NRC-89-0153, Forwards Response to NRC Bulletin 88-010, Nonconforming Molded-Case Circuit Breakers. Documentation for Verifiable Traceability to Circuit Breaker Mfg for Circuit Breakers Available & on File at Facility

Forwards Response to NRC Bulletin 88-010, Nonconforming Molded-Case Circuit Breakers. Documentation for Verifiable Traceability to Circuit Breaker Mfg for Circuit Breakers Available & on File at Facility

ML20246D781
Person / Time
Site:	Fermi
Issue date:	07/06/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-89-0153, CON-NRC-89-153 IEB-88-010, IEB-88-10, NUDOCS 8907110425
Download: ML20246D781 (8)

Text

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' O. It/ph SyttlJ Senior vice President D.etroi.t.

6400 North Dixie Highway Edison==~~

July 6,1989 NIC-89-0153 U. S. Nuclear Regulatory Cmunission Attn: Document Control Desk

~ Washington, D. C.

20555

References:

1) Fermi 2-NIC Docket No. 50-341 i

NRC License No. NPF-43 2)

NIC Bulletin No. 88-10: Nonconforming Molded-Case Circuit Breakers, dated November 22 1999

3) Detroit Edison Letter to NIC, " Response to NIC Bulletin 88-10", IGC-89-0078, dated March 31, 1989

Subject:

Resubmittal of the Response to NIC Bulletin 88-10 Reference 3 subnittEd Detroit Edison's response to the NIC Bulletin 88-10 (Reference 2). The response contained a table listing the stock number and other detailed information for all of the safety-related molded-case circuit breakers stored in our warehouse. Subsequently, a review has indicated that the table required a few minor corrections to sme circuit breakers' warehouse location and purchase order number.

However, these corrections do not change the substance of our response to Bulletin 8&-10 and all circuit breakers listed have verifiable traceability to the circuit breaker manufacturer.

Enclosed is our emplete response to Bulletin 88-10 with the corrected table.

If you have any questions, please contact Mr. Girija Shukla at (313) 586-4270.

Sincerely, CLb}

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July 6; 1989 NRC-89-0153

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s 't I, B. RALPH SYLVIA, do hereby/ affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

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B. RALP6 SYLy'J1.

Senior Vice President on this I4 day of'

,1989, before me personally. appeared B. Ralph SyhFia, %ing first duly sworn and says that he. executed the foregoing as his free act ard deed.

. SHARGN K. B'JCK'd.Y h0iARY PUBUC-MONh0E Cat N!Y. IEli.

fJY COMMISSION D.PiRES 7 28-92 Notar Public A& TW"-

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Enclosure to tmC-89-0153 Page 1 l

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RFSPONSE 'ID NIC BUILETIN 88-10 I

' Detroit Edison's response to each item of the NIC Bulletin 88-10 is

'given below:

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NIC Bulletin 88-10 Action 1 All addressees are requested to perform the following review by March 1, 1989:

6.

Identify all molded-case CBs purchased prior to August 1, 1988, that are being maintained as stored spares for safety-related (Class lE) 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 rxx3ifications to form a mininum sangle of 50 CBs per nuclear plant site.

b.

Verify the tracealeility of these CBs.

c.

Identify the number, manufacturer, model number, and to the extent possible the pr.ocurenent chain for all those CBs identified in (la) that cannot be traced to the CBM. For installed CDs, also identify each system in which they are/were installed.

Detroit B31 son's Resporme 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 during plant construction were not in the scope of this investigation in accordance with paragraph 4, page 2 of MIC Bulletin 88-10.

a.

The attached table provides a listing of stored spare 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 ard on file at Fermi 2.

Enclosure to l

NIC-89-0153 Page 2 c.

Not applicable because the entire inventory of spare circuit breakers intended for safety-related applications are traceable to the CBM.

o NIC Bulletin 88-10 Action 2 All' holders of operating 1icenses 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.

Detroit Edison's Response to Action 2 This action is not applicable to Fermi 2 because the ntmber of stored spares are greater than 50 and all are traceable to the circuit breaker manufacturer.

o NRC Bulletin 88-10 Action 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 1

described in Attactment 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 CDs 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 beginning l

af ter March 1,1989. Holders of construction permits are requested to complete this testing program before fuel load.

