ML19324C254

Responds to NRC Bulletin 88-010,Suppl 1 Re Nonconforming Molded Case Circuit Breakers & Forwards Revised Summary of non-traceable Circuit Breakers Maintained as Stored Spares for safety-related Applications

ML19324C254
Person / Time
Site:	North Anna
Issue date:	11/07/1989
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
88-788F, IEB-88-010, IEB-88-10, NUDOCS 8911160021
Download: ML19324C254 (6)

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. i VIRGINIA El.ECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 November 7, 1989 United States Nuclear Regulatory Commission Serial No. 88-788F Attention: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen: ,

VIRGINIA ELECTRIC AND POWER COMPANY 1 AND 2 RESPONSE TO NRC BULLETIN NO. 88-10. SUPPLEMENT 1 NONCONFO'9 MING MOLDED-CASE CIRCUIT BREAKERS As requested by NRC Bulletin No. 88-10, Supplement 1, Nonconforming Molded-Case Circuit Breakers, the Virginia Electric and Power Company has reviewed the previous responses to NRC Bulletin No. 88-10 dated March 31, 1989 and May 5, 1989. It has been determined that the previous responses did not. completely meet the bulletin provisions as clarified by Supplement 1.

Specifically, the previous responses did not adequately identify 1) all molded-case circuit breakers (MCCBs) maintained as stored spares for safety related applications that could not be traced to a circuit breaker manufacturer or 2) MCCBs purchased between August 1, 1983 and August 1, 1988 and installed in safety related applications. Previous responses did adequately reflect the programmatic controls initiated to ensure that traceable MCCBs would be procured in the future.

In our original submittal we assumed that breakers ordered from Westinghouse Electric Supply Company (WESTC0) and General Electric Supply Company (GESCO) were traceable to the original circuit breaker manufacturer. After assembling auditable documentation, we determined that documented traceability did not clearly exist and that the original population of non-traceable breakers was higher than originally reported.

Attachment 1 provides a revised summary of non-traceable MCCBs that are being maintained as stored spares for safety related applications. Sixty-one (61) of the 107 stored spare MCCBs were classified as being non-traceable. These non-traceable MCCBs were placed on QC hold in the warehouse and will not be used in plant applications. It is our intention to test these non-traceable MCCBs in accordance with Attachment 1 of NRC Bulletin 88-10.

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p Since it is now recognized that less than 80% of the total MCCBs maintained as have been veri fied as being traceable to the breaker stored spares manufacturer, we are proceeding to identify the non-traceable breakers

! installed in the plant in safety related applications. This effort will include the review of previously installed Engineering Work Requests and Design Change Packages, Materiel Requests. Storeroom Transaction Logs and Maintenance Werk Orders.

We are currently in the process of testing the 61 in stock non-traceable breakers discovered in the warehouse inventory in an effort to detect fraudulent or substandard breakers. Based on past procurement practices, c there is no technical difference in the way the 61 in stock non-traceable MCCBs were procured and the way the currently installed breakers were procured. This testing is intended to give some reasonable assurance about the quality of the installed breakers that may not be traceable. In addition, we have completed walkdowns and visual inspections, based on the Guidelines for Identifying Suspect Molded Case Circuit Breakers contained within NUMARC letter dated March 8,1989, of all traceable and non-traceable safety related i breakers in stock and have identified no breakers that exhibit tampering or fraudulent manufacturing. Finally, longstanding maintenance practices require that all safety related replacement circuit breakers normally be functionally tested prior to being declared operational. Only breakers that satisfactorily l

pass this test are installed.

As reported in our May 5, 1989 supplemental response to the NRC Bulletin 88-10, a review of the purchase order files that had supplied the originally identified non-traceable in stock MCCBs was conducted. Of the 18 MCCB's judged at that time to be non-traceable, only six MCCBs were determined to be installed in the plant. Of these six MCCBs only one was found to be installed in a safety application. All six non-traceable installed MCCBs were replaced j with traceable breakers.

l It is our intention to identify any non-traceable MCCBs in safety related i systems, develop any necessary Justification for Continued Operation, and {

replace those non-traceable MCCBs by the end of the next refueling outage for  !

each unit. Also, we have re-evaluated our procurement procedures and i

! practices to determine if any further actions are required to ensure only

qualified MCCBs are being purchased and maintained as stored spares. These ,

controls continue to ensure that purchases, since April 1989, of MCCBs for i

safety related applications are from an approved circuit breaker manufacturer with a 10 CFR 50, Appendix B Program or from an approved distributor that can certify direct traceability to a circuit breaker manufacturer. To provide an .

additional level of assurance, traceability will be verified by audit or by l other appropriate means. An auditaole documentation package associated with l the review of MCCBs in stock is being maintained. Additional documentation  !

l for the installed breakers in the plant will be developed. e l

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n .l Should'. you havel:any?' questions'. concerning this response, please contact us' j ;.. ' o :immediately..

