Text

Forwards Revised Proposed Bulletin Re molded-case Circuit Breakers
	ML20235A939
Person / Time
Issue date:	11/14/1988
From:	Sniezek J; Office of Nuclear Reactor Regulation
To:	Jordan E; Committee To Review Generic Requirements
Shared Package
ML20235A942	List: IA-88-607, Forwards Revised Proposed Bulletin Re molded-case Circuit Breakers; ML20235A939; ML20235A945; ML20235G773;
References
	FOIA-88-607 NUDOCS 8811180083
	Download: ML20235A939 (105)
	v • d • e

( A0V 141988

- MEHORANDUM FOR? Edward L. Jordan, Chairman

.. Committee to Review Generic Requirements FRON: James H. Snferek, Deputy Ofractor

Office of Nuclear Reactor Regulation

SUBJECT:

DRAFT BUI,LETIN REGARDING MOLDED-CASE CIRCUIT BREAKERS The Office of Nuclear Reactor Regulation (NRR) previously requested by memorandum dated August 19,1988, that the Comittee to Review Generic Requirements (CRGR) consider a proposed bulletin regarding nonconforming electrical equipment, components and devices. The CRGR approved the issuance of the bulletin at the August 24, 1988, meeting. The draf t i bulletin was not issued and has been substantially revised since then; consequently, NRR requests that the CRGR consider the revised proposed ,

bulletin. $

l The revised proposed bulletin requests that holders of operating licenses '

and construction permits take certain actions to provide reasonable as-surance that molded case circuit breakers (CBs) purchased for safety-grade applications without traceability to the original circuit breaker manufacturer (CBM) perform their safety functions. The proposed bulletin also requires that addressess provide reports listing those molded-case CBs that could )

not be traced to the CBM as well as the results of tests performed in accordance with the actions requested in the bulletin.

The revised proposed bulletin and the information required to support the issuance of this bulletin are enclosed. Lawrence Shao, Director, Division of Engineering and Systems Technology, is the sponsoring Division Director.

James H. Snierek, Deputy Director Office of Huclear Reactor Regulation

Enclosures:

As stated '

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.W 14 D00 Edward L. Jordan, Chairman

. , MEN 0RANDUM FOR:

3 Comittee to Review Generic Requirements FROM: Janes H. Sniezek, Deputy Director Office of Nuclear Reactor Regulation

SUBJECT:

DRAFT BUI,LETIN REGARDING M0LDED-CASE CIRCUIT BREAKERS The Office of Nuclear Reactor Regulation (NRR) previously requested by memorandum dated August 19, 1988, that the Comittee to Review Generic Requirements (CRGR) consider a proposed bulletin regarding nonconforming electrical equipment, components and devices. The CRGR approved the issuance of the bulletin at the August 24, 1988, meeting. The draft bulletin was not issued and has been substantially revised since then; consequently, NRR requests that the CRGR consider the revised proposed bulletin.

The revised proposed bulletin requests that holders of operating licenses and construction permits take certain actions to provide reasonable as-surance that molded-case circuit breakers (CBs) purchased for safety-grade applications without traceability to the original circuit breaker manufacturer (CBM) perform their safety functions. The proposed bulletin also requires that addressees provide reports listing those molded-case CBs that could not be traced to the CBM as well as the results of tests performed in accordance with the actions requested in the bulletin.

The revised proposed bulletin and the information required to support the issuance of this bulletin are enclosed. Lawrence Shao, Director, Division of Engineering and Systems Technology, is the sponsoring Division Director.

James H. Sniezek, Deputy Director Office of Nuclear Reactor Regulation m_._________ ___ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _

A Enclosure 1

CRGR Item IV.B. Contents of Packages Submitted to CRGR l

-(Rev.4.StellotoList 042387, des 41860 342 ff) ,

I The following requirements apply for proposals to reduce existing requirements 1 or (regulatory) positions as well as. proposals to increase requirements or '

(regulatory) positions. Each package submitted to the CRGR for review shall include fifteen (15) copies of the following infomation:

SUBJECT:

BULLETIN REGARDING NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS Question:

1. The proposed generic requirement as it is proposed to be sent out to licensees.

Response

The proposed generic requirement is spelled out in the proposed bulletin.

Question:

II. Draft staff papers or other underlying staff documents supporting the requirements or staff (regulatory) positions. (A copy of all materials referenced in the document shall be made available~ upon request to the CRGR staff. Any comittee member may request CRGR staff to obtain a copy of any referenced material for his or her use.)

Response

A. Proposed NRC Bulletin No. 88-XX: " Nonconforming Molded-Case Circuit Breakers."

B. Previous proposed NRC Bulletin No. 88-xx: " Nonconforming Electrical Equipment Components and Devices."

C. Letter from Underwriters Laboratories, Inc., dated October 25, 1988.

D. Letter from General Electric Company (GE), dated October 28, 1988.

E. Letter from National Electric Manufacturers Association (NEMA), dated October 24, 1988. .

Question:

III. Each proposed requirement or staff (regulatory) position shall" contain the sponsoring office's position as to whether the proposal would increase requirements or staff (regulatory) positions, implement existing require-ments or staff (regulatory) positions, or would relax or reduce existing requirements or staff (regulatory) positions.

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Response

A.- The proposed bulletin requires verification that existing require-ments are being met.

B .' Staff regulatory positions are not altered by this proposed bulletin.

Addressees are only being requested to review their records, provide the NRC with the requested information, and to comply with existing regulatory requirements.

Question:

IV. The proposed method of implementation along with the concurrence (and any.

comments) of OGC on the method proposed.

Response

The staff proposes to promulgate this proposed requirement by means of a bulletin. This method has been effective in the past. OGC reviewed the previous proposed bulletin and had no legal objection to that package, including the proposed bulletin, and all of their comments were incorporated.

None of the subsequent changes necessitated OGC's review.

,0uestion:

V. Regulatory analyses generally confonning to the directives and guidance of NUREG/BR-0058 and NUREG/CR-3568. (Make sufficient to address the Paper-work Reduction Act, the Regulatory Flexibility Act and Executive Order 12291).

Response

A. This request for information was approved by the Office of Management and Budget under blanket clearance number 3150-0011 as meeting the requirements of the Paper Reduction Act and Executive Order 12291.

B. Since this is not a rulemaking action, the Regulatory Flexibility Act does not apply.

Question:

VI. Identification of the category of reactor plants to which the generic requirement or staff position is to apply (that is, whether it is to apply to new plants only, new Ols only, OLs after a certain date, OLs before a certain date, all OLs, all plants under construction, all plants, all water reactors, all PWRs only, some vendor types, some vintage types such as BWR 6 and 4. jet pump and nonjet pump plants, etc.)

Response

The proposed requirements apply to all holders of operating licenses and construction permits for nuclear reactors.

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i Question:

VII. For each such category of reactor plants, an evaluation which demonstrates how the action should be prioritized and scheduled in light of other ongoing regulatory activities. The evaluation shall document for con-sideration information available concerning any of the following factors as may be appropriate and any other information relevant and material to the proposed action:

Response

Response to this item is not required pursuant to Revision 4 of the CRGR Charter,Section III.D., since the requirements of the proposed bulletin are intended to provide the NRC with information and will bring licensees into compliance with existing regulatory requirements. l Question: l VIII. For each evaluation conducted pursuant to 10 CFR 50.109, the proposing office director's determination, together with the rationale for the determination based on the considerations of all the above, that:

A. There is a substantial increase in the overall protection of public health and safety or the common defense and security to be derived from the, proposal; and

Response

The specific actions in the bulletin will address nonconformances and concerns identified by the staff during recent inspections and provide a reasonable assurace that these CBs perform their intended functions.

The proposed bulletin also requests addressees to perform certain actions and provide certain information regarding molded-case CBs to assess com-pliance with existing regulatory requirements. The information will be selectively audited by the staff to identify possible additional generic concerns.

Question:

B. The direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection.

Response

The actual implementation costs will vary between 1,000 to 10,000 man-hours for each addressee depending on the total number of molded-case CBs in stores for or installed in safety-grade applications, the number of non-traceable CBs identified, the failure rate of the CBs tested, and replacement costs. These estimates are highly speculative due to the unknown scope of the problem and the adequacy of addresses' records.

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,\*" .4 It is estimated that a typical holder of an operating license with -

computerized procurement records will require approximately 2,000.

man-hours (or $120,000 at $60 per man-hour) to meet the bulletin requirements and will spend approximately $30,000 to replace CBs that fail the tests-included in the bulletin. These estimates are calculated based on the licensee having 300 molded-case CBs in stores for safety-grade application and an additional 300 that have been installed between August 1,1983 and August 1,'1988, in safety-grade applications. In addition, 25% of the breakers are assumed not to be traceable to the CBM and a total of 30 are assumed to fail _ the tests ,

included in the bulletin and require replacement. Replacement breakers are estimated to cost approximately $1,000 each.

It is estimated that typical addressees that do not have computerized procurement records will require approximately 8,000 man-hours (or

$480,000 at $60 per man-hour) to implement the bulletin requirements and spend $30,000 to replace CBs that fail the tests included in the bulletin. These estimates are based on the same assumptions-as the example above, except that search and traceability determination may take an additional 6,000 man-hours.

Actions that can not be completed during normal operation may be completed.

during the next refueling outage beginning after March 1,1988; therefore, plant shutdowns are not required. In addition, addressees that cannot meet the bulletin schedules can justify to the NRC their proposed alter-rative schedule.

The NRC staff feels that the costs of implementation of the~ bulletin are justified in view of the increased confidence in the safety of nuclear power reactors.

Question:

IX. For each evaluation conducted for proposed relaxations or decreases in current requirements of staff positions, the proposing office director's determination, together with the rationale for the determination based on the considerations of the above, that the public health and safety and the common defense and security would be adequately protected if the proposed reduction in requirements or (regulatory) positions were implemented, and

! the cost savings attributed to,the action would be substantial enough to justify taking the action.

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Response: ,

This item is not applicable to the proposed bulletin because no relaxation or decrease in current requirements is being proposed. ,

No.: 3150-0011 !

. ; NRCB 88-xx UNITED STATES NUCLEAR REGULATORY COMMISSION NOEB"*P OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 Bf{Q(( l November xx,1988 i NRC Bulletin No. 88-xx: NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS Addressees:

All holders of operating licenses or construction permits for nuclear power reactors.

PJrpose:

The purpose of this bulletin is to request that addressees take actions to including providereasonableassurancethatmolded-casecircuitbreakers(CBj)a,pplic CBs used with motor contro11ers g purchased for use in safety-grade without verifiable traceability to the circuit breaker manufacturer (CBM) perform their safety functions.

Description of Circumstances:

NRC Information Notice No. 88-46, " Licensee Report of Defective Refurbished Circuit Breakers," dated July 8,1988 and Supplement I thereto, dated July 21, 1988, discussed a report by Pacific Gas and Electric Company that indicated that its Disblo Systems, Inc. Canyon through Nuclear Power Plant a local electrical was supplied distributor. These30 CBs CBs by(Anti-Theft Square D molded-case, type KHL 36125) were intended for use in non-safety-grade appli-cations at the Diablo Canyon Nuclear Power Plant. Square D Company reported that an inspection and testing of these breakers detemined that the CBs wcre refurbished Square D Company equipment. Furthemore, Square D reported that !

several of the circuit breakers tested did not comply with Square D or Under- i writers Laboratories, Inc. (UL) specifications for all of the electrical tests performed. Infomation Notice No. 88446 also listed several California com-panies that were involved in supplying surplus refurbished and possibly defective refurbished electrical equipment to the nuclear industry.