Detroit Filison's Response to Action 3 This action is not applicable because the number of stored sparer j

are greater than 50 and all are traceable to the circuit breaker manufacturer.

o NIC Bulletin 88-10 Action 4 All cddressees who identify less than 80 percent of the CBs j

traceable to the CBM per item 1 above or who identify a failure l

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Enclosure to ImC-89-0153 Page 3 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 tra:eability of these CDs.

c.

Identify the number, manufacturer, raodel number, systwn in which they are/were installed, and to the extent possible, the procurement chain for all those CBs identified in (4a) that cannot be trcced to the CBM.

Detroit D31 son's Besoonse to Action 4 This action is not applicable to Fermi 2 because all of the stored spare circuit breakers are traceable to the circuit breaker manufacturer.

o NIC 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.

q 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.

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Holders of construction permits are requested to replace or to I

test these installed CBs before fuel load.

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Enclosure to NIC-89-0153.

Page~4' Dat;goit B51 son's mannnsm to Action 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 NIC Dulletin 88-10 Action 6

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Information generated while performing the actions requested in items 1, 2, 3, 44 and 5 above should be docunented and maintained

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-for-a period of 5 years after the conpletion of all requested actions.

Detroit R31 son's ResixnnBE to Action 6 Information generated while performing actions 1 through 5 is docunented and available on file. at Fermi 2.

'Ihece files will be

. maintained for a period of 5 years.

o NIC Bulletin 88-10 ActigL2 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 l

l b.

Procured frcra a CBM or others with verifiable traceability to l

the CBM, in compliance with applicable industr,7 standards, and upgraded to safety-related by the licensee or others using an

-acceptable dedication program. The NPC encourages addressees to significantly upgrade their dedication programs through a joint industry effort to ensure their adequacy and consistency. The NIC will monitor these industry initiatives and if they are not sufficient or not timely, or if problems with the dedication of conarcial grade equipment for safety-related use continue, the Imc will take appropriate regulatory actions.

Detroit Bilson's Response to Action 7 a.

Detroit Edison has not procured any safety related molded-case circuit breakers since August 1,1988. The standard attachment P-55 to procurement docunents for molded-case circuit breakers effective March 1,1989 requires that future i

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7' n, ~l .; o _. Enclosure'to NRC-89-0153 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 aM dedicated on site for safety-relatcd application in accordance' with procedures based on EPRI NP-5652 guidelines. o NIC Bdletin 88-10 Action 8 Maressees that cannot meet the schedule for the actions requested above and/or the corresponding' reporting requirements below, 'should justify to the' NIC their proposed alternative schedule. Detroit Blison's Bescanse to Action 8 The schedule for the actions requested in Bulletin 80-10 has been satisfied and this action is not applicable to' Fermi 2. o-Nic Bulletin 88.-10 Beoortino Requirement 1 All holders of operating licenses are required to provide a written 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 spares for future use in safety-related applications. b. Summarizes the total number, manufacturer, model number, and to the extent possible the procursent chain of those CBs that could not be traced to the CBM in items 1 and 4 of the actions requerted. 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 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 empleted or will be implemented as requested. l )

p { ~ ~ ~ ' - ~ ~ ~ R + .I:nclosure to .IGC-89-0153 b. Fage 6 ' Detroit Mison's W to Beoortina Beauir-t 1 This letter provides the required written report. a. A total quantity of fifty-eight safety-related molded-case L_ circuit breakers conprising of fifteen different model numbers were accounted for in the existing inventory of stored L -spares. Investigation of. these circuit breakers stored 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 10CFP50 Appendix' B quality I' . assurance program. The remaining twenty-four CB's were procured camercial 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, L 4, 5, 6, & 7 all actions have been completed. o Nic Bulletin 88-10 Beoortina 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 'S 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, rodel number, and to the extent possible the procurment chain of CBs tested (summary report format is acceptable). For CBs that fail these test (s), these reports should indicate the test (s) ard the values of test parameter (s) at which the failure (s) occurred, as well as the corresponding manufacturer, model number, ard to the extent possible, the procurement chain. Detroit Mison's W to Reportina Requirement 2 No tests were requirca to be corducted. Hence, this requirement is not applicable to Fermi 2. o NIC Bulletin 88-10 Reportina Requirements 3 and 4 Note: These requirements are related to holders of construction permit only and are not applicable to Formi 2.

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