ML20248G901
| ML20248G901 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/02/1989 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-010, IEB-88-10, NUDOCS 8904130620 | |
| Download: ML20248G901 (11) | |
Text
C.
- 1
't ver Valley Power Station Shippmgport, PA 15077 0004 I
v$$$$nfNewom, m2) 643 s2ss l
April 2, 1989 i
l l
U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk j,
Washington, DC 20555 1
Reference:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73
)
Response to NRCB 88-10 Gentlemen:
l As requested in NRC Bulletin 88-10, the following information is i
provided to address each of the reporting requirements.
Reporting Requirement 1.a:
Confirm that only molded-case CBs that meet the criteria of item 7 of the actions requested are being maintained as stored spares for future use'in safety-related applications.
Response
Duquesne Light Ccmpany has reviewed its stock of stored spares which-includes large quantities of breakers left over from construction of BVPS-2 and is withholding molded-case circuit breakers from future use if verifiable traceability to the circuit breaker manufacturer has not yet been established.
These items are tagged and may not be released unless the criteria of the Bulletin can be satistied.
Reporting Requirement 1.b:
Summarize the total number, manufacturer, model number, and to the extent
- possible, the procurement chain of those CBs 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 actione requested, this information should be updated within 30 days af the completion of item 4
to address those additional CBs that could not be traced to the CBM.
f5 8904130620 890402 PDR ADOCK 05000334
-Q PDC
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Beaver Valley Power Station, Unit Nos. 1&2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Response to NRCB 88-10 Page 2
Response
Attachments 1
through 3 provide a listing of those items currently in storage and being withheld from use. provides a listing of installed circuit breakers resulting from action item 4.
It should be noted that many items appearing on these i
attachments have been included only because traceability is not currently confirmed.
Duquesne Light Company is awaiting additional f
vendor documentation for many of these items.
Further confirmation efforts for these items will be pursued if necessary, or the breakers will not be used in safety related systems.
j Reporting Requirement 1.c:
Confirm that items 1, 2,
3, 4,
5, 6 and 7 of the actions requested have been completed or will be implemented as requested.
I
Response
Action Item 1 l
l All addressees are requested to perform the following review by March 1, 1989 1
a.
Identify all molded-case CDs purchased prior to August 1, 1988 1
that are being maintained as stored spares for safety-related (Class 1E) applications or commercial grade CBs that are being maintained as stored spares for future use in safety-related applications; this 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 nuclear plant site, 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 site.
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.
Action item 1
is completed.
This review included a relatively small quantity of breakers procured by Duquesne Light Company as well as a
much larger quantity of breakers procured by the Architect-Engineer and left over from construction.
Any of these could be, and are being used, as plant spares.
Bea'ver Valley Power Station, Unit Nos. 1&2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Response to NRCB 88-10 Page 3 Action Item 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.
With respect to Action item 2, stored spares exceeded the minimum of 50 specified in the Bulletin.
Within 30 days of identification, JCOs will be prepared for Items on Attachment 4, or those items will be tested, replaced, or verified traceable as outlined in the Bulletin.
Action Item 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 Attachment 1.
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.
Holders of operating licenses are requested to complete this testing program before startup from the first refueling outage beginning after March 1, 1989.
Holders of construction permits are requested to complete this testing program before fuel load.
Action item 3
was recently postponed prior to confirming 80%
traceability for stored spares and prior to implementation of a test program for the non-traceable ones.
This decision was based on the consideration of available resources and benefits to be obtained by expending those resources.
It became evident that with the large quantities of stored breakers on site and the schedule dictated by the Bulletin that the most efficient use of resources would be to conduct only a partial traceability search for each stored breaker and to proceed directly to actior item 4 withcut testing stored spares.
The option of testing stored spares is being reserved as a
last resort (obsolete breaker styles for l
example) but is not presently anticipated.
l
Bea'vor Valloy Power Station, Unit Nos. 1& 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Response to NRCB 88-10 Page 4 Action Item 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, system in which they are/were installed, and to the extent possible, the procurement chain for all those CBs identified in (4a) that cannot be traced to the CBM.
Identification of breakers installed as replacements, or as part of a
station modification, and a review of all applicable maintenance work requests is complete.
This review identified 15 installed breakers which would potentially fit the Bulletin's criteria for replacement breakers.
Twelve of these were found to be acceptable by virtue of their purchase date or verifiable traceability to the manufacturer.
Documentation for the remaining three is being pursued with the vendor.
Review of Engineering records is also complete.
This review identified 16 breakers.
Five are confirmed traceable at this time.
Duquesne Light Company is currently attempting to verify traceability for the others.
l I
Action Item 5 I
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 test 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.
L
Beaver Valley Power Station, Unit Nos. 1&2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Response to NRCB 88-10 Page 5 Action Item 5, (cont.)
Holders of construction permits are requested to replace or to test these installed CBs before fuel load.
Action item 5
is being implemented as requested.
As with spares, testing of installed items found by action item 4 is being reserved as an option of last resort.
Replacement is the preferred option and will be accomplished within the Bulletin's schedule.
Action Item 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.
This information will be maintained as requested.
Action Item 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.
The NRC encourages addressees to significantly upgrade their dedication programs through a joint industry effort to ensure their adequacy and i
consistency.
The NRC will monitor these industry initiatives and if they are not sufficient or not timely, or if problems with the dedication of commercial grade equipment for safety-related use
- continue, the NRC will take appropriate regulatory actions.
Action item 7 will be implemented as requested.
I i
~
Bedver Valloy Power Station, Unit Nos. 1&2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Response to NRCB 88-10 Page 6 Reporting Requirement 2:
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 after 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 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
We do not anticipate the need for testing at this time.
If testing is conducted, the requested information will be provided.
Reporting requirements 3 and 4 apply to construction permit holders and are not applicable to Duquesne Light Company.
Very truly yours, D.
Sieber Vice President Nuclear Group cc:
Mr. J.
Beall, Sr. Resident Inspector w/ attachment Mr. W. T. Russell, NRC Region I Administrator w/ attachment Mr.
P.
Tam, Sr. Project Manager w/ attachment i
. COMMONWEALTH OF PENNSYLVANIA)
).
SS:
COUNTY OF BEAVER
)
On this
///
day of
,-1989, b&
MY ',
Notary Public in and for said, before me, a
commonwealth and
' County, personally appeared J..D.
Sieber, who being.
duly
- sworn, deposed, and said that (1) he is Vice President'of Duquesne
- Light, (2) he is duly authorized.to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth-in the Submittal are true and correct.to the best of his knowledge, information and belief.
L Jt'[ av # tar /s 1
/
NebM Seal Shelta M. Fa' tore, Notary Putic Sh.ppingrcrt Boro.Soaver County My Commtwion Egra Oct 23.1M9 Member, Perawyivare Moc.4Wo el Notaries
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