ML19324C247

Responds to NRC Bulletin 88-010,Suppl 1 Re Nonconforming molded-case Circuit Breakers.Util Believes All Provisions of Bulletin & Suppl Have Been Addressed as Required

ML19324C247
Person / Time
Site:	South Texas
Issue date:	11/07/1989
From:	Rosen S HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-88-010, IEB-88-10, ST-HL-AE-3285, NUDOCS 8911160013
Download: ML19324C247 (6)

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L 1.: The Light.

P.O. Ilox 1700 llouston, Texas 77001 (713) 228 9211 Houston Lighting & Power. .. - -- --

November 7 1989 ST-HL- AE- 328b File No.: C3.03 10CFR50

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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Electric Cenerating Station Units 1 and 2 Docket Nos. STN 50 498 and STN 50-499 Respqnse to NRC Bulletin 88-10. Sucolement 1 L Reference Letter from S. L. Rosen, HL&P, to NRC Document Control Desk, dated June 30, 1989 (ST-HL-AE-3150)

L The referenced letter is HL&P's final report addressir.g Bulletin 88 10 regarding Nonconforming Molded-Case Circuit Breakers (MCCBs). HL&P has reviewed its responses to the Bulletin, and compared them to the NRC positions described in Supplement 1 to the Bulletin. HL&P believes that all provisions of the Bulletin and its supplement have been addressed as required. Specific responses to the NRC position.s in the supplement are provided in the l l attachment. Documentation of the MCCB review substantiating the HL&P l

l. responses is available on site. .

, 1 I If you have any questions, please contact Mr. A. W. Harrison at (512) l 972-7298.

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S. L. Rosen  :

Vice President l Nuclear Engineering and Construction l SLR/AWH/n1 1 1

Attachment:

Responses to NRC Positions in IEB 88-10 Supplement 1 8911160013 891i07 I 1: PDR .ADOCK 05000498 Q PDC fs>l A1/030.NL9 l1 A Subsidiary of Ilouston Industries incorporated ig s

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' Ilointon Lighting & P6wer Cornpany I .~~I ST-llL AE-3285 File No.: C3.03 Page 2 cc:

Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaze. Drive, Suite 1000 llouston Lighting & Power Company Arlington, TX 76011 P. O. Box 1700 llouston, TX 77001 George ' Dick, Project Manager

!- U. S. Nuclear Regulatory Commission INPO

!. Washington, DC 20555 Records Center i 1100 circle 75 Parkway .

F-J. I. Tapia- Atlant <., CA 30339-3064 .

Senior. Resident Inspector s c/o U..S. Nuclear Regulatory Commission Dr. Joseph M. llendrie a I

P. O. Box 910 50 Bellport Lane Bay City, TX 77414 Be11 port, NY 11713 J. R. Newman, Esquire D. K. Lacker Newman & iloltzinger, P.C. bureau of Radiation Control

-1615'L Street, N. W. Texas Department of llealth -

Washington, DC 20036 1100 West 49th Street "

Austin, TX . 78756-3189 J. R. Newman, Esquire Newman & Holtzinger, P. C.

1615 L Street, N. W.

. Washington, DC 20036 R. L. Range /R. P. Verret.

L Central Power & Light Company L P. O. Box 2121 r L Corpus Christi, TX 78403 l

l R. John Miner (2 Copies)

L Chief Operating Officer l City of Austin Electric Utility 721 Barton Springs Road Austin, TX 78704 R. J . Costello/M. T. liardt City Public Service Board

?. O. Box 1771 San Antonio, TX 78296 A1/030.NL9 l

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. UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION  ;

In the Matter )

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Houston Lighting & Power ) Docket Nos. 50-498 Company, et al., ) 50 499

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South Texas Project )

Units 1 and 2 )

AFFIDAVIT S. L. Roaen being duly cworn, hereby deposes and says that he is Vice President', Nuclear Engineering and Construction of Houston Lighting & Power

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Company; that he is duly authorized to sign and file with the Nuclear Regulatory ,

Commission the attached update relative.te NRC Bulletin 88-10; is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge and belief.

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S . L. Rose'n .

Vice President, Nuclear Engineering and Construction Subscribed and sworn to before me, a Notary Public in and for The State of Texas this N day of MVEM4Eg ,1989.