. c Very.truly yours,

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'r k W.~ L. Stewart s

Senior

Vice. President'- Nuclear '

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LU. S. Nuclear Regulatory Commission-

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101 Marietta Street,.N. W.

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l - Mr. J. - L. . Caldwell NRC Senior Resident Inspector North Anna Power Station i

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(

COMMONWEALTH OFVIRGINIA )

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COUNTYOFHENRICO ) ,

The foregoing document. was acknowledged before me, in and for the

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County and Commonwealth aforesaid, today by F. K. Moore who 'is Vice President - Nuclear Engineering Services, for W. L. Stewart who is Senior Vice President --Nuclear, of Virginia Electric and Power Company. He is duly' authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief. <

Acknowledged before me this N day of 47A&x/w/ ,19ff.

My Commission Expires:

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L ATTACHMENT 1 NON TRACEABLE SXITTY RELATED STORES MCCBS P. O. NO. P. O. DATE MANUFACTURER SUPPLIER MODEL NO. QTY NS-35639 10/11/77 GEN. ELECTRIC GESCO TQB 1110 5 NS-35639 11/10/77 GEN. ELECTRIC GESCO TEB 111015 1-NS-35635 10/11/77 GEN. ELECTRIC GESCO TEB 111050 1 NS-35639 10/11/77 GEN. ELECTRIC GESCO TEB 111070 1 NS-35639 10/11/77 GEN. ELECTRIC GESCO TEB 111020 1 NS-31485 2/10/86 G0ULD I-T-E ECK SUPPLY EF3-B030 5 NS-129833 4/23/87 HEINEMAN GAMMAMETRICS JA2-A3-A 2 ET-16481 10/3/86 HEINEMAN WESTINGHOUSE AM1 1 NS-97202 3/2/77 WESTINGHOUSE SOLID STATE 63E4866 1 NS-97202 3/2/77 WESTINGHOUSE SOLID STATE JA2200W 1 NS-97202 3/2/77 HEINEMAN SOLID STATE CJA-G3-0 1 .

I NS-39296 6/16/80 WESTINGHOUSE STEARNS/ ROGER FB-3100 1 NS-11799 1/31/85 WESTINGHOUSE WESTCO FB-3100 1 NS-09527 6/25/84 WESTINGHOUSE WESTC0 EHB-3010 2 NS-09527 6/25/84 WESTINGHOUSE WESTC0 EHB-3015 2 NS-12149 3/11/85 WESTINGHOUSE WESTC0 FB-3040 3 NS-33430 7/30/86 GEN. ELECTRIC GESCO THE0136070 1  ;

NS-06139 4/12/83 GEN. ELECTRIC GRAYBAR THOB22020 4 NS-57028 2/4/81 GEN. ELECTRIC GRAYBAR THED126050 2 CNS113426 12/9/86 GEN. ELECTRIC GESCO THE0124070WL 1 NS-33484 8/2/86 GEN. ELECTRIC GESCO THED124070WL 1 NS-12006 2/27/85 GEN. ELECTRIC ELEC. SUPPLRS THJK426F000 1

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NS-14526. 3/17/85 GEN. ELECTRIC- GESCO THJK426F000 1

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NS-14526 '3/17/85 GEN. ELECTRIC GESCO TEB111020 2  :

n l NS-14526 3/17/85 GEN. ELECTRIC GESCO TEB111070 2 i t-L NS-10435 9/10/84. WESTINGHOUSE WESTC0 EHB-3020 4 s

!- NS-11143 11/24/84 WESTINGHOUSE WESTCO EHB-3020 2 i F

[ NS-33255 4/9/80 WESTINGHOUSE WESTCO EHB-3020 1 I

NS-33255 4/9/801 WESTINGHOUSE WESTCO EHB-2015. 1  !

t- NS-162885 '12/10/87 WESTINGHOUSE WESTCO EHD-2015 1 I NS-32535 5/2/86 GEN. ELECTRIC GESCO TEB-111015 1 l

NS-82795 4/25/79 GEN. ELECTRIC GESCO TE0-134100. I f .i^

NS-24527 5/25/82 GEN. ELECTRIC ELEC. EQ. C0. TEB-111050 1 NS-09434' 6/14/83 GEN. ELECTRIC GRAYBAR THED136070 1 f

NS-29616 '

7/7/82 GEN. ELECTRIC GRAYBAR THQB1115 3 NS-69647 6/17/81 GEN. ELECTRIC GESCO TEB122090 1 TOTAL NON TRACEABLE 61 i

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