During recent NRC inspections . additional examples were identified that indicate a potential safety concern regarding electrical equipment supplied to nuclear power plants. The NRC is concerned that equipment being procured as new and assumed to meet all applicable plant design requirements and/or original manufacturer's specifications may, in fact, not confom to these requirements and specifications. ,

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1. Refer to Attachment 2 for Definition.of Tems

- e, ' NRCB 88-J November xx, 1988

' Page 2 of The actions requested in this bulletin are limited to molded-case CBs. Molded-case .CBs are . tested and calibrated at the manufacturer's plant in accordance with recognized industry standards, such as UL-489 " Molded Case Circuit Breakers and Circuit Breaker Enclosures," and National Electrical Manufacturers Associ-ation (NEMA)-AB1, " Molded-Case Circuit Breakers." Since molded-cane CBs have factory-calibrated and sealed elements, any unauthorized modificat' on or re-furbishing of these CBs could jeopardize their design capability and reliability.

The NRC is concerned that the reliability and capabilities of refurbished CBs purchased as comercial grade (non-Class IE) for later upgrading to safety-grade (Class IE) applications may not meet the minimum commercial grade standards. In addition, the NRC is concerned about the reliability and capabilities of commercial grade breakers upgraded to safety-grade because of some observed inadequacies in the dedication process and numerous failures found during the testing of some of these breakers. In order to properly dedicate electrical items procured as commercial grade for subsequent use in safety-grade applications, the dedication process should build from the commercial grade quality, include a proper evaluation of seismic and environ- i mental qualification, confirm critical parameters, and include testing as appropriate.

Safety-grade electrical equipment purchased as Class 1E from the CBM, or corporate divisions associated with the CBM, is of lesser concern as this equipment is controlled under quality assurance (QA) programs that confom to Appendix B of 10 CFR Part 50. The controls imposed by these QA programs are more stringent than those exercised in the manufacturing of crinercial

4. grade equipment. While the upgrading programs of CBMs or corporate divisions associated with the CBMs, may vary in quality, the controls exercised over the procurement and manufacturing activities provide reasonable assurance that improperly refurbished components have not been introduced and passed through the upgrading process. Furthennore, the redundancy of safety systems and the in-service use of these components provide a reasonable basis for accepting installed replacement components that have been procured as safety-grade from the CBM, or from corporate divisions associated with the CBM.

The NRC currently believes that the concerns addressed in this bulletin do not l apply to electrical equipment (safety-grade and commercial grade) originally l installed in plants. This equipment. appears to have been procured during plant l

construction from CBMs with full certification. The large quantities of I electrical assemblies or components procured under bid packages during plant construction reduce the possibility of any original plant equipment being supplied by vendors doing refurbishing.

The NRC expects all addressees to participate in a joint industry program that ensures that non-safety-grade molded-case CBs, which may have been installed as replacements, installed during modifications, or are being maintained as stored spares and that were not procured from the CBM, or whose.orihinal {

source has not been detennined, are suitable for their intended service.

A joint industry report describing the program is expected withth 180 days of receipt of this bulletin.

l 4

, November xx, 1988 Page 3 of

' The NRC requested and received comments from the Nuclear Management and Resources Council (NUMARC), the National Electrical Manufacturers Association (NEMA), and the Underwriters Laboratories, Inc. (UL), during the preparation of this bulletin.

These coments were considered and some were appropriately incorporated into this bulletin. i NEMA has connented to the NRC that determination of the critical performance characteristics of durability and short-circuit capabilities of circuit breakers requires destructive testing of selected breakers that are representative of breakers to be placed in service. Because a refurbished breaker may not have been refurbished under controlled conditions to conform to a proven design, destructively testing selected breakers will not infer anything about a re-furbished breaker. UL provided specific comments on the tests in Attachment 1 of this bulletin. In addition, they stated that, "it is UL's opinion that the test program is not adequate to provide assurance that the tested, non-traceable, circuit breakers would be suitable for their intended purpose." The NRC agrees with these comments. The non-destructive testing in Attachment 1 of this bulletin, however, is directed at ensuring that the circuit breakers will perfonn those functions most important to ensuring reactor safety even though j the tests will not verify the capability of performing certain functions that )

can only be verified by destructive testing.

The NRC investigation of this issue is not complete. A supplement to this l bulletin may be issued to include other electrical equipment or a longer pro- l curement review period if warranted by the results of the ongoing evaluations 1 or the results of testing requestad in this bulletin. ,

Act1ons Requested:

1. All addressees are requested to perfonn the following review by March 1,1989:

a. Identify all molded-case CBs purchased prior to August 1,1988, that are being maintained as stored spares for safety-grade (Class 1E) applications or connercial grade CBs that are being maintained as stored spares for future use in safety-grade 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-grade applications as replacements or modifications to form a minimum sample of 50 CBs.

b. Verify the traceability of these CBs.

c. Identify the number, manufacturer, model number, and to the extent 4 possible the procurement chain for all CBs that cannot be, traced to the CBM. For installed CBs, also identify each system in which they are/were installed. _

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November xx, 1988 l,' -

Page 4 of l

2. All holders of operating licenses who identify installed CBs per item 1 above that cannot be traced to a CBM are requested to prepara, within 30 ;

days of the completion of item 1 above, an analysis justifying continued l operation until items 1 through 5 of the actions requested in this bulletin i have been completed. . i

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 components 1 that meet the criteria of item 7 of the actions requested or that pass all tests in accordance with the testing program described in Attachment 1. If moro 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 pemits are requested to complete this testing program before fuel load.

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 perfom 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-grade 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 f'or all those CBs that cannot be traced to the CBM.

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 de' s cribed in Attachment 1; CBs that fail any of these tests should be replaced with components that meet the criteria of item 7 of the actions requested or that pass all tests in accordance with the test program described in Attachment 1.

NRCB 88-November xx, 1988 Page 5 of 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 breakers 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 breakers before fuel load.

6. Information generated while performing the actions requested in items 1, 2, 3, 4, and 5 above should be documented and maintained for possible NRC I

audit for a period of 5 years after the completion of all requested actions.

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-grade appli-cations after August 1,1988 should be:

a. Manufactured bu and procured from a CBM under a 10 CFR 50, Appendix B, program; or

. b. Procured fros a CBM or others with verifiable traceability to the CBM, in compliance with applicable industry standards, and upgraded to safety-grade by the licensee or others using an acceptable dedi-cation program. Tests equivalent to those in Attachment 1 are acceptable for a dedication process of CBs traceable to the CBM.

In addition, seismic and environmental qualification requirements should be addressed by additional testing or analysis based on plant-specific considerations.

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.

Reporting Requirements:

1. All holders of operating licenses are required to provide a written report by April 1,1989, that:

a. Confirms 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-grade applications.

b. Sumarizes 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 e

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.,.- , NRCB 88-

., November xx, 1988 j

'Page 6 of I by April 1,1989, se to the schedule' for tests in item 3 of the actions requested, this infomation should be updated within 30 days of the completion of item 4-to address those additional C8s that could not be traced to the CEM. t

c. Confirms that items 1, 2, 3, 4, 5, 6 and 7 of the actions requested have been completed or will be implemented as requested.

2. All holders of operating licenses are required to submit a report that sumarizes available results of tests conducted in accordance with items 3 and 5 of the actions requested within 30 days after startup fror the first and second refueling outages beginning after March 1,1989. These reports should Mclude the number, manufacturer, model number, and to the ;

extent possible the procurement chain of CBs tested. For CBs that fail i thesetest(s),thesereportsshouldindicatethetest(s)andthevaluesof 1 test parameter (s) at which they failed.

3. All holders of construction permits are required to provide a written report by April 1, 1989, that:

a. Confirms 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-grade applications.

b. Sumarizes 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 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. Confims that items 1. 3, 4, 5, 6 and 7 have been completed or will be implemented before fuel load.

4. All holders of construction pemits are required to submit a repcrt that sumarizes the results of tests conducted in accordance with items 3 and 5 of the actions requested within 30 days after fuel load. The report should include the number, manufa'cturer, and model number of all breakers tested.

For CBs that fail these test (s), the report should indicate the test (s) and the values of test parameter (s) at which they failed.

The written reports required above shall be addressed to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,.D.f. 20555, under oath or affirmation under the provisions of Section 182a Atomic Energy Act of 1954, as amended. Inaddition,acopyshallbesubmitted;tothe appropriate Regional Administrator.

NRCB 88-November xx, 1988 Page 7 of This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated burden hour is 1000 to 10,000 man-hours per plant response, including assessment of these require-ments, searching data sources, testing, and analyzing the data, and preparing the required reports. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Managenent and Budget.

Room 3208, New Executive Office Building, Washington, D.C., 20503, and to the U.S. Nuclear Regulatory Commission Records and Reports Management Branch, Office of Administration and Rescurce Management, Washington, D.C., 20555.

If you have any qeestions regarding this matter, please contact one of the technical contacts listed below or the Regional Administrator of the appropriate NRC regional office.

M#JT Charles E. Rossi, Director Division of Operatonal Events Assessment Office of Nuclear Reactor Regula+. ion Technical Contacts: Paul Gill, NRR (301) 492-0811 Jaime Guillen, NRR (301) 492-1170 Attachments:

1. Test Program for Molded Case Circuit Breakers

2. Definition of Terms

3. List of Recently Issued NRC Bulletins O

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Attachment 1 NRCB 88-xx Noyember xx, 1988 TEST PROGRAM FOR MOLDED-CASE CIRCUIT BREAKERS 1.0- Test Program Objectives The objective of this proposed test program is to verify the reli-ability and capabilities of molded-case circuit breakers (CBs).

For the safety of personnel and others involved with the activities related to these proposed tests, appropriate safety practices, such as ANSI /NFPA 70E, " Electrical Safety Requirements for Employee Workplaces," Part II, should be followed.

These proposed tests have been based on tests described in industry standards, such as NEMA AB-1, " Molded-Case Circuit Breakers," NEMA AB-2, " Procedure for Field Inspection and Performance Verification of Molded-Case Circuit Breakers Used in Comercial and Industrial Applications," UL 489 " Molded Case Circuit Breakers and Circuit Breaker Enclosures," and NETA STD ATS-1987, " National Electrical Testing Association Acceptance Testing Specifications."

2.0 Test Procedures for CBs The following tests should be performed in the sequence listed. CBs failing any of these tests should be considered unacceptable for safety-grade applications.

2.1 Mechanical Test The CB should be operated, reset, and closed a minimum of five times, to ensure that the latching surfaces are free of any binding.

2.2 Individual Pole Resistance or Mil 11 volt Drop Test (Ref. NETA STD ATS-1987 & NEMA AB-2)

The contact resistance of each pole of the CB should be measured at ambient temperature. Three readings of each pole should be taken with the CB operated without load between each reading. The average of three readings for each pole should be calculated and compared with the manufacturer's contact resistance data or with those values of similar CBs from the same manufacturer. - Also, the average value for each pole should be compared with the average of the other poles and the difference between the pole values should not exceed 50 percent of the lowest value; or A millivolt drop test may be performed by applying a direct current across the closed CB contacts and measuring the voltage drop due to the contact resistance. The millivolt drop test should be performed at room temperature. Direct current should be applie(across each I

2

,1 . . ' pole and the millivolt drop'and test current recorded for each pole.

Three readings of each pole should be taken with the CB operated with-out load between each reading. The average of the three. readings for each pole should be calculated and compared with the manufacturer's value for acceptance of the breaker.

2.3. Rated Current Hold-In Test (Ref. NEMA AB-l'& UL 489) y Th'is test should 'be conducted at 100% rated current and at an ambient air temperature of 25'C

3*C, and followed by a test at 135% rated current and at an ambient temperature of 25'C

3*C.

Equal 100% rated currents should be applied to all poles of the CB.

The CB must not trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for CBs rated 50 amperes or below or within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for CBs rated over 50 amperes during this test. At the end of the 100% rated current test, the current should be increased to 135% and the CB should trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for CBs rated 50 amperes or below or within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for CBs rated over 50 amperes. ;

2.4 Overload Test (Ref. NEMA AB-1 & UL 489)

This test consists of one operating cycle (i.e., closing action followed by an opening action) of the CB at 600% rated current.

