ML20248G772
| ML20248G772 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/31/1989 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, ULNRC-1959, NUDOCS 8904130566 | |
| Download: ML20248G772 (6) | |
Text
l 1901 Gratiot Stieet Post 0thce B<u 149 St iouis, Missuun 63166 314-654 2650 Union oc" 's m "
Euzenue March 31, 1989 f,
h5 U.
S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail ~ Station F1-137 Washington, D.C.
20555 Gentlemen:
ULNRC-1959 DOCKET NUMBER 50-483 CALLAWAY PLANT NONCONFORMING MOLDED-CASE l
C_IRCUIT BREAKERS
Reference:
1)
NRC Bulletin No. 88-10 dated November 22, 1988 2)
F.
J. Miraglia (NRR) Letter to W. H. Rasin (NUMARC) dated February 17,-1989 3
i NRC Bulletin 88-10 was issued to address concerns that defective refurbished circuit breakers had been purchased for use in nuclear generating facilities.
The bulletin requires that all spare molded-case circuit breakers (MCCBs) stored for use in safety-related applications be identified and traced to the circuit breaker manufacturer (CBM).
NRC Bulletin 88-10 states that equipment procured during plant construction is not a concern, therefore MCCBs 4
purchased along.with installed equipment and delegated as spares were not considered in this review.
We have identified 78 safety-related MCCBs purchased by UE and maintained as stored spares for use at Callaway plant.
A documentation search was made to determine if the stored breakers had adequate traceability to the CBM, as defined in the bulletin.
Procurement documentation exists for each breaker and each was traceable to a certificate of Conformance (C of C).
Seven breakers were traceable to a C of C from the CBM and 71 were traceable to a C of C from a 10CFR50, Appendix B qualified supplier (Telemecanique).
l The acceptability of MCCBs from Telemecanique was confirmed by two source surveillance.
One was conducted by Wolf Creek Nuclear Operating Corp. on March 28, 1988.
The scope of this surveillance included verification of design control, part traceability, configuration control, part ggf 8BA4A83eIS$8Slkg3 r
g G
testing / inspection, and part certification of items procured by WCNOC.
This surveillance verified that Telemecanique has used a dedication program acceptable to Union' Electric.
On March 13 and 14, 1989, Union Electric participated in a joint utility surveillance to determine if the 71 MCCBs maintained as stored spares by Union Electric were traceable l
to the CBM.
We found that the 71 MCCBs were either procured directly from the CBM to fill UE purchase orders or allocated from Telemecanique's inventory.
The procurement chain for MCCBs procured specifically to fill Union Electric purchase orders was traceable to the CBM through Telemecanique purchase orders.
The procurement chain for the MCCBs allocated from inventory was established as being traceable to the CBM through the Telemecanique KARDEX inventory card system which identified requisitions and quantities ordered.
Each requisition on the card was traceable to a Telemecanique purchase order to the CBM.
The KARDEX system was established for inventory purposes.
Some pre-1984 cards were not located and some inventory adjustments were recorded that did not refer to a requisition.
This prevented verification of a complete inventory balance.
Lack of a complete inventory balance is not considered to be evidence of fraudulent refurbished MCCBs, particularly when each requisition on the KARDEX card was traceable to a Telemecanique purchase order to the CBM.
We have concluded that the entire sample of 78 MCCBs
'i maintained as stored spares at Callaway Plant were either manufactured by a CBM under a 10CFR50, Appendix B program, or procured from a qualified supplier under a 10CFR50, Appendix B program in accordance with Action Item 7 of the bulletin.
The qualified supplier, Telemecanique, had verifiable traceability to the CBM and had upgraded MCCBs using an acceptable dedication program.
The definition of
" Verifiable Traceability" in Reference 2 (Final Clarifications to NRC Bulletin 88-10, Including Staff Comments of 2-17-89) is considered to be satisfied based on the UE surveillance of Telemecanique.
This surveillance found Telemecanique procurement documents for MCCBs to be consistently traceable to the CBM.
Based on the surveillance as described above, Union Electric's stock of spare MCCBs meets the requirement of Action Item 7 for future uce in safety-related applications.
No MCCBs have been procured and installed in safety-related applications at Callaway Plant since August 1, 1988.
3
P Since Union Electric was able to determine acceptable traceability on the 78 MCCBs maintained as stored spares, all appropriate action items from the bulletin have been completed.
Time constraints associated with the multiple utility surveillance of Telemecanique prevented completion of the actions until March 27, 1989.
No additional action on the part of Union Electric is required.
If you have any questions concerning this letter, please contact me.
ery truly yours,
~
7f -
h j
Donald ochne WEK/skn l
6 I
i
\\
L STATE OF MISSOURI )
)
Donald F.
Schnell, of lawful age, being first duly sworn upon oath says that he is Senior Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By Donald F.
Schnell Senior Vice President Nuclear SUBSCRIBED and sworn to before me this 3 M day of 1989 NM/_
CAHt5 ARA FAF NOI ARY FUBLIC, STATE OF MISSOURI hjy COMMISSION EXPlRES APRIL 22, 1989.
ST. LOUIS COUNTY,
a c
4 l.
l I
cc:
Gerald Charnoff, Esq.
f Shaw, Pittman, Potts & Trowbridge l
2300 N.
Street, N.W.
l Washington, D.C.
20037 l
Dr.
J. O. Cermak CFA, Inc.
l l
4 Professional Drive (Suite 110) j Gaithersburg, MD 20879 R.
C. Knop Chief, Reactor Project Branch 1 U.S.
Nuclear Regulatory Commission Region III 799 Roosevelt Road i
Glen Ellyn, Illinois 60137 l
Bruce Little Callaway Resident Office U.S.
Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 Tom Alexion (2)
Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Meil Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 U.S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Joe F. Colvin Nuclear Management and Resources Council 1776 Eye Street, N.W.
Suite 300 Washington, D.C. 20006-2496
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bcc:
D. Shafer/A160.761
/QA Record (CA-758) ituclear Date E210.01 DFS/ Chrono D.
F.
Schnell J.
E. Birk J. V.
Laux M.
A.
Stiller G.
L. Randolph R.
J.
Irwin II. Wuertenbaccher W.
R.
Campbell A.
C.
Passwater R.
P. Wendling D.
E.
Shafer D.
J. Walker O. Maynard (WCNOC)
N.
P. Goel (Bechtel)
T.
P.
Sharkey NSRB (Sandra Auston) l i
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