the NUMARC Industry Initiative on Molded Case Circuit Breakers [ Reference (c)) and has the objective of identifying any external signs of refurbishment, prior use, or alteration from the as-new condition. The inspection of sixty-eight (68) MCCB's segregated in inventory did not identify any suspect MCCB's.
The procurement chain has been determined to the extent possible for sixty-eight (68) MCCB's segregated in inventory. The information requested by the Bulletin for these MCCB's is tabulated in Enclosure 2.
Efforts are.
continuing to determine, to a further extent, the procurement chain of three MCCB's listed in Enclosure 2:
two supplied by Elgar and one supplied by Telemecanique. Additional information from Elgar has been requested.
Additional information from Telemecanique, if available, will be obtained during a future vendor source surveillance.
Supplemental traceability information, if obtained, will be included in the August 11, 1989 update.
i __-_________- _ -_--- _
=_.
NHY has received correspondence from Telemecanique, Inc. attesting to the traceability to the CBM of all MCCB's purchased from Telemecanique and its predecessors as either spares or replacements for MCCB's installed in j
type 5600 motor control centers.
Therefore, although strict " verifiable traceability" (as defined by the Bulletin) of some Class 1E MCCB's supplied by Telemecanique.or its predecessors cannot be established NHY has a high degree of confidence that all MCCB's supplied by Telemecanique or its predecessors were obtained new from the CBM.
Similarly, NHY has received letters from three additional suppliers, Basler Electric, Vitro Corporation and COMSIP, Inc., indicating that a total of fifteen (15) Class 1E MCCB's supplied to Seabrook by these suppliers were purchased from CBM's.
Therefore, of a total of 341 MCCB's within the scope of the Bulletin supplied to Seabrook by nine (9) suppliers, NHY has a very high level of confidence that at least 308 or over 90 percent have been procured new by the suppliers from a CBM.
Based upon the results of the procurement chain determination for Class 1E MCCB's in inventory, it was determined that the appropriate follow-up cetion, in accordance with the requests of the Bulletin, was to proceed with the specified 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 installed in safety-related applications as replacements or as part of modifications. To ensure identification of all such MCCB's installed in Seabrook Station Unit 1 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. A combined inventory system records search and work control program documentation review was performed to identify Class 1E MCCB's issued from inventory for use in safety-related applications at Seabrook Station Unit 1 during this five and three-quarter year interval. As of May 3. 1989, twenty-three (23) Class 1E MCCB's have been identified as issued from inventory to safety-related applications in Unit 1.
Of these twenty-three (23), eight were determined to not have verifiable traceability.
Seven of these eight were purchased from Telemecanique, and one was purchased from Sorrento Electronics.
Each of these eight MCCB's have been replaced with appropriate Class 1E MCCB's having verifiable traceability. The replaced Class 1E MCCB's will be segregated in inventory and not issued for any application, retained for at least one year or until further notice by NRC or NUMARC, and externally inspected for signs of refurbishment.
The information requested by the Bulletin for these eight MCCB's which had been installed in safety-related applications during the five and three-quarter year period are included in.
The records of Class 1E MCCB's identified as within the scope of NRC Bulletin 88-10 will be verified against MCCB's in inventory to confirm the numerical results of the actions performed to date.
The results of the verification will be included in the follow-up report to be provided by August 11, 1989. _.
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