This test may be conducted at low voltage. There should be no electrical or mechanical breakdown of the CB during this test.

2.5 Instantaneous Trip Test (Ref. NEMA AB-1 & UL 489) 2.5.1 Fixed Instantaneous Setting CBs Each pole of the CB should be tested for pickup of the instantaneous unit. Each pole must be between 75% and 125% of the instantaneous trip rating. The trip time should not exceed 0.1 seconds (6 cycles).

2.5.2 Adjustable Instantaneous Setting CBs This test is the same as that in Section 2.5.1 except that each pole must be tested at the lowest and highest settings.

The trip value for the lowest setting should be between 75% and 125%

of the lowest setting, and the highest setting should be ~between 80%

and 120% of the highest setting.

l 2.5.3 Short-Time Trip Setting Test This test is applicable only if the CB is equipped with the short-time delay trip. This test'should be conducted at an ambient air temperature of 25'C i 3*C. The operation of the short-time delay unit should be within 90% and 125% of the overcurrent.setling o-f the CB as shown on the manufacturer's time-current curves'.

J

. 3 2.6 Time Delay Overcurrent Trip (Ref. NEMA AB-2)

This test should be conducted at an ambient air temperature of 25'C i 3*C.

A current of 3005 (at low voltage) of the marked rating thould be applied to each pole of the CB. The trip time for each pole should be compared with the time shown in the CB manufacturer's time-current curves. 'If the test trip times obtained for each pole are not within the time band shown on the CB manufacturer's time-current curves, then the test trip must not exceed the time specified in. Table 1 and the acceptance of the CBs must be evaluated with the criteria listed below:

TABLE 1

. VALUES FOR OVERCURRENT TRIP TEST-(AT 300% OF RATED CONTINUOUS CURRENT OF CIRCUIT BREAKER)

(REF. NEMA AB-2)

Breaker Range of Rated Voltage Continuous Current Maximum Tripping Volts Amperes Time In Seconds 240 lb-45 50 240 50-100 70 600 15-45 70 600 50-100 125 240- 110-225 200 240 250-400 300 600 110-225 250 600 250-400 300 600 450-600 350 600 700-1200 500 600 1400-2500 600 600 3000-5000 650 4 Minimum Tripping Time: , If the' minimum tripping times are lower than indicated by the manufacturer's time-current curves for the CB under test, the CB should be retested after it has been cooled to 25*C. If the values obtained are still lower after retest, the ,

coordination with upstream and downstream CB should be evaluated.

If no problem with coordination is indicated, then the CL is ac-ceptable.

< ~4~

Maximua Tripping Time: Ifthetrippingtime'exceedsthemaximum

, tripping time shown on the manufacturer s time-current curves but is below the time shown in Table 1, check the CB time against the protection requirements of the circuit (such as cable, penetration, etc.) to ensure that the CB provides the protection, as well as the-coordination with upstream and downstream CBs. If the CB provides the necessary protection and. coordination, then the CB 18 acceptable.

Maximum Allowable Time: If the tripping time'of the CB exceeds the trip time shown in Table 1, the breaker is unacceptable for Class 1E applications.

2.7 Dielectric Tests (Ref. NEMA AB-1 & UL-489) l The dielectric' test should be conducted at an ac test voltage of 1760 volts (80% x [2 r. rated voltage + 1000 volts]), or at 2500 volts de for 1 minute withstand. The dielectric t:'n should be conducted for (1) line to load terminals with CB open, (i) line to line terminals with CB closed, and (3) pole to ground with CB open, and (4) pole to .

ground with CB closed.

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NRCB 88-xx November xx,1988 DEFINITION OF TERMS CIRCUIT BREAKER MANUFACTURER (CBM)

The manufacturing facility that actually produced the circuit breaker being purchased.

VERIFIABLE TRACEABILITY Decumented evidence such as a certificate of compliance that establishes

. traceability of purchased equipment to the CBM. If the certificate of compliance is provided by any party other than the CBM, the validity of such certificate must be verified by the l'rensee or permit holder through an audit or other appropriate means.

DEDICATION PROCESS

\

The process by which commercial grade (non., tass IE) equipment is upgraded to safety-grade (Class IE) and is thereby considered qualified for use in nuclear safety-related applications. The dedication process must include:

a. A technical evaluation to determine the characteristics critical to fulfilling the safety function (s).

b. An acceptance process to ensure that those critical characteristics are met.

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.l UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON D.C. 20555 AUGUST XX, 1988

- NRC BULLETIN 86-XX: NONCONFORMING ELECTRICAL EQUIPMENT, COMPONENTS AND DEVICES ADDRESSEES:

All holders of operating licenses or construction permits for nuclear power reactors.

PURPOSE:

- The purpose' of this bulletin is to request that addressees take actions to assure thatinstalledmoldedcasecircuitbreakers(CBs)andmotorcontrollers(MCs) comply with plant design requirements such as IEEE, Underwriters Laboratory (UL), National Electrical Manufacturers Association (NEMA) or original manufacturer's specifications.

The scope of requested actions are limited to molded case CBs and MCs, procured

.as replacements for original plant equipment, that have or may have been refurbished.

DESCRIPTION OF CIRCUMSTANCES:

NRC Infomation Notice No. 88-46 " Licensee Report of Defective Refurbish (d Circuit Breakers," dated July 8,1988 and its supplement 1, dated July 21, 1988, discussed a report by Pacific Gas and Electric which indicated that the Diablo Canyon Nuclear Power Plant had been supplied 30 CDs by Anti-Theft Systems, Inc. through a irc.1 f electrical distributor. These CBs (Square D molded case, type KHL 36125), were j intended for use in non-safety-related applications at the Diablo Canyon nuclear power plant. Square D company reported that the inspection and testing of these breakers determined that the CBs were refurbished Square D Company equipment.

, Further, Square D reported that many of the circuit breakers tested did not comply

with Square D or UL specifications for all of the electrical tests'perfdrmed.

Information Notice No. 88-46 also listed several California companies that were '

. involved in supplying possibly defective refurbished electrical equipment to the nuclear industry.

NRC Information Notice No. 88-19 " Questionable Certification of Class IE Components" '

dated April 26, 1988 discussed a 10 CFR Part 21 notification, submitted on April I, 1988 by the Wolf Creek Nuclear Operating Corporation (WCNOC), which brought into question the validity of Certificates of Corpliance issued by Planned Maintenance In response to this notification, the NRC Systems, Inc. (PMS) for Class IE fuses.

staff inspected PMS. Components supplied by PMS with questionable certification included circuit breakers, fuses and relays. The NRC investigation of this issue is not complete and, if warranted, a supplement to this bulletin may be issued.

These examples indicate a potential safety concern regarding electrical equipment '

supplied to nuclear power plants. The NRC is concerned that the equipment procure as being new and assumed to meet all applicable plant design requirements and/or ;

original manufacturer's specifications may in fact not conform to these requirements and specifications.

The actions Nguested in this bulletin are only related to molded case CBs and ,

MCs due to their widespread use and applications and the potential im failure. Molded case CBs are tested and calibrated at th'e manufacturer's plant in accordance with recognized industry standards (UL-489-Molded-Case Circuit Breakers and Circuit Breaker Enclosure,s, NEMA-AB1-Molded-Case Circuit Breake Since molded case CBs have factory-calibrated and sealed elements, any unauth modification or refurbishing of the CBs Jeopardize their capabliity and reliability, as well as the manufacturer's warranty. The MCs are also built in accordance with similar NEMA standards and are UL listed, and any unauthorized refurb,ishing of su Therefore, reliable operation of refurbished equipment compromises its integrity.

molded case CBs and MCs installed in nuclear power plants cannot be relied upon, to lack of assurance of uniformity of parts, materials and workmanship used in unauthorized refurbishing activities.

1 9

3 The NRC is concerned about refurbished CBs and MCs purchased as commercial grad (non-Class 1E) for later upgrading to safety grade (Class IE) applications, because these CBs and MCs may not meet the minimum commercial grade standards In order to dedicate electrical items procured as comercial grade and subse-quently used in safety-related systems, the dedication process should build fro the comercial grade quality, and include proper evaluation of seismic and environ-mental qualification, as well as confirmation of critical operating parameters and functional testing as appropriate. When refurbished CBs and MCs are upgraded to safety grade applications, the NRC is con:erned that the licensee's normal dedicat l

process may not be adequate for properly evaluating the acceptability of the components.

i The safety grade electrical equipment originally purchased as Class IE is not a concern, since this equipment is purchased and installed under quality assurance The controls imposed (QA) programs which conform with Appendix B of 10 CFR 50.

by these QA programs are more stringent than the controls exercised in procurem of comercial grade equipment. Further, the requirements of these QA programs are well established and known to electrical equipment suppliers and are subject to frequent audits.

The NRC beMe$es that the safety concern does not extend to the electrical equipment (Class IE and non-Class IE) originally installed since t procured during plant construction from original manufacturers with full certif tion. Moreover, this equipment was inspected and tested before the nuclear plant

-became operational. The large quantities of electrical assemblies or components procured under bid packages minimizes the possibility of" small vendors doing refurbishing business having supplied original equipment.

The actions requested in this bulletin apply only to molded case CBs and MCs pro-l cured as replacements for original plant equipment as indicated in ac' tion item A supplement l below. However, the NRC investigation of this issue is not complete.

to the bulletin may be issued to include other electrical equipment if warranted l

by the results of the ongoing evaluation.

s. .

ACTIONS REQUESTED:

2.

All addressees are requested to review their records to identify the number, types and applications of installed (or stored spare) replacement molded case CBs and MCs, that were procured as commercial grade (non-Class IE) '

later upgraded to safety grade (Class IE), that were not procured from the original manufacturers,I or whose procurement source has not been determ Replacement CBs and MCs, procured from distributors who cannot demonstr the equipment was procured directly from the original equipment manufacturer without intermediate refurbishment, must be assumed to be unacceptable.

2. All addressees that identified installed CBs or MCs per item 1 above are requested to replace these CBs or MCs with fully qualified components, or providejustificationforcontinuedoperations(JCO)untilthesuspectCBs or MCs are replaced, to be completed not later than before startup after thesecondrefuelingoutagefromthedateofthisbulletin.(forallholders of cps, the CB or MC replacement should be completed prior to fuel load)

3. All addressees that identified stored spare CBs or MCs per item 1 above are recLuested to take appropriate actions to ensure that these CBs are n used for safety-related service. f

1. Original Manuf acturers are defined as those companies that Supply companies distributing CBs manufacture the CBs.

(WESCO, GESCO, GRAYBAR and others) are not considered as original manufacturers of CBs.

4

5-

4. All addressees are requested to develop a program for the installed or in 1 storage non-safety related replacement molded case CBs and MCs, that were not procured from ti.e original manufacturer or whose original source has not been A

determined, to assure that they are suitable for the intended service.

joint industry program which attains this objective is encouraged.

5. Inf ormation generated during the conpletion of items 1,2,3 and 4 above shall be documented and maintained for possible NRC audit. (

REPORTING REQUIREMENTS:_ ,

. 1. All holders of operating licenses for nuclear power reactors are required within 120 days of the receipt of this bulletin to provide a written report that:

a. confins that no molded case CBs or MCs have been procured and upgraded as described in action item 1, or forwards the infonnation requested in action item 1.

b. confirms that the CB and MC replacement actions requested in action item 2 have been completed, or provides an appropriate schedule for completion of these actions and confirms that a justification for continued operation has been completed and is b'eing retained for possible NRC audit.

~

c. confirmsactionitem3hasbencompleted. .

2. All holders of a construction pemkt for nuclear power reactors are required to, within 120 days of receipt of this bulletin, provide a written report that: -

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a. confirms that no molded case CBs or MCs have been procured and ,

upgraded as described in action item 1, or forwards the information requested in item 1.

b. confirms that the CB and MC replacement action requested in action item 2 will be completed prior to fuel load,

c. confirms action item 3 has been completed.