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NBtary Public in and for the

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. . . Ik uston Lighting & Power Company l Attachment to ,

ST HL-AE-3285

, , Page 1 RESPONSES TO NRC POSITIONS IN IEB 88-10, SUPPLEMENT 1

1. If CBs are traceable to an original plant construction order and the CBs were. received prior to August 1983, there is reasonable

. assurance that the CBs are acceptable and no additional traceability ,

is required, i

STP Response: The STP traceability review encompassed the period from August 1983 to December 1988.

2. Visual inspection and physical examination of the CBs by the CBM is not considered adequate to meet the requested traceability provisions of Bulletin No. 88 10. Although visual inspection and physical examination by the CBM may provide a reasonable basis that the CBs have not been opened or altered in a substantial way, there is no reasonable assurance that the CBs have not been previously used or subjected to service conditions that may have adversely affected the performance capabilities of the CBs.

STP Response: STP did not use CBM inspection of safety related MCCBs as a basis for considering a MCCB as traceable.

3. Item 4 of the actions requested in Bulletin No. 88-10 applies only to CBs that were purchased and installed after August 1, 1983.

STP Response: Traceability was determined for MCCBs received at the South Texas Project (STP) between August 1983 and i December 1988. Only 6.5% of the MCCBs received were determined to be untraceable.

4. If an addressee identifies any CBs as nontraceable during the review requested by Bulletin No. 98 10, it should take appropriate corrective actions as required by Criterion XVI of 10 CFR Part 50, Appendix B. As part of these corrective actions, the NRC expects l addressees to assess the acceptability of all installed safety-l related CBs that were procured under the same purchase orders as the i I nontraceable CBs. I 1

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STP Response: Jorrective actions havo been taken for thoso MCCBs I which were found to be untraceable. Untraceable -

MCCBs in the warehouses have been segre6ated and are in hold areas.

Untraceable MCCBs installed in the field were.  ;

, documented and continued operation with the subject  ;

H breakers in place was justified. The Unit 1 y untraceable MCCBs were replaced in the first I refueling and the Unit 2 untraceable MCCBs will be replaced before restart after the Unit 2 first refueling outage. Traceability was verified for Safety related MCCBs that were procured under the same purchase orders as nontraceable MCCBs. l Note: Safety related spare or replacement MCCBs were not received at STP prior to August 1983 for '

those P.O.s where there were determined to be

• untraceable MCCBs.

5. In an effort to limit the number of nonconforming CBs in safety-related systems, nontraceable CBs that were installed or are being maintained as stored spares as of August 1, 1988, and that i successfully pass all tests specified in Attachment 1 of Bulletin No. 88-10 are considered acceptable for use only as replacements for safety related CBs that are found to be nontraceable during the review requested by Bulletin No. 88-10. These breakers may not be used as safety related replacements during other activities such as planned plant modifications or routine maintenance.  ;

! STP Response: For safety related applications, only traceable MCCBs are being maintained as spares or used as replacements.  ;

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6. For CBs stored as spares that were not procured directly from the

j. CBM, each individual CB should be reviewed in order to establish o proper traceability, regardless of the number of CBs.

l' STP Response: MCCBs received at STP from August 1983 to December 1988, whether they are spares or permanent replacements, have been investigated to determine '

traceability back to the original manufacturer. A documentation trail was conff.rmed for traceable MCCBs.

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HJuston 1.ighting k I'ower Company

- Attachment to 9 ST-llL AE-3285 i

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7. All safety-related CBs from the same procurement order.are considered traceable provided that 1) the-order was procured directly from a CBM having a' quality assurance program in accordance with 10 CFR Part 50, Appendix B, 2) the CBM has been audited by the

. addressee in accordance with Appendix B, 3) the CBs were ordered as safety-related,'and 4) documented evidence has been furnished to the I addressee, such as a certificate of compliance. Ilowever, if safety-related CBs were procured from a vendor other than.the CBM, a i: certificate of compliance by itself is not considered an adequate basis for establishing traceability. In such cases, traceability of individual procurement orders should be established through the

! review of procurement or shipping records back to the CBM. -

Telephone discussions with'the CBM or vendor are not acceptable for establishing a basis for traceability. Traceability to a warehouse facility controlled by the CBM is considered equivalent to traceability to the CBM.

STP Response: See response to position No. 6 above.

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