NRC-89-0078, Forwards Response to NRC Bulletin 88-010, Nonconforming Molded Case Circuit Breakers, Ensuring That Molded Case Breakers Purchased for Use in safety-related Applications Verifiably Traceable to Circuit Breaker Mfg
| ML20248E697 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/31/1989 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-89-0078, CON-NRC-89-78 IEB-88-010, IEB-88-10, NUDOCS 8904120339 | |
| Download: ML20248E697 (9) | |
Text
._ ___
e.
B. R;lph Sylvia Senios Vice President d
6400 North Dime Highwaj ISOD Newport. Mechigan 48166 (313) $66-4150 4
March 31,1989 NIC-89-0078 U. S. Nuclear Regulatory Commission Attn: Document Control Desk
' Washington, D. C.
20555 Peferences:
- 1) Fermi 2 NBC Docket No. 50-341 NIC License No. NPF-43
- 2) NIC Bulletin No. 88-10:
Nonconforming Molded-Case Circuit Breakers, dated November 22, 1988
Subject:
Response to NIC Bulletin 88-10 This is to provide Detroit B31 son's response to the NIC Bulletin 88-10 (Reference 2). Detroit Edison has reviewed the Bulletin and has ensured that molded-case circuit breakers purchased for use in safety-related applications have verifiable traceability to the circuit breaker manufacturer.
Specific response to the actions requesta3 by the Bulletin 88-10 is provided in the Enclosure of this letter.
If you have any questions, please conca:t Mr. Girija Shukla at (313) 586-4270.
Sincerely, b
Enclosure j
cc:
A. B. Davis R. C. Knop W. G. Rogers J. F. Stang I
\\
l 8904120339 890331 PDR ADOCK 05000341 Q
PDC 1
L_
h
p-V vsmc L
March 31, 1989 l
M C-89-0078 Page 2 l
I, B. PALPH SYLVIA, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and scurate to the best of my knowledge and belief.
Yhl fo B. PAIfH S)Y dIA Senior V4.ce President j
On this 8
day of Y /dA/ b
, 1989, before me personally appeared B. Ralph Sylvia, being first duly sworn and says that he executed the foregoing as his free act and deed.
RJNY h.
/X17W sitary Public RC1%!E A. ARMDTA N0ic!'r Pub!!O, Montco Ccunty, M1 IAyCommlas!cn D:p!rosJan.11,1992
'Enclosura to
^ '
NRC-89-0078' i
Page 1
'f RESPONSE TO NRC BULIETIN 88-10 Detroit Edison's response to each item of.the NRC Bulletin 88-10 is given below.
k
~
i
~~~~~
a NRC Bulletin 88-10 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,.
q i
.1988, that are being maintained as stored spares for safety-related (Class 1E) applications or commercial grade CBs l
that are being maintained as stored apares 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.
Identify the number, manufacturer, model number, and to the l
c.
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 l
are/were installed.
. Detroit Edison's Response to Action 1 Detroit Edison has completed the requested review and a summary of the action taken is given below. Circuit breakers (CB's) procured
'I during plant construction were not in the scope of this j
investigation in accordance with paragraph 4, page 2 of NRC
]
l 1
a.
The attached table provides a listing of stored spare I
molded-case circuit breakers intended for safety-related applications.
b.
Documentation for verifiable traceability to the circuit breaker manufacturer for the above circuit breakers is available and on file at Fermi 2.
1 L________-____2__________
l
h f
-c Enclosure 'o t
e NRC-89-0078-
[
Page 2 L
c.
Not applicable because the entke. inventory of spare circuit breakers intended for safety-related applications are traceable to the CBM.
o NRC Bulletin 88-10 Action 2
'All holders of operating licenses who identify installed CBs per item 1 above or item 4 below that'cannot be traced t'o a"CBM are
~
requested to prepare, within 30 days of the completton of each item, an analysis justifying continued operation until items 1 through 5 of the actions requested in this bulletin have been-completed.
Detroit Edison's Response to Action 2
, This action is not ' applicable to Fermi 2 because the number of
]
stored spares are greater than 50 and all are traceable to the circuit' breaker' manufacturer.
o NRC Bulletin 88-10 Action 3
~
All addressess 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 ther,e 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.
Ho17ers of' operating licenses are requested to complete this te:
ng program before startup from the first refueling beginning a'
- r March 1, 1989. Holders of construction permits are requested to complete this testing program before fuel load.
Detroit Edison's Response to Action 3 This action is not applicable because the number of stored spares are greater than 50 and all are traceable to the circuit breaker manufacturer.
o NRC Bulletin 88-10 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
L Enclo:ura to l
l NRC-89-0078 i
Page 3 H
l rate of more.than 10 percent for the CBs tested per item 3 above are requested to perform the following actions:
1 a.
