ML20248G260
| ML20248G260 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/03/1989 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, NUDOCS 8904130354 | |
| Download: ML20248G260 (6) | |
Text
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NRC Bulletin 88-10 u-4 PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699
- PHILADELPHIA A, PA 19101 (215) 841-5001 JOSEPH W, G ALLAGHER April 3, 1989 VIC E PNESIDENT Docket Nos. 50-352 50-353 License No. NPF-39 Construction Permit No. CPPR-107 l
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Limerick' Generating Station, Units 1 and 2 Response to NRC Bulletin 88-10, Nonconforming l
Molded-Case Circuit Breakers
Dear Sir:
The subject Bulletin requested that licensees take actions to provide reasonable assurance that molded-case circuit breakers
- (CBs), including CBs used with motor controllers, purchased for use in safety-related applications.without verifiable traceability to the circuit breaker. manufacturer (CBM) perform their safety functions.
The Reporting Requirements delineated in the Bulletin are restated below followed by our response.
Note that because the required reporting due date fell on a Saturday, this response is being submitted on the next Federal working day, April 3, 1989, in accordance with regulations.
1.
Reporting Requirement All holders of operating licenses are required to provide a written report by April 1, 1989, that:
N00 a.
Confirms that only molded-case CBs that meet the criteria
$o$
of item 7 of the actions requested are being maintained as
$8 stored spares for future use in safety-related gg applications.
Egf b.
Summarizes the total number, manufacturer, model number, i
no and to the extent possible the procurement chain of those 8@
CBs that could not be traced to the CBM in items 1 and 4 of g-the actions requested.
For installed CBs, also identify om each system in which they are/were installed.
If item 4 of j@o the actions requested has not been completed by April 1, 1989, due to the schedule for tests in item 3 of the gpg>f actions requested, this information should be updated
'\\
Docum:nt Control Deck April 3, 1989 Prgs 2 within 30 days of the completion of item 4 to address those additional CBs that could not be traced to the CBM.
c.
Confirms that items 1, 2,
3, 4,
5, 6, and 7 of the Actions Requested have been completed or will be implemented as requested.
Response
la. We have completed the traceability determination for approximately 55% of the molded-case CBs which are being maintained as stored spares at Limerick Generating Station (LGS)
Unit 1.
We are continuing to pursue traceability of the remaining 45% of molded-case circuit breakers being maintained as stored spares at LGS Unit 1, most of which were supplied by Eaton Cutler Hammer.
As of the issuance of this response, this supplier has not been able to provide us with traceability documentation for CBs which we purchased from them as safety-related.
We have'taken administrative actions to assure that only breakers which meet the criteria of item 7 of the Actions Requested can be released from stored spares for une in safety-related applications.
b.
Since we have not yet completed the traceability determination-for all of the molded-case CBs which are being maintained as stored spares, we have not yet begun any investigation into their procurement chain.
However, should we fail to obtain the proper traceability for any CBs in stored spares we shall provide this information in a supplement to this response.
c.
Item No. 1 of the Action Requested has been completed as discussed below.
a.
We have identified a total of 313 molded-case CBs being maintained as stored spares for safety-related (Class lE) applications for LGS Unit 1.
These CBs were manufactured by various CBMs and obtained through various suppliers as follows:
Stored Spares i
CBM Supplier Number I
Square D Thermon 2
ETA Simmons Precision 2
Westinghouse Eaton/ Cutler Hammer 225 Westinghouse CBM Direct 1
Eaton/ Cutler Hammer CBM Direct 75 ITE Gould/ Brown Boveri CBM Direct 2
1 ITE Gould Consip/Delphi 1
Heinnmann Simmons Precision 3
Heinnmann Sorrentto Electronics 2
T@I'AL 313
., Document Control Desk April 3, 1989
~
Pags 3 l
Or'iginally, during the identification process of the molded-case
]
CBs which are being maintained as stored'apares at LGS 1, we i
limited our scope to a sample of 50 CBs from stored spares based l
on our understanding of the Bulletin Requirements.
These 50 CBs identified and the investigation'into their traceability to l
were the CBM was begun prior to the required date of March 1,
- 1969, f
L specified in.the Actions Requested.
Subsequently, upon receipt i
of a letter from the Nuclear Management and Resources Council (NUMARC) to all nuclear utilities, dated March 9, 1989, which included as an Enclosure, " Final Clarifications of NRC Bulletin j
l 88-10...,"
we conc.luded that if there were more than 50 molded-case CBn wuich were being' maintained as stored-spares, all such CDs were required to comprise the initial set for traceability review.
Consequently, since an additional 263 CBs were not originally identified as a part of the initial sample, the traceability review for these CBs was not begun until March 28, 1989.
b.
We have verified the traceability of 173 CBs.
However, we have not received traceability documentation for 131 Westinghouse molded-case CBs which were ordered through Eaton Cutler-Hammer (50 of which made up the original sample).
We are also continuing with the traceability process for the remaining'CBs identified following the receipt of the March 9, 1989 letter from NUMARC.
We will notify you of.our results upon completion of the final traceability determination.