3. All addressees are requested to provide a report, within 180 days of receipt of this bulletin, that confirms that no molded case CBs or MCs have been pro-cured for non-safety related applications as described in action item 4, or that describes the program required under action item 4.

The writtan reports required above shall be addressed to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 under oath or affirmation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the appropriate Regional Administrator.

This request-is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated average burden,4our is 400 man-hours per plant response, including assessment of the new require-ments, searching data sources, gathering and analyzing the data, and preparing the required reports. Coments on the accuracy of this estimate and suggestions t.o reduce the burden may be directed to the Office of Management and Budget.

Room 3208, New Executive Office Building, Washington, D.C., 20503, and to the U.S. Nuclear Regulatory Commission, Records and Reports Management Branch of Administration and Resource Management, Washington, D.C., 20555.

Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation

7. , ,

Technical Contacts: Paul Gill, NRR (301? 492-0811 JaimeGuillen,NRRI,301)492-1170

' Attachment 1: List of Recently Issued NRC Bulletins 1

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INTEROFFICE CORRESPONDENCE

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r Po.w..e..o SITE a . NUCLEAR ENGINEERING SERVICES NAlE 230-4589 Q office MAC Telephone SubscT: NRC Bulletin 88-05 Preliminary Material Review for continued Plant operation TO: G. - Flakes DATE: July 15, 1988 SNES88-0428

'As requested by Licensing, SNES/ Mechanical Design has performed an independent review of -the Jectyprepared by l Procurement Engineering. The following information augments l the subject M .

, Je a. Qo I l

A review of CR-3 documentation indicates that the material in l question was installed in the Nuclear Service and Decay Heat Sea Water (RW) System. A review of the RW system design basis and analysis indicates that the systems maximum stress values do not exceed 25 per cent of the materials established ultimate strength.

To establish the materials ultimate strength, an EQUOTIP portable hardness tester was used. The EQUOTIP hardness number obtained was then expressed in terms of a Brinell Hardness number using the EQUOTIP conversion tables. The jj lowest hardness value obtained to date is 115 HB.

The Requirement Outline R0-2891 contains material and design specifications for the different systems at CR-3. The RW system is classified as Line specification 150-1 with a design temperature and pressure of 150 deg. F and 100 psi respectively. This specification also states that ASTM A-105 is acceptable as flange material. The current ASTM standard for A-105 only specifies information for one grade of material; that being a minimum tensile strength of 70 KSI, a minimum yield strength of 36 KSI and a hardness range of HB 137 to 187. The previously determined hardness value (115

,. HB) does not fall within the acceptable range for ASTM A-105 material.

To further evaluate the questionable material, the hardness value was converted to an approximate tensile strength of 57

, KSI. The design code for this system is USAS B31.1.0, code for Power Piping, 1967 ed. Paragraph 102.3.1 (b) of this code provides the basis for establishing material allowable stress values. For Ferrous materials at temperatures below the creep range, allowable stresses are established at the l lowest value of stress obtained from using 25 per cent of the specified minimum tensile strength at room temperature or 25 per cent of the minimum expected tensile strength at design temperature. The test value of 57 KSI was obtained at room kw)' temperature and is not expected to change at the 150 deg. F design temperature. Using this technique, an allowable stresa value of 14.25 KSI is obtained. A review of the RW ses m us:

C4 c. 65iV4 00/LC/C6 . O ' O Ji t e Q 'lO A D A Q s, .HVc3

't _s Page 2 Q July 15, 1988 G. Flakes

-System seismic and Deadweight Analysis (CR-19,20,21,22,24,29) by GAI revealed a maximum operating' stress 4,575 psi (CR-24)~

. and a maximum seismic stress of 9,680 pai (CR-22). Both these valves are below the calculated material allowable stress of 14,250 psi. A review of calculations previously-performed on the flanges in the RW system using the rules of ASME Section III, Appendix XI and Article L-1000, indicate that both the radial stress and the tangential stress induced by system pressure and bolt torque are less than 5000_ psi.

The forgoing treatise shows that the material with the 57 KSI !

Tensile Strength is. acceptable for use in the RW system.

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S. J. Roe, Project Engineer Site Nuclear Engineering Services hA / h ltick k.)/ F. V. Fusick, Supervisor Nuclear Mech / Structural Engineering Services SJR/jj cc: G. A. Becker J. E. Colby G. D. Obendorfer L. B. Tiscione W. R. Watts Records Management W

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f SPECIFIED SUSPECT MATERIAL' MATERIAL ;

(A105) (?) !

YIELD (psi) 36,000 not obtainable HARDNESS (HB) 137-187 115 TENSILE (psi) 70,000 57,000 ALLOWABLE (psi) 17,500 14,250 J The allowable value should 'be compared to the actual system and flange design stress of 4575 psi and 5000 pai.

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Q Date: July 13,1988

Subject:

NRC Bulletin 88-05 l Preliminary Material. Review for continued Plant Operation TO: G Flakes )

The questionable material has been identified to be installed in the RW(Sea Water) System.

Per the Requirement Outline for Fabricated Piping RO ' I 2891,the design conditione for this system are, Maximum Pressure 100 PSI.and Maximum Temperature 150 F. The individual.line specifications for this system allow the use of ASTM A105 material. The piping design code for this system is ANSI B31.1(orginal design input date 1967).

Paragraph 102.3.1 " Allowable Stress Values" of B 31.1 references Appendix A Table A-2 for Maximum Allowable Strees.

This table indicates under ASTM A105 a minimum tensile of 60,000 ' PSI for type 1 material and 70,000 PSI for type 2 material with corresponding maximum allowable design stresses -

of ' '00 PSI and 17,500 PSI.

.ne current Asta Standard for A105 material only L, indicates one type ~ material available with a 70,000 PSI v tensile, 36,000 PSI yield and a Hardness range of 137 to 187 HB.

V The lowest hardness reading of suspect installed material obtained to date is 115 HB. When converted to a tensile strength this indicates an approximate 57,000 PSI tensile for the suspect installed material. 1 A review of the actual RW system Stress Analysis Sheets i (CR-19,20,21,22,24,29 ) by GAI revealed a Maximum Normal System Design Stress of 4,575 PSI (CR-24) and a Maximum Seismic Design Stress of 9,680 PSI (CR-22). l Using a ratio of material design stress and maximum code allowable stress (70,000/17.500) a safety factor of 4 can be obtained. Using the actual installed material design stress and the actual system design stress (57,000/9,680) a actual safety factor of 5.89 exists.

This demonstrates that. the installed tested material properties, though even below the minimum ASTM material requirements still far exceed the design bases of the affected components in the RW system.

If you have any questions on the above information, please contact me at ext.4664.

Donald W Bienkowski h Senior Procurement Engineer copy:L.B. Tiscione (

B. Watts G.0berndorfer

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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON D.C. 20555 JULY XX, 1988 NRC BULLETIN 88-XX: NONCONFORMING ELECTRICAL EQUIPMENT, COMPONENTS AND DEVICES ADDRESSEES:

All holders of operating licenses or construction permits for nuclear power reactors.

PURPOSE:

The purpose of this bulletin is to request that addressees take actions: to assure that any installed electrical equipment, components and devices procured from the companies listed in Attachment I comply with industry standards, such as IEEE and Underwriters Laboratory (UL), and original manufacturer': specifications; to demonstrate that the identified electrical equipment, components and devices are acceptable for their intended use; or replace the electrical equipment, components and devices.

DESCRIPTION OF CIRCUMSTANCES:

' NRC Information Notice No. 88-46 " Licensee Report of Defective Refurbished Circuit Breakers," dated July 8, 1988 and its supplement 1 dated July 21, 1988, respectively, i

l ,

1

\

4 discussed a report by Pacific Gas and Electric which indicated that the Diablo Canyon Nuclear Power Plant had been supplied 30 circuit breakers (CBs) by Anti-Theft Systems, Inc. through a local electrical distributor. These CBs (Square D molded case, type KHL 36125), were intended for use in non-safety-related applications at the Diablo Canyon nuclear power plant. Square D company reported that the inspection and testing of these breakers determined that the CBs were refurbished Square D Company equipment. Further, Square D reported that none of the circuit breakers tested complied with Square D or UL specifications for all of the electrical tests performed. Information Notice No. 88-46 also listed several California companies that were involved in supplying possibly defective refurbished electrical equipment to the nuclear industry.

Information Notice No. 88-19 " Questionable Certification of Class IE Components,"

dated 26, 1988 discussed a 10 CFR Part 21 notification, submitted on April .

1988 by the Wo reek Nuclear Operating Corporation (WCNOC) which brough ' to question the validity Certificates of Compliance issued by Plano aintenance Systems, Inc. (PMS) for Class fuses. WCN0C reported that ad issued a pur-chase order to PMS for fuses qualif1 or Class 1E ap ation. The PMS Certificate of Compliance supplied with the order certi t all of the procurement document requirements had been met and no deviati rom requirements had been identi-fied. However, a subsequent WCN surveillance reveale hat the records in PMS's possession did not suppor is. In response to this notific on, the NRC staff inspected PMS. C nents supplied by PMS with questionable certi ' ation in-cluded cir breakers, fuses and relays. The NRC inspectors found li or no evid e that indicated that PMS had performed its contractually required IEE 3 k ctivities to qualify components as Class IE. j These examples indicate that there is a potential generic safety concern regarding electrical equipment supplied to nuclear power plants. The NRC is concerned that the equipment procured as being new and meeting all applicable industry requirements and original manufacturer's specifications may in fact not confonn to these re-quirements and specifications.

I The actions requested in this bulletin are primarily related to CBs, fuses and relays due to their widespread use and applications and the potential impact of their failure.

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4 In order to facilitate the completion of the actions requested, a copy of Information Notice No. 88-46 and its Supplement 1 is enclosed (Attachment 3) with this bulletirm The attachments to Information Notice No. 88-46 and its Supplement 1 provide a listing of customers / distributors of the five California companies, original equipment sold as refurbished equipment and direct shipments of such equipment to nuclear plants or utilities. These lists were based on a partial review of records obtained from the identified electrical suppliers.

> h e , . 1 ; a t o f =. ""I r "e + ^-e I n + t :: h..m.n. ) h;; M :n &v; h p;d th,e d .

a pm, ciai n h e ri revice of I"S's Juvunion A It is emphasized that th b list (

may not be complete and that the actions requested should not be limited to the receiving companies and facilities identified in these lists.

ACTIONS REQUESTED:

1. All addressees are requested to review their purchasing records for original and replacement electrical equipment to determine whether they have procured electrical equipment directly or indirectly from the identi-fied companies. The sa cch for P"i perh: = r;;; Ja need vnly vuu, tb

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g, ;ud i,;r 3="~y 1,1995, tb hte Dul hg= b:in=:, te

2. All addressees who detennine that they have procured electrical equip-ment directly or indirectly from the identified companies are requested to develop three separate lists of electrical equipment:

a. A list specifying all equipment purchased as Class IE which includes its type and the chain of purchase. ;

b. A list specifying all equipment purchased as non-class IE electrical equipment and later upgraded for class 1E applications which includes its type, chain of purchase and a description of the conversion ;

process, and

,1

c. A list specifying-all equipment' purchased as.non-class 1E which includes its type, and the chain of purchase.