Identify all' molded-case CBs that have been purchased between i
August 1, 1983 and August 1, 1988, and installed in
'l safety-related applications as replacements or installed l
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.
Detroit Edison's Response to Action 4 i
This action is not applicable to Fermi 2 because all of the stored spare circuit breakers are traceable to the circuit breaker manufacturer.
o NRC Bulletin 88-10 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 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 startuo 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 Holders of construction permits are requested to replace or to test these installed CBs before fuel load.
l l
I
v.
Enclosura to:
NRC-89-0078 Page 4' i
F Detroit ~ Edison's Response to iction 5 This action is not applicable to Fermi 2 because all of the stored.
spare circuit breakers are traceable to the circuit breaker manufacturer.
o NRC Bulletin 88-10 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.
L Detroit Edison's Response to Action 6 Information generated while performing actions 1 through 5 is documented and available on file'at Fermi 2.
These files will be maintained for a period of 5 years.
o NRC Bulletin 88-10-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 10CFR50, 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 j
joint industry effort to ensure their adequacy and 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 cegulatory actions.
t Detroit Edison's Response to Action 7 Detroit Edison has not procured any safety related molded-case a.
circuit breakers since August 1, 1988. The standard attachment P-55 to procurement documents for molded-case circuit breakers effective March 1, 1989 requires that future l
l:
u
Enclosur@ to NRC-89-0078 Page 5; procurement of safety related molded-case circuit breakers be traceable to the circuit breaker manufacturer.
b.
In the event, a CBM drops out of a 10CFR50, Appendix B program, the circuit breaker shall be procured commercial
-grade and dedicated on site for safety-related application in accordance with procedures based on EPRI NP-5652 p idelines.
t f
o NRC Bulletin 88-10 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.
Detroit Edison's Response to Action 8 The schedule for the actions requested in Bulletin 88-10 has been satisfied and this action is not applicable to Fermi 2, l
o NRC Bulletin 88-10 Reporting Requirement 1 All holders of operating licenses are required to provide a
.nritten report by April 1, 1989, that:
a.
Confirm that only molded-case CBs that meet the criteria of.
item 7 of the actions requested are being maintained as stored j
spares for future use in safety-related applications.
l b.
Summarizes the total number, manufacturer, r.odel 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 I
schedule for tests in item 3 of the actions requested, this information should be updated within 30 days of the completion l
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 i
requested.
)
1 1
Enclorura to NRC-89-0078 Page 6 Detroit Edison's Response to Reporting Requirement 1 This letter provides the required written report.
A total quantity,of fifty-eight safety-related molded-case a.
circuit breakera comprising of fifteen different model numbers were accounted for in the existing inventory of stored spares.
Investigation of these circuit breakers st'ored as stock show that these breakers are traceable to the circuit breaker manufacturer (CBM). Thirty-four of the CB's were procured from a manufacturer with a 10CFR50 Appendix B quality assurance program. The remaining twenty-four CB's were procured commercial grade and dedicated upon receipt.
b.
Not applicable because the entire inventory of spare circuit breakers are traceable to the CBM.
c.
As described under specific response to action items 1, 2, 3, 4, 5, 6, & 7 all actions have been completed.
i o
NRC Bulletin 88-10 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 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.
Detroit Edison's Response to Reporting Requirement 2 No tests were required to be conducted. Hence, this requirement is not applicable to Fermi 2.
o NRC Bulletin 88-10 Reporting Requirements 3 and 4 Note: These requirements are related to holders of construction permit only and are not applicable to Fermi 2.