The applicabity of Items Nos. lc through 5 of the Actions Requested has not yet been established since the final traceability determination has not been made regarding the subject Westinghouse molded-case CDs.
j In accordance with item No. 6 of the Actions Requested, we shall maintain all of-the information obtained during this investigation for a period of 5 years.
Jn accordance with item No. 7 of the Actions Requested, future i
purchases of molded case circuit breakers intended for safety related use at LGS will be ordered from the equipment manufacturer with the requirements of 10 CFR 50, Appendix B, and 10 CPR 21 invoked.
If the purchase order is to be fulfilled by a supplier other than the manufacturer, the order will require documentation traceable to the manufacturer in addition to the 10 CPR 50, Appendix B, and 10 CFR 21 requirements.
2.
Reporting Requirement All holders of operating licenses are required to submit a report that summarizes available results of tests conducted in accordance with items 3 and 5 of the actions requested within 30 days af t<n* startup from the first and second refueling outages beginning after March 1, 1989.
For CBs that pass these tests, the only information required is the number, manufacturer, model number, and to the extent possible the procurement chain of CBs tested (summary report format is acceptable).
For CBs that fail these test (s), these reports should indicate the test (s) and the i
I I
i I
m
- t.. Doct; ment ControlE D sk April.3, 1989; Pagn 4 values.of test parameter (s) at whichthe failure (s) occurred, as l:
well as the corresponding manufacturer, model number, and to the' i
extent possible, the procurement chain.
RESPONSE
Since the final traceability of all CBs.which are being maintained as stored spares has not been determined no testing of CDs has occurred.
3.
Reporting Requirement All holders of construction permits are required to provide a written report by April 1, 1989, that:
a.
Confirms that only molded-case CBs~that meet the criteria of' item 7 of the actions requested are being maintained as stort - spares for. future use in safety-related applications.
b.
Summarizes the total number, manufacturer, model number, and to the extent possible the procurement chain of those CDs 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 i
additional CBs that could not be traceu to the CBM.
c.
Confirms that items 1, 3,
4, 5,
6 and 7 have been completed or will be implemented before fuel load.
RESPONSE
la.EAll molded-case CBs being maintained as stored spares for use at-LCS Unil 2 have been vo~ified traceable to the circuit breaker r
manufacture.
I b.
Not Applicable.
All CBs are traceable to the CBM.
c.
Item No. 1 of the Actions Requested has been completed as discussed below.
I a.
We have identified a total of 122 molded-case CBs being maintained as stored spares for safety-related (Class lE) applications for bGS Unit 2.
b.
We have verified the traceability of these CBs to the CBM.
I These breakers have been verified traceable from the supplier, Eaton, to the CBM, Westinghouse.
,,, Document Control Dsski April 3, 19891 Paga 5 It'em Nos. 1c through 5 of the Actions Requested are not applicable as all-CBs identified are traceable to.the CBM.
In accordance with item No. 6 of the Actions Requested, we shall'
~
maintain all of the information obtained during this investigation for a period of 5 years.
In accordance with item No. 7 of the Actions Requested, future purchases of molded case circuit breakers intended.for safety related use at LGS will be ordered from the equipment manufacturer with the requirements of 10 CPR 50, Appendix B,.and-10 CPR 21 invoked.
If the purchase order is to be fulfilled by a' supplier other than the manufacturer, the order will require documentation traceable to the manufacturer in addition to the-10 CPR 50, Appendix B, and 10 CFR 21 requirements.
4.
Reporting Requirement
~
All holders of construction permits are required to submit a report that summarizes the results of tests conducted in accordance with items 3 and 5 of the actions requested within 30 days after fuel load.
For CBs that pass these tests, the only information required is the number, manufacturer, model number, and to the extent possible, the procurement' chain (summary report format is acceptable).
For CBs that. fail these test (s),
the report should indicate the test (s) and the values of test parameter (s) at which the failure (s) occurred, as well as the corresponding manufacturer, model number, and to the extent possible, the procurement chain.
RESPONSE
Not Applicable.
All CBs being. maintained as stored spares for LGS Unit 2 have been traced to the CBM and therefore, no terting has been performed.
1 Very truly yours, 1
cc:
W. T. Russell, Administrator, Region I, USNRC T. J.
Kenny, USNRC Senior Resident Inspector, LGS Lo I
g ;, --
j y4 4
A 6
COMMONWEALTH OF PENNSYLVANIA c
' ~
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COUNTY OF: PHILADELPHIA 1
J. W. Gallagher, being first duly, sworn, deposes and'says:
'That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he han' read the foregoing Response to-NRC Bulletin 88-10 for the Limerick Generating Station, Units 1 and 2,'and knows'the contents thereof; and that the. statements and matters cet forth therein are true and correct to the.best of his knowledge, information and belief.
o Vice President Subscribed and sworn to before me this h day of f\\egr t, 1989.
i dt.h4 -?lnn J C Jotary ublic
~~ " I NOTARIAL SEAL JUDITHY FRANKUN. Notary Pubhc Cityof PMadelptwa,Phila County
]_ Commission Expres JJy 28.1991 y
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