3. All holders of operating licenses for nuclear power reactors who determine-that they.have installed electrical equipment purchased from-these companies; or their distributors are requested to:

a. take appropriate actions to ensure that the' installed equipment used in. safety-related systems is in compliance with appropriate standards (IEEE 323 and 344,' ANSI, UL) and original manufacturer's specifica--

tions. If unqualified equipment is idkntified from this. search, then provide (1) a justification for continued operation which includes'a replacement or testing program to assure the qualifica-tion of the installed equipment; and, (2) an assessment'of the adequacy of your QA program and the remaining electrical equipment installed under that program.

b. take appropriate actions to ensure that the installed equipment used in non-safet,, 'ated systems meets the relevant industry standards (ANSI, UL) and original manufacturer's specifications. If equipment is identified as not meeting industry specifications then either:

(1) replace the escipment or (2) provide justification for its con-

~

tinued use or a testing program to assure that it is suitable for its intended purpose.

4. All holders of construction permits for nuclear power reactors who determine that they have installed electrical equipment purchased from the identified companies or their distributors are requested to:

a. .

4 t l' 5

'a.. take appropriate action, on. a schedu'le compatible with the. reporting requirements, to ensure that the procured equipment used in safety-

relatedsystems'isincompliancewithappropriate: standards (IEEE; l- '323~and344, ANSI,UL)._'Ifunqualifiedequipmentisinstalledthen:

(1) either demonstrate that it is acceptable for its intended use or replace the' installed equipment and, (2) provide an _ assessment of ,

the adequacy of your QA program and the remaining electrical equipment installed under.that pregram.

b. take appropriate actions'on a schedule compatible with the reporting requirements to ensure that the installed equipment used in.non-safety related systems is in compliance with appropriate industry standards (ANSI, UL) and original manufacturer's specifications.

If equipment is identified as not meeting industry specifications then.

either: (1) provide a testing program'to demonstrate that the identi-fied equipment is acceptable for its intended use or (2) replace the installed equipment.

5. All addressees who determine that they have purchased electrical equipment from these companies or their distributors and that thi: equipment is in storage are requested to:

~

a. take appropriate actions to ensure that the procured equipment to be used in safety-related systems is in compliance with the appropriate standards (IEEE 323, 344, ANSI, UL) and original manufacturer's speci-fications.

1

b. take appropriate actions to ensure that the procured equipment to be used in non-safety related systems meets the relevant industry standards (ANSI, UL) and original manufacturer's specifications.

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Information generated during the comp 1e' tion. of items 1,'2', 3, 4, and 5 above

~

6.

~s hall'be documented and maintained in.accordance with plant procedures for possible NRC. audit. -1 REPORTING REQUIREMENTS:-

l' . All holders of operating licenses.for nuclear power reactors'are required:

within 90 days (180 days for non-safety related systems) of the receipt of this bulletin to provide a written report that:

a. confinns that no electrical equipmen't has been procured from the identified companies or their distributors or forwards the informa--

tion requested in item 2 above.

'b. confirms that the actions requested in item 3 above have been com-pleted or provides an appropriate schedule for completion of these actions and verifies that a justification for continued operation has been completed and is being retained for NRC audit.

c. provides a cownitment that equipment in storage will conform to action item 5 prior to installation.

2. All holders of a construction permit for nuclear power reactors are required

. - to, within 90 days (180 days for non-safety related items) of receipt of this bulletin, provide a written report that:

a. confirms that no electrical equipment has'been procured from the identified companies or their distribtltors or forwards the information requested in item 2 above. (

b. confirms that the actions requested in item 4 above will be completed prior to fuel load.

.c. provides a consnitment that equipment in storage will conform to action item 5 prior to installation.

3. All addressees are requested to provide as soon as practicable a list of the electrical. equipment found to be unqualified for its intended service as a result of above actions 3, 4 and 5, and the identification of the manufacturer / supplier.

The written reports required above shall be addressed to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, under oath or affirmation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the appropriate Regional Administrator.

This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated average burden hour is 1000 man-hours per licensee response, including assessment of the new require-ments, searching data sources, gathering and analyzing the data, and preparing the required reports. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget, Room 3208, New Executive Office Building, Washington, D.C., 20503, and to the U.S. Nuclear Regulatory Commission, Records and Reports Management Branch, Office

~ of Administration and Resource Management, Washington, D.C., 20555.

Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: Paul Gill, NRR (301) 492-0811 Jaime Guillen, NRR (301) 492-1170 Joseph Petrosino, NRR (301) 492-0979

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l - Attachment 1: List of companies supplying nonconforming electrical equipment, components and devices Attachment 3: Copy of NRC Infonnation Notice No. 88-46 and its Supplement 1 Attachment 4: List of Recently Issued NRC Bulletins i

h - .____-__.___ __________.___m__

e 4 ,

ATTACHMENT 1 LIST OF COM!'ANIES SUPPLYING NONCONF0P' A ING ELECTRICAL EQUIPMENT, COMPONENTS AND DEVICES

1. General Circuit Breaker and Electr'ical Supply, Inc.

Los Angeles, CA.

2. HLC Electric Supply Co., Inc.

Los Angeles, CA.

3. PENCON International, Inc./ General Magnetics /

Electric Wholesale Los Angeles, CA.

4. California Breakers, Inc.

Los Angeles, CA.

5. Anti-Theft Systems, Inc../ATS Circuit Breakers /

AC Circuit Breakers-Electrical Supply, Los Angeles, CA.

M rn I

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ROUGH DRAFT

.8/5/88 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON D.C. 20555 JULY XX, 1988 NRC BULLETIN 88-XX: NONCONFORMING ELECTRICAL EQUIPMENT, COMPONENTS AND DEVICES

' ADDRESSEES:

All holders of operating licenses or construction permits for nuclear power reactors.

PURPOSE:

' The purpose of this bulletin is to request that addressees take actions: to assure that any installed electrical equipment, components and devices procured from the companies listed in attachment I comply with industry standards,'such as IEEE I and Underwriters Laboratory (UL), and original manufacturer's specifications, to demonstrate that the identified electrical equipment, components and devices are acceptable for their intended use; or replace the electrical equipment, components

,and devices.

DESCRIPTION OF CIRCUMSTANCES:

NRC Information Notice No. 88-46 " Licensee Report of Defective Refurbished Circuit Breakers," dated July 8,1988 and its supplement 1, dated July 21, 1988, respectively discussed a report by Pacific Gas and Electric which indicated that the Diablo Canyon Nuclear Power Plant had been supplied 30 circuit breakers (CBs) by Anti-Theft Systems, Inc. through a local electrical distributor. These CBs (Square D molded case, type KHL 36125), were intended for use in non-safety-related I

applications at the Diablo Canyon nuclear power plant. Square D company reported that the inspection and testing of these breakers determined that the CBs were refurbished Square D Company equipment. Further, Square D reported that none of the circuit breakers tested complied with Square D or UL 1 specifications for all of the electrical tests performed. Information Notice No. 88-46 also listed several California companies that were involved in supplying possibly defective refurbished electrical equipment to the nuclear industry.

NRC Information Notice No. 88-19 " Questionable Certification of Class 1E Components,"

dated April 26, 1988 discussed a 10 CFR Part 21 notification, submitted on April 1, 1988 by the Wolf Creek Nuclear Operating Corporation (WCNOC) which brought into question the validity of Certificates of Compliance issued by Planned Maintenance Systems, Inc. (PMS) for Class IE fuses. In response to this notification, the NRC staff inspected PMS. Components supplied by PMS with questionable certification included circuit breakers, fuses and relays. NRC investigation of this issue in regard to PMS is not complete. NRC is gathering additional information regarding electrical equipment supplied by PMS, and it warranted a supplement to the bulletin be issued.

These examples indicate that there is a potential generic safety concern regarding electrical equipment supplied to nuclear power plants. The NRC is concerned that the equipment procured as being new and meeting all applicable industry requirements

~ and original manufacturer's specifications may in fact not conform to these re-quirements and specification. ,

The actions requested in this bulletin are primaril related to CBs I, fuses and relays due to their widespread use and applications vnd the potential impact of

]

their failure.

1. Non-automatic CBs (i.e., CBs without thermal and magnetic trip units) are not impacted by this Bulletin.

e .

b ACTIONS REQUESTED

All holders of operating licenses and construction permits for nuclear reactor are requested to:

1. determine whether they have procured electrical equipment directly or indirectly from the-identified companies (attachment 1), and whether this equipment is installed in safety related systems. If it'is determined.that such equipment is i.nstalled in safety related systems then provide-a justification for continued operation which includes a replacement and/or testing program to assure.that the-installed equipment is suitable for the intended service.

'2. retain a list of all- equipment purchased from the identified companies as non-class 1E electrical equipment and later upgraded for class IE applications.which includes its type, chain of. purchase and description of the conversion process.

3. describe your program for the installed non-safety related electrical equipment procured from the identified companies that it is suitable for the intended service.

~4' . take steps to ensure that the electrical equipment purchased from the identified companies directly or indirectly which is in storage is suitable for its intended service prior to use.

5. retain all electrical equipment procured from the identified companies which is found to be unsuitable for its intended service.

6. Information generated during the completion of items 1,2,3,4 and 5 above shall be documented and maintained in accordance with plant procedures for possible NRC audit.

REPORTING REQUIREMENTS:

1. All holders of operating licenses for nuclear power reactors are required within 180 days (before restart from the next refueling outage which begins 180 days subsequent to the date of this bulletin for non-safety system) of the receipt of this bulletin to provide a written report that:

a. confirms that the actions requested in items 1,2,3 and 5 above have been completed or provides an appropriate schedule for completion of these actions and verifies that a justification for continued operation has been completed and is being retained for NRC audit.

b. provides a commitment that equipment in storage will conform to action item 4 prior to installation.

t@

2. All holders of a co truction permits for nuclear power reactors are /j required to within days (no later than 180 days after the fuel load l date for non-safety related items) of receipt of this bulletin, provide a written report that:

a, confirms that the actions requested in items 1,2,3 and 5 above will be completed prior to fuel load.

b. provides a commitment that equipment in storage will conform to action item 4 prior to installation.

3. All addressees are requested to provide as soon as practicable a list cf the electrical equipment found to be unqualified for its intended service as a result of above actions 1,2,3 and 5 and the identification of the manufacturer / supplier.

1

I.

O The written reports required above shall be addressed to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, under oath or affirmation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the appropriate Regional Administrator.

This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated average burden hour

-is 1000 man-hours per licensee response, including assessment of the new require-ments, searching data sources, gathering and analyzing the data, and preparing the required reports. Coments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget, Room 3208, New Executive Office Building, Washington, D.C., 20503, and to the U.S. Nuclear Regulatory Comission, Records and Reports Management Branch, Office of Administration and Resource Management, Washington, D.C., 20555.

Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Attachment 1: List of companies supplying nonconforming electrical equipment, components and devices

~ Attachment 2: Copy of NRC Information Notice No. 88-46 and its Supplement 1 Attachment 3: List of Recently Issued NRC Bulletins l

l

4 19, /JPd-1 ,

UNITED STATES NUCLEAR REGULATORY COMMISSION.

OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON D.C. 20555 AUGUST XX, 1988 l- l l

NRC BULLETIN 88-XX: NONCONFORMING ELECTRICAL EQUIPMENT,-

COMP 0NENTS AND DEVICES ADDRESSEES:

All_ holders of operating licenses or construction permits for nuclear power reactors.

PURPOSE:

The purpose of this bulletin is to request that addressees take actions to assure that installed molded case circuit breakers (CBs) and motor controllers (MCs) comply j with plant design requirements such as IEEE, Underwriters Laboratory (UL), National Electrical Manufacturers Association (NEMA) or original manufacturer's specifications.

The scope of requested actions are limited to molded case CBs and MCs, procured as replacements for original plant equipment, that have or may have been refurbished.

DESCRIPTION OF CIRCUMSTANCES:

NRCInformationNoticeNo.88-46"LicenseeReportofDefectiveRefurbishddCircuit

-Breakers," dated July 8,1988 and its supplement 1, dated July 21, 1988, discussed a report by Pacific Gas and Electric which indicated that the Diablo Canyon Nuclear Power Plant had been supplied 30 CBs by Anti-Theft Systems, Inc. through a local electrical distributor. These CBs (Square D molded case, type KHL 36125), were intended for use in non-safety-related applications at the Diablo Canyon nuclear power plant. Square D company reported that the inspection and testing of these breakers determined that the CBs were refurbished Square D Company equipment.

Further, Square D reported that many of the circuit breakers tested did not comply

~

3

4 with Square D or UL specifications for all of the electrical tests performed.

Information Notice No. 88-46 also listed several California companies that were involved in supplying possibly defective refurbished electrical equipment to the nuclear industry.

NRC Information Notice No. 88-19 " Questionable Certification of Class 1E Components" dated April 26, 1988 discussed a 10 CFR Part 21 notification, submitted on April 1, 1988 by the Wolf Creek Nuclear Operating Corporation (WCNOC), which brought into question the validity of Certificates of Con;pliance issued by Planned Maintenance Systems, Inc. (PMS) for Class IE fuses. In response to this notification,'the NRC staff inspected PMS. Components supplied by PMS with questionable certification included circuit breakers, fuses and relays. The NRC investigation of this issue is not complete and, if warranted, a supplement to this bulletin may be issued.

These examples indicate a potential safety concern regarding electrical equipment supplied to nuclear power plants. The NRC is concerned that the equipment procured as being new and assumed to meet all applicable plant design requirements and/or original manufacturer's specifications may in fact not conform to these requirements and specifications.

The actions requested in this bulletin are only related to molded case CB,s and MCs due to their widespread use and applications and the potential impadt of their fa'ilure. Molded case CBs are tested and calibrated at the manufacturer's plant in accordance with recognized industry standards (UL-489-Molded-Case Circuit Breakers and Circuit Breaker Enclosures, NEMA-AB1-Molded-Case Circuit Breakers).

Since molded case CBs have factory-calibrated and sealed elements, any unauthorized modification or refurbishing of the CBs jeopardize their capability and reliability, as well as the manufacturer's warranty. Tne MCs are also built in accordance with similar NEMA standards and are UL listed, and any unauthorized refurbishing of such equipment compromises its integrity. Therefore, reliable operation of refurbished molded case CBs and MCs installed in nuclear power plants cannot be relied upon, due to lack of assurance of uniformity of parts, materials and workmanship used in unauthorized refurbishing activities.

.- . i I k

. i

)

The NRC is concerned about refurbished CBs and MCs purchased as commercial grade (non-Class IE) for later upgrading to safety grade (Class 1E) applications, because these CBs and MCs may not meet the minimum commercial grade standards.

In order to dedicate electrical items procured as commercial grade and subse-quently used in safety-related systems, the dedication process should build from the commercial grade quality, and include proper evaluation of ' seismic and environ-mental qualification, as well as confirmation of critical operating parameters and functional testing as appropriate. When refurbished CBs and MCs are upgraded to safety grade applications, the NRC is concerned that the licensee's normal dedication process may not be adequate for properly evaluating the acceptability of the components.

The safety grade electrical equipment originally purchased as Class 1E is not a concern, since this equipment is purchased anc installed under quality assurance (QA) programs which conform with Appendix B of 10 CFR 50. The controls imposed by these QA programs are more stringent than the controls exercised in procurement of comercial grade equipment. Further, the requirements of these QA programs are well established and known to electrical equipment suppliers and are subject to frequent audits.

The NRC believes that the safety concern does not extend to the electrica,1 equipment (Class IE and non-Class 1E) originally installed since this efipment was

~ pr'ocured during plant construction from original manufacturers with full certifica-tion. Moreover, this equipment was inspected and tested before the nuclear plant became operational. The large quantities of electrical assemblies or components procured under bid packages minimizes the possibility of small vendors doing refurbishing business having supplied original equipment.

The actions requested in this bulletin apply only to molded case CBs and MCs pro-cured as replacements for original plant equipment as indicated in action item 1 below. However, the NRC investigation of this issue is not complete. A supplement to the bulletin may be issued to include other electrical equipment if warranted by the results of the ongoing evaluation.

l

i

, ivs4 .

v/

d ACTIONS REQUESTED:

. 1. . All a'ddressees are requested to review their records to identify the number, typesandapplicationsofinstalled(orstoredspare)replacementmolded caseCBsandMCs,thatwereprocuredascommercialgrade(non-ClassIE)and later upgraded to safety grade (Class 1E), that were not procured from the original manufacturers,1 or whose procurement source has not been determined.

Replacement CBs and MCs, procured from distributors who cannot demonstrate the equipment was procured directly fro the original equipment manufacturer without intermediate refurbishment,5 t be assumed to be unacceptable.

2. All addressees that identified installed CBs or MCs per item 1 above are ,

requested to replace these CBs or MCs with fully qualified components, et g/M providejustificationforcontinuedoperations(JCO)untilthesuspectCBs A r or MCs are replaced, to be completed not later than before startup after M the second refueling outage from the date of this bulletin. (for all holders /7 of cps, the CB or MC replacement should be completed prior to fuel load)

3. All addressees that identified stored spare CBs or MCs per item 1 above are requested to take appropriate actions to ensure that these CBs are not used for safety-related service.

'I'

1. Original Manufacturers are defined as those companies that

' ' manufacture the CBs. Supply companies distributing CBs (WESCO, GESCO, GRAYBAR and others) are not considered as original manufacturers of CBs.

____m.__________

i l

(. '

l l

4. All addressees are requested to develop a program for the installed or in storage non-safety related replacement molded case CBs and MCs, that were not procured from the original manufacturer or whose original source has not been determined, to assure that they are suitable for the intended service. A joint industry program which attains this objective is encouraged.

5. Information generated during the completion of items 1,2,3 and 4 above shall be documented and maintained for possible NRC audit.

REPORTING REQUIREMENTS:

1. All holders of operating licenses for nuclear power reactors are required within 120 days of the receipt of this bulletin to provide a written report that:

a. confirms that no molded case CBs or MCs have been procured and upgraded as described in action item 1, or forwards the information requested in action item 1.

b. confirms that the CB and MC replacement actions requested in action item 2 have been completed, or provides an appropriate schedule for completion of these actions and confirms that a justificationsfor

- continued operation has been completed and is being retained for possible NRC audit.

c. confirms action item 3 has been completed.

2. All holders of a construction permit for nuclear power reactors are required to, within 120 days of receipt of this bulletin, provide a written report that:

L l

I i

a. confirms that no molded case CBs or MCs have been procured and upgraded as described in action item 1, or forwards the information requested in item 1.

b. confirms that the CB and MC replacement action requested in action item 2 will be completed prior to fuel load.

confirms action item 3 has been completed. !

c.

3. All addressees are requested to provide a report, within 180 days of receipt of this bulletin, that confirms that no molded case CBs or MCs have been pro-cured for non-safety related applications as described in action item 4, or that describes the program fa g The under action item 4.

The written reports required above shall be addressed to the U. S. Nuclear l Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, under oath or affirmation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the appropriate Regional Administrator.

This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated average burden' hour

~is 400 man-hours per plant response, including assessment of the new require-ments, searching data sources, gathering and analyzing the data, and preparing the required reports. Comments on the accuracy of this estimate and suggestions toreducetheburdenmaybedirectedtotheOfficeofManagementandBudget, Room 3208, New Executive Office Building, Washington, D.C., 20503, and to the U.S. Nuclear Regulatory Commission, Records and Reports Management Branch, Office of Administration and Resource Management, Washington, D.C., 20555.

Charles E. Rossi, Director )'

Division of Operational Events Assessment Office of Nuclear Reactor Regulation i

l I

- _ _ _ _ - _ _ - - _ - _ _ _ _ - _ - _ _ _ _ . _ _ _ _ l

o Technical Contacts: PaulGill,NRR(301)492-0811' JaimeGuillen,NRR(301)492-1170 Attachment 1: List of Recently. Issued NRC Bulletins

/

9 L:_ _ _ _ ___ _ -_ _ _ --_ _ _. - _ _ -. I

u, , ;

10/4/88

" DRAFT l

'l SELB j

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR PEGULATION WASHINGTON D.C. 20555 j August xx, 1988 i

Addressees:

?

All holders of operating licenses or construction permits for nuclear power reactors.

Purpose:

)

The purpose of this bulletin is-to request that addressees take actions to ;

assure that molded case circuit breakers (CBs) and motor controllers (MCs) )

which have been installed as replacements for original plant equipment, in- ]

stalled during modifications, or are being maintained as stored spares comply {

with plant design requirements such as IEEE, Underwriters Laboratory (UL),

i National Electrical Manufacturers Association (NEMA)'or original manufacturer's specifications. The scope of requested actions is limited to molded case CBs and MCs that were procured from any source as coninercial grade and later upgraded }

to safety grade, or that were procured as safety grade from a source other than the I 1 original manufacturer or whose original source has not been determined.

Description of Circumstances:

NRC Information Notice No. 88-4C, " Licensee Report of Defective Refurbished Circuit Breakers," dated July 8,1988 and its Supplement 1, dated July 21, 1988, discussed a report by Pacific Gas and Electric which indicated that the Diablo Canyon Nuclear Power Plant had been supplied 30 CBs by Anti-Theft Systems, Inc.

through a local electrical distributor. These CBs (Square D molded case, type KHL 36125) were intended for use in non-safety-grade applications at the Diablo Canyon Nuclear Power Plant. Square D Company reported that the inspection and

~ .

- 10/4/88 DRAFT SELB testing of these breakers determined that the CBs were refurbished Square D Company equipment. Further, Square D reported that many of the circuit breakers tested did not comply with Square D or VL specifications for all of the elec-trical tests performed. Information Notice No. 88-46 also listed several California companies that were involved in supplying possibly dafective refurbished electrical equipment to the nuclear industry.

NRC Information Notice No. 88-19 " Questionable Certification of Class 1E Com-ponents" dated April 26, 1988 discussed a 10 CFR Part 21 notification, submitted on April 1,1988 by the Wolf Creek Nuclear Operating Corporation (WCNOC), which brought into question the validity of Certificates of Compliance issued by Planned Maintenance Systems, Inc. (PMS) for Class 1E fuses. In response to this notification, the NRC staff inspected PMS. Components supplied by PMS with questionable certification included circuit breakers, fuses and relays.

The NRC investigation of this issue is not complete, and, if warranted, a sup-plement to this bulletin may be issued.

These examples indicate a potential safety concern regarding electrical equip-ment supplied to nuclear power plants. The NRC is concerned that the equipment procured as being new and assumed to meet all applicable plant design require-

, ments and/or original manufacturer's specifications may, in fact, not conform to these requirements and specifications.

The actions requested in this bulletin are only related to molded case CBs and MCs, due to their widespread use and applications and the potential impact of their failure. Molded case CBs are tested and calibrated at the manufacturer's plant in accordance with recognized industry standards (UL-489-Molded Case Circuit Breakers and Circuit Breaker Enclosures and NEMA-AB1-Molded-Case Circuit Breakers). Since molded case CBs have factory-calibrated and sealed elements,

1 *..

l-10/4/88-DRAFT SELB I,

l any unauthorized modification or refurbishing of the CBs jeopardize their capa-bility and reliability, as well as the manufacturer's warranty. The MCs are also built in accordance with similar NEMA standards and are UL listed, and any unauthorized refurbishing of such equipment compromises its integrity.

Therefore, reliable operation of refurbished molded case CBs and MCs installed in nuclear power plants cannot be relied upon, due to lack of assurance of uniformity of parts, materials and workmanship used in unauthorized refurbishing activities.

The NRC is concerned about refurbished CBs and MCs purchased as commercial grade (non-Class 1E) for later upgrading to safety-grade (Class 1E) applications, because these CBs and MCs may not meet the minimum commercial grade standards.