(
l j
o97 s8 E
R
__ i - e U
3 3
7 1
_ 1 1
1 2
2 2
5 5
3 3
4 7
cCg C
8 8
8 8
8 8 _ 8 8
8 8
8 8
8 8
8 8
nRa O / / / / / / _ / / / / / / / / / /
R 1
0 0
1 1
1 1
8 8
8 8
1 0
0 8
0 ENP P
1 1
1 1
1 1
1 0
0 0
0 0
1 1
0 1
E D
r O-e C
r u
F t
R c
U a
C f
O u
R Q Q O Q Q Q Q-Q-
n P
C C
C Q Q Q Q C
C C
Q C_ 0 Q Q C-a M
2 r
0 0
8 2
2 _ 2 2
2 2
2 1
5 _ 7 7
8 3 -
e 1
3 1
3 3 _ 3 3
5 5
5 0
0 _ 4 4
9 7 -
k 3 _ 3 2
1 1
1 1
0 0
0 -
3-6 _ 5 5
8 _
0-a 6 _ 5 1 - 7 7
7 7
0 0
0 -
5-6 _ 5 5
3 _ 2 -
e R
6 _ 2 3-0 0
0 0
8 8
8 7 - 8 _ 2 2
5-1 r
I 1
4 0
1 1
1 1
2 2
2 5-5 4
4 5-6 _
B R
5 5
R 5 5 5
5 5
5 5
5-5 5
5 5-9 t
i u
1 c
P r
0 0
5 0
5 0
5 0
0 0
4 0
i 3
3 1
5 2
0 5
0 2
0 4
6 7
9 5
C 0
0 0
1 1
1 1
0 0
2 3
0 0
0 4
1 L
8 -
8 B
B B. B B
5 1
8 0
8 8
B 4
8 o
E 1
3 8
C 3
t
- 3 3 - 3 3
3 B
2 1
33 3
4 6
r D
3-3 1
O F
F C - J J-E E
B H
J C
E - E E
8 J
e e M
E E
C - F F - H H _ F E
Q C HH H 1
F r
l u
b t
a c e 6
6
- 6 6 8
8 8
- 3 3
a c 0
4 -
1 8 _ 8 8
8 8
8 - 8 8
3-4 - 9 9. 9 4
f a
1 1 - 4 9 - 7 7
7 7
0 - 0 0
9 4 - 6 6 _ 7 0
u r 1 - 0 7 - 3 _ 3 3
3 0 0
2 8
6 6 - 4 7
n t
38 8
_ 3 - 6 3 - 3 _ 3 3
3 -
1 -
1 1
6 7. 1 1 - 7 3
a O _ 8 - 8 6 0 0
1 -
1 1
0 1
1 1
- 9 6
M n
0_
0 9
P _ 2 - 2 1 - A - A A
A A - A A
1 3
A 2N8
-_ A - 2 1
o r i
- I /
e t
8T1 k
a 8E1 a
t L/
Y -
e n sL3 A -
r e
EC
- C -
C - C C
T._
B m
OO O RU K -
u D
- M.
C-
- R -
t c
C Y - Y V
E E
- TE i o R
- N-R - R R
U L - I - I - C U
u D
- O E - E E
Q E
. R - E Q
c N
- T T - T T
I R_
E E - L I
r D
D~H D
DDD T - T T
N N
V_
VE N _
i R
L L ~ T L
L-L - L A - A A
A O O O-A _
C r
E U UU U
U-U-
U B - B B
C S
B -
B-L C
e I _ O O
A - O - OO O
E I _ - - - - A E
y r
L G G NG _ GG GDD D
M D-N N-R M
b u
P - -
C - - - - - -
E A
W WE E
t P - E E
ME E - E E
C - C C-L M
O O-N L
d c
U-T T
- T _ T - T T
- E -
R R - E E
e a S - I I
- - I I - I I
ee e T-6 B - G T
i f
lp n
u p
a
_ E -
E u m U-
- C U
s Q-
- I Q
t N
- T N -
b m
I
- R I
t n
u e R
E - E -
A
- C A
E E -
S - S -
C E
- E C
p R
T -
U-U-
E T
- L E
, i U
n u T
L - L
- - L - L L - L HH L
E - -
L - L -
E o
q S - U U
U-U GG U
L - S U-U -
L-L i e C
U - U. N - O_O O. O N - N O
E - N OO - A - E t
A O-O _
F - GGE -
G_G-GG I - I G
T - E
_G G
R - T u
T - T
- - M-E-
b l
U - - - - - M -
a N - E - E - E - E-E-
E-E S - S E
E-E - E - E - N E
i n A - T - T - I - T - T - T - T E - E T
T - I - T - T - E. T _ 8 r i MI - I -
S-I - I - I - I W-W I
I - S - I - I - GI - 5 t
g s i i
r d
o N -
O-E - E - GF - E - A - E 8 - C I -
- E - D-
- s h
h I G 9 9 6 8 F 7 - r g
g T A 7 6 O-1W W-WO - J - J -
1 -
- k o o O - B 5 - e u u A - J - C - G-J _ J - J - J - J -
O1 -
C-2 -
1 1
1 1 - 1W W-lWF - J - J - F - A - a r
r C - J -
- G-J _
J-J - J - J -
1 I
1 1
1 I
- e h
h B-B B-B - B B-B - B B - D-r t
t L - B - Q-A -
8 _.
- B d
d 6 4 -
1 1 92 -
1
- 2.. 42 - t e e Y 5- 0.
5 __
- i c
c T -
1 Q-
- u a a
- c l
l
- r p
p O 5 3 5-6 8 7 - 2 _ 7 6 i N 0 2 2 6 6 3 3 7 - C r
r 3 3 3 3 3 4 4 4 -
e e K 7 9-9-
999 9-9 9 9 l d
d
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - a r
r C-1 9 - 9L 9 9 9-9-
9 9 9-t O
O O-1 T 8 8 8 8 8 8 8 8 - o S 6 6 6 6 6 6 6 T o