In addition, the NRC is concerned about commercial grade breakers that are up-graded to safety-grade by the licensee because of observed inadequacies in the dedication process and the significant number of failures found during testing ;

of these breakers. In order to dedicate electrical items procured as comercial grade and subsequently used in safety-grade systems, the dedication process should build from the commercial grade quality, and include proper evaluation of seismic and environmental qualification, as well as confirmation of critical operating parameters and functional testing as appropriate. When CBs and MCs are upgraded

- to safety-grade applications, the NRC is concerned that the licensee's normal dedication process may not be adequate for properly evaluating the acceptability of the components for safety-grade service.

The safety-grade electrical equipment purchased as Class 1E from the original manufacturer is not a concern, since this equipment is purchased and installed I under quality assurance (QA) programs which conform with Appendix B of 10 CFR 50.

The controls imposed by these QA programs are more stringent than the controls exercised in procurement of commercial grade equipment. Further, the

m_ __- _ _ - _ _ _ _ _ _ - _ - _-

.*.a t

10/4/88 l DRAFT SELB-I requirements of. these QA programs are well established and known to electrical equipment' suppliers and are subject to frequent audits.-

' The NRC believes that the safety concern does not extend to the electrical equipment (Class 1E and non-Class 1E) originally installed since this equipment was procured during plant construction from original . manufacturers with full .

certification. Moreover, this equipment was inspected ~and tested before the nuclear plant became operational. The large quantities of electrical assemblies or components procured under bid ~ packages minimizes the possibility of small vendors'doing' refurbishing business having supplied' original; equipment.

The' actions requested in this bulletin. apply only to molded case CBs and MCs procured as replacements.for original plant equipment, procured in conjunction with subsequent plant. modifications, or being maintained as stored' spares,.as indicated in action item i below. However, the NRC investigation of this issue is not complete. A supplement to the bt11etin may be issued to include other electrical equipment if warranted by the results of the ongoing evaluation.

Actions Req 0ested (see Figure 1):

1. All addressees are requested to review their records to identify the number, types and applications of molded case CBs and MCs which have been installed as replacements for original plant equipment, installed during modifications, or are being maintained as stored spares, that were procured from any source as commercial grade (non-Class 1E) and later upgraded to safety-grade (Class 1E), or that were procured as safety-grade from a source other than the original manufacturer or whose original source has not been determined.

2. All holders of operating lict.nses that identify installed CBs or MCs per item 1 above are requested to replace these CBs or MCs with fully qualified

l>g. M

- 10/4/88 DPAFT SELB components, or to test (and replace failed components) in accordance wit? !

l the test program described in Attachment 1. The replacement or testing :

program,'whichever is selected, should.be completed prior to startup after the third refueling outage from receipt of this bulletin (for all holders of cps, the CB or MC replacement or testing should be completed prior to-fuel load), with 1/3 but no less than a total of 50 of the identified CBs or MCs (pro rated) replaced or tested at.each refueling. Within 120 days of the receipt of this bulletin, holders of operating licenses should complete a justification for continued operations (JCO) for the interim i period until such time that the suspect CBs or MCs are replaced. q

3. All addressees that identify stcred spare CBs or MCs per item I' above are requested to take appropriate actions to ensure that these CBs are l not used for safety-grade service until they have been tested in accord-i ance with the testing program described in attachment 1.

4. All addressees are requested to develop a program for non-safety-grade-molded case CBs and MCs which have been installed as replacements for original plant equipment, installed during modifications, or are being maintained as stored spares, that were not procured from the original manufacturers or whose original source has not been determined, to assure that they are suitable for the intended service. A joint industry pro- j gram which attains this objective is encouraged. f i

5. Information generated during the completion of items 1,2,3 and 4 above l

shall be documented and maintained for possible NRC audit,

6. Molded case circuit breakers and motor controllers installed after March 1, 1989 in safety related applications should be:

4

1

',f , .

10/4/88 l

DRAFT ',

SELB-La. manufactured by and procured' from an Original ~ Equ'ipment' Marwfacturer

. (OEM).under a 10 CFP 50 Appendix' B program; or

b. procured from an OEM with certified (1) seismic qualification, (2)manufactureunderapplicableindustrystandards(NEMA,UL),

and (3) upgrading to Class'1E by the OEM using tests equivalent to-those in Attachment 1; or -

I

c. procuredfrom'anOEMwithcertified(1)seismicqualificationand' (2) manufacture under applicable industry standards, and upgraded to Class 1E by the licensee or by others under the supervision of.

the-licensee using tests equivalent to those of Attachment 1.

Reporting Requirements:

1.- All holders of operating licenses are required within 120 days of'the l 1

receipt of this bulletin to provide a written report that:

a. confirms that no molded case CBs or MCs have been procured and upgraded as described in action item 1, or forwards the information.

.. requested in action item 1. .j b, confirms that the CB and MC replacement or testing actions requested in action item 2 have been completed, or provides an appropriate schedule for completion of these actions) and confirms that a justification for continued operation has been completed and is being retained for possible NRC audit. (

\

c. confirms action item 3 has been completed.s

d. confirms action item 6 will be followed.

l- 2. All holders of construction permits are required within 120 days of l

receipt of this bulletin to provide a written report that:

10/4/88 DRAFT SELB

i

a. confirms that no molded case CBs or MCs have been procured and upgraded as described in action item 1, or forwards the information requested in item 1.

b. confirms that the CB and MC replacement or testing actions requested in action item 2 will be completed prior to fuel load.

c. confirms action item 3 has been completed.

d.- confirms action item 6 will be followed.

3. All addressees are required to provide a report, within 180 days of receipt I

of this bulletin, that confirms that no molded case CBs or MCs have been procured for non-safety-grade applications as described in action item 4, or that describes the program requested under action item 4.

The written reports required above shall be addressed to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, under oath or affirmation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the

, appropriate Regional Administrator.

This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated average burden hour is 400 man-hours per plant response, including assessment of the new require-ments, searching data sources, gathering and analyzing the data, and preparing the required reports. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget, Room 3208, New Executive Office Building, Washington, D.C., 20503, and to the U.S. Nuclear Regulatory Commission, Records and Reports Management Branch, Office !

of Administration and Resource Management, Washington, D.C., 20555.

Charles E. Rossi, Director Division of Operatonal Events Assessment Office of Nuclear Reactor Regulation

1..., , ,

.g.

Technical Contacts: Paul Gill, NRR (301) 492-0811 JaimeGuillen,NRR-(301)492-1170 Attachments: 1. Test program for Molded Case Circuit Breakers .

and Motor Controllers

2. 1.ist of Recently Issued NRC Bulletins' O &

4 E

ATTACHMENT 1 TEST PROGRAM FOR M0LDED-CASE CIRCUIT BREAKERS AND MOTOR CONTROLLERS 1.0 Test Program Objectives The objective of this proposed test program is to verify the performance of molded-case circuit breakers (CBs) and motor controllers (MCs) that were procured as commercial grade (non-class IE) and later upgraded to safety grade (class 1E), or that were procured as safety grade in a manner described in Bulletin No. 88-xx such as to bring into question their safety grade classification. All such CBs or MCs that are in-stalled in class IE systems should be tested in'accordance with this pro-gram. Also, all such CBs or MCs that are in storage should be tested in accordance with this program before they are installed in class IE systems.

The purpose of the proposed tests is to provide a reasonable assurance that the tested CBs or MCs are suitable for the intended service. A minimum of one-third (1/3) of such CBs or MCs but not less than 50 CBs or MCs (pro-rated) should be tested every refueling outage until all CBs or MCs have been tested as outlined in this program.

For the safety of personnel and others involved with the activities re-lated to these proposed tests, appropriate safety practices (such as ANSI /NFPA 70E, Part II) should be followed.

The below listed tests proposed for the CBs and MCs have been based on tests described in industry standards, such as NEMA AB-1 (Molded Case Circuit Breakers), UL 489 (Molded Case Circuit Breakers and Circuit Breaker Enclosures), NEMA 1CS1-6 (Industrial Control and Systems Equipment) and UL 508 (Industrial Control Equipment).

,- y.

2.0 Test Procedures for CBs The'fo110 wing tests should be performed in the order of sequence listed.

2.1 Mechanical Test The CB should be tripped, reset and closed a minimum of five times to insure that the latching surfaces are free of any binding.

2.2 Time-Overcurrent Trip Test 2.2.1 Rated Current Hold-In Test This test should be conducted at 100% rated current and at an ambient air temperature of 40*c 3'c, or at 135% rated current and at an ambient temperature of 25'c 3*c.

Equal current should be applied to all poles of the CB; and CB must not trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for CBs rated 50 amperes or below and within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for CBs rated over 50 amperes.

2 2.2 Overload test This test consists of I operating cycle (i.e., closing action followed by an opening action) of the CB at 600% rated current. There shall be no electrical or mechanical breakdown of the CB during this test.

2.2.3 Time Delay Overcurrent Trip This test should be conducted at an ambient air temperature of 25 degrees c : 3 degrees c.

F

1. ]

1 A current of 300 percent of the marked rating should be applied to each pole of the CB. The trip time for each pole should be com-pared against the time'shown in the CB manufacturer's time-current curves. If the test trip times obtained for each pole are not with-in the time band shown on the CB manufacturer's. time-current curves, then the test trip must not exceed the time specified in table-1 and the acceptance of CB evaluated with the criter(a as listed below:

TABLE 1 VALUES FOR OVERCURIENT TRIP TEST (AT 300% OF RATED CONTINUOUS CURRENT OF CIRCUIT BREAKER)

(REF. NEMA AB-2)

Breaker Range of Rated Voltage Continuous Current Maximum Trip Time Volts Amperes In Seconds 240 15-45 50 240 50-100 70 600 15-45 70 600 50-100 125 240 110-225 200 1 240 250-400 300 600 110-225 250 600 250-400 300

. . 600 450-600 350 600 700-1200 500 600 1400-2500 600 600 3000-5000 650 Minimum trip times: If the minimum tripping times are lower than indi-cated by the manufacturer's time-current curves for the breaker under test, the breaker should be retested after it has been cooled to 25'C. l If the values obtained are still lower after retest, the coordination with upstream and downstream breakers should be evaluated. If no mis- !

coordination is indicated, then the CB is acceptable.

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~

1 Maximum tripping time: If the tripping time exceeds the maximum tripping time shown on the manufacturer's time-current curves but is below the time shown in table 1 above, check the breaker time against the protection re-quirements of the circuit (such as cable, penetration, etc.) to ensure ,

that the CB provides the protection, as well as the coordination with up-stream and downstream CBs. If the CB provides the necessary protection and coordination, then the CB is acceptable.

Maximum allowable time: If the tripping. time of the CB exceeds the trip time shown in the table 1 above, the breaker is unacceptable for class IE applications.

2.3 Instantaneous Trip Test 2.3.1 Fixed Instantaneous Setting CBs Each pole of the CB should be tested for pickup of the instan-taneous unit. The average of the three readings for each pole must be between 80% and 120% of the instantaneous trip setting as shown on the manufacturer time-current curves. The trip time should not exceed .05 seconds (3 cycles).

~

2'. 3. 2 Adjustable Instantaneous Setting CBs Same as 2.3.1 except that each pole must bestested at the lowest and highest setting, j t

The average trip value for the lowest setting ~should be between 75 percent and 125 percent, and the highest setting should be between 80 percent and 120 percent of the setting value shown on the manufacturer's time-current curves.

~ .

2.3.3 Short-time trip setting test This test is applicable only if the CB is equipped with the short-time delay trip. This test should be conducted at an ambient air temperature of 25'c 2 3 c. The operation of the short-time delay unit should be within 90% and 125% of the overcurrent setting of the CB as shown on the manufacturer's time-current curves.

Individual Pole Resistance Test 2.4 The contact resistance of each pole of the CB should be measured at ambient temperature. The average of 3 readings for each pole should be calculated and compared with the manufacturer's data or with those of similar CBs of the same manufacturer. Also, the average reading of each pole should be compared with each other and the difference between the pole readings should not exceed fifty percent.

2.5 Dielectric Tests The dielectric test should be conducted at an ac test voltage of 2200 volts (2 x Rated Voltage + 1000 volts) for 1 minute withstand. The dielectric test should be conducted for (1) line to load terminals with CB open, (2) line to line terminals with CB closed, and (3) pole

' ~

to ground with CB open and closed.

3.0 Test procedures for MCs The following tests should be performed in the order of sequence i listed.

3.1 Make and break test (overload test) i The make and break test for manual and magnetic starters should be performed with a current value equal to the most severe locked rotor i

..z 1 I

J

- j current for.the range of application of the MC, for a minimum of 5 4 operations. During this test there should be no electrical or mechanical breakdown of the MC, no undue burning, pitting or welding of the contacts.

3.2 Range of operating voltage test (under and overvoltage test)

DC contactors shall withstand 110% of their rated voltage continuously for a period of not less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months without injury to the operating coils and shall close successfully at 80% of their rated voltage.

AC contactors shall withstand 110% of their rated voltage continuously for a period of not less than I hour without injury to the operating coils and shall close successfully at 85% of their rated voltage.

3.3 Rated current carrying test (Temperature Test)

The motor controllers (contactors and starters) should be energized and carry rated current in an ambient temperature of 40*c. The motor controller should carry this current until steady state con-ditions are reached, and the temperatures are constant. The temper-ature rise of the coils and controller contacts should be within the manufacturer's specified ratings for the motor controller under test. The overload should not trip during the test.

3.4 Overload relay trip test Each overload relay in the motor controller should be tested at an ambient temperature of 40 c with a primary current of 200 percent of the current element rating at the high and low points of the

_w l

~

operating range, and the trip time for each relay compared cgainst the relay operating time at 100 percent setting. The relay trip times obtained from the test should be within manufacturer's tolerance.

3.5 Short-circuit protection test In cases, where the short-circuit (magnetic) protection is provided by a molded case circuit breaker (CB),,it should be tested in accord-ance with the appropriate criteria of section 2.

3.6 Individual pole contact resistance test The contact resistance of each pole of the motor controllers should be neasured at ambient temperature. The average of 3 readings for each pole should be calculated and compared with the manufacturer's data or with those of similar size controllers of the same manufacturer. Also, the average reading of each pole should be compared with each other and the difference between the pole readings should not exceed fifty percent.

3.7 Dielectric tests The dielectric test should be conducted at an ac test voltage of 2200 volts (2 x rated voltage + 1000V) for 1 minute withstand. The dielectric test should be conducted between (1) uninsulated live parts and the en-closure with contacts open and closed, (2) line to line terminals with contacts closed, and (3) insulated live parts of different circuits.

- r

- 10/12/88 DRAFT SELB.

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON D.C. 20555 October xx, 1988 Addressees:

All holders of operating licenses or construction permits for nuclear power reactors.

Purpose:

The purpose of this bulletin is to request that addressees take actions to assure that molded case circuit breakers (CBs) including CBs used with motor controllers which have been installed as replacements for original plant equipment, installed during modifications, or are being maintaine; as stored spares comply with plant design requirements such as IEEE, Underwriters Laboratory (UL), National Electrical Manufacturers Association (NEMA) or orig-inal manufacturer's specifications. The scope of requested actions is limited

.to molded case CBs that were procured from any source without verifiable trace-ability tol the original equipment Manufacturer (OEM)I as commercial grade and later upgraded to safety grade, or that were procured as safety grade but without verifiable traceability to OEM from a source other than the original manufacturer.

Items procured as safety related from OEM or from a source other than the OEM but l with verifiable traceability to OEM ana dedicatedI for safety related applications are excluded from the scope of this Bulletin.

Description of Circumstances:

NRC Information Notice No. 88-46, " Licensee Report of Defective Refurbished Circuit Breakers," dated July 8,1988 and its Supplement 1, dated July 21, 1988, l !

I

1. refer to attachment 2 for Definition of Terms J

L

4 10/12/88 DRAFT SELB discussed a report by Pacific Gas and Electric which indicated that the Diablo Canyon Nuclear Power Plant had been supplied 30 CBs by Anti-Theft Systems, Inc.

through a local electrical distributor. These CBs (Square D molded case, type KHL 36125) were intended for use in non-safety-grade applications at the Diablo Canyon Nuclear Power Plant. Square D Company reported that the inspection and testing of.these breakers determined that the CBs were refurbished Square D Company equipment. Further, Square D reported that many of the circuit breakers tested did not comply with Square D or VL specifications for all of the elec-trical tests performed. Information Notice No. 88-46 also listed several California companies that were involved in supplying surplus and possibly defective refurbished electrical equipment to the nuclear industry.

NRC Information Notice No. 88-19. "Questiranable Certification of Class IE Com-ponents" dated April 26, 1988 discussed a 10 CFR Part 21 notification, submitted on April 1,1988 by the Wolf Creek Nuclear Operating Corporation (WCNOC), which brought into ouestion the validity of Certificates of Compliance issued by Planned Maintenance Systems, Inc. (PMS) for Class 1E fuses. In response to this notification, the NRC staff inspected PMS. Components supplied by PMS with questionable certification included circuit breakers, fuses and relays.

These examples indicate a potential safety concern regarding electrical equip-

' ment supplied to nuclear power plants. The NRC is concerned that the equipment procured as being new and assumed to meet all applicable plant design require-ments and/or original manufacturer's specifications may, in fact, not conform to these requirements and specifications.

The actions requested in this bulletin are only related to molded case CBs due to their widespread use and applications and the potential impact of their failure. Molded case CBs are tested and calibrated at the manufacturer's plant in accordance with recognized industry standards (UL-489-Molded Case Circuit Breakers and Circuit Breaker Enclosures and NEMA-AB1-Molded-Case Circuit Breakers). Since molded case CBs have factory-calibrated and sealed elements, L_______________._._

10/12/88 DRAFT SELB any unauthorized modification or refurbishing of the CBs jeopardize their capa-bility and reliability, as well as the manufacturer's warranty. Therefore, re-liable operation of refurbished molded case CBs installed in nuclear power plants cannot be relieu upon, due to lack of assurance of uniformity of parts, materials and workmanship used in unauthorized refurbishing activities.

The NRC is concerned about refurbished CBs purchased as commercial grade (non-Class 1E) for later upgrading to safety-grade (Class 1E) applications, because these CBs may not meet the minimum commercial grade standards. In addition, the NRC is concerned about commercial grade breakers that are upgraded to safety-grade because of observed inadequacies in the dedication process and the significant number of failures found during testing of these breakers. In order to dedicate electrical items procured as consnercial grade and subsequently used in safety-grade systems, the dedication process should build from the commercial grade quality, and include proper evaluation of seismic and environmental qualification, as well as confirmation of critical operating parameters and functional testing as appropriate.

When CBs are upgraded to safety-grade applications, the NRC is concerned that the observed dedication process as currently used by licensees and others may not be adequate for properly evaluating the acceptability of the components for safety-grade service.

The safety-grade electrical equipment purchased as Class 1E from the original manufacturer (0EM) or a corporate division associated with the OEM is of lesser concern, since this equipment is controlled under quality assurance (QA) programs which conform with Appendix B of 10 CFR 50. The controls imposed by these QA programs are more stringent than the controls exercised in procurement of commer-ciel grade equipment. While the upgrading programs of OEM or a corporate division l

associated with the OEM may vary in quality, the controls exercised over the pro-curement and manufacturing provide reasonable assurance that improperly refurbished

10/12/88 DRAFT-SELB components have not been introduced and passed through the upgrading process.

Further, the redundancy of safety systems and the in-service use of these com-ponents provide a reasonable basis for accepting installed replacement components that have been procured as safety grade from the OEM or from a corporate division associated with the OEM.

The NRC believes that the actions described in this bulletin need not extend to the electrical equipment (Class 1E and non-Class 1E) originally installed, at this time. This equipnent appears to have been procured during plant construction from original manufactueert with full certification. The large quantities of electrical assemblies or components procured under bid psakages minimizes the possibility of small vendors doing refurbishing business having supplied original equipment.

The actions requested in this bulletin apply only to molded case CBs procured l within the last five years from the date of this-bulletin for replacement for plant equipment, for plant modifications, or for maintaining as stored spares, as indicated in action item I below. However, the NRC investigation of this issue is not complete. A supplement to'the bulletin may be issued to include other electrical equipment or a longer review period for procurement if war-ranted by the results of the ongoing evaluation or the results of testing called for by this bulletin.

Actions Requested

)

1. All addressees are requested to review their records of purchases for the last 5 years from the date of this bulletin to identify the number, types and applications of molded case CBs which have been installed as replace-ments for plant equipment, installed during modifications, or are being maintained as stored spares, that were:

l

4 10/12/88 DRAFT-SELB

-a. . procured from any source'as commercial grade without verifiable traceability to OEM and later upgraded for safety related applica- i tion or

b. procured as safety related from any source other than OEM without-verifiable traceability to OEM.

This review should be completed by February 1, 1989.

2. All holders of operating licenses that identify installed CBs per item 1 above are requested to replace these CBs with fully qualified components, or to test (and repine failed components) in accordance with the test program described in Attachment 1. The replacement or testing program, whichever is selected, should be completed prior to startup after the second refueling outage after March 1, 1989 with 1/2 but no less than a total of 50 of the identified CBs replaced or tested at each refueling shutdown after March 1989 (for all holders of cps, the CB replacement or I

testing should be completed prior to fuel load). Within 30 days of the identification of the location of suspect breakers, but no later than March 1,1989, holders of operating licenses should complete a justifi-cation for continued operations (JCO) for the interim period until such time that the suspect CBs are replaced or tested in accordance with the testing program described in attachment 1. s l

3. All addressees that identify stored spare CBs p,er item 1 above are requested to take appropriate actions immediately to ensure that these CBs are not used for safety-grade service until they have been tested in accordance with the testing program described in attachment 1.

4. All addressees are requested to develop a program for non-safety-grade molded case CBs which have been installed as replacements for plant

10/12/88 DRAFT SELB equipment, installed during modifications, or are being maintained as stored spares, that were not procured from the original manufacturers or whose original source has not been determined, to' assure that they are suitable for the intended service. A joint industry program which attains this objective is encouraged.

5. Information generated during the completion of items 1,2,3 and 4 above shall be documented and maintained for possible NRC audit.

6. Molded case CBs installed after the date of this Bulletin in safety related !

i applications should be:

1

a. manufactured by and procured from an OEM under a 10 CFR 50 Appendix B program; or

b. procured from an OEM or others with verifiable traceability to the OEM, meeting applicable industry standards and upgraded to Class 1E by the licensee or others using tests equivalent to those of Attach-ment 1. However, it should be noted that Attachment I does not ad-dress seismic or environmental qualification requirements and that this would require additional testing or analysis based on plant-specif.c considerations.

Reporting Requirements:

1. All holders of operating licenses are required by March 1, 1989 to provide j I

a written report that:

a. confirms that no molded case CBs have been procured or upgraded as described in action item 1, or forwards the information described in action item 1.

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10/12/88 DRAFT.

SELB

b. confirms that the CB replacement or testing actions requested in action. item 2 have been completed, or confirms that the schedule in action item 2 will be adhered to, and confirms that a justi-fication for continued operation has been completed and is being retained for possible NRC audit.

c. confirms action item 3 has been completed.

d. confirms action item 6 will be followed.

e. reports the final results of and all conclusions of tests conducted in response to items 2 and 3 above in accordance with attachment I within 30 days of such tests.

2. All holders of construction permits are required by March 1,1989 to provide a written report that:

i

a. confirms that no molded case CBs have been procured or upgraded as described in action item 1, or forwards the information described in action item 1.

b. confirms that the CB and MC replacement or testing actions requested in action item 2 will be completed prior to fuel load,

c. confirms action item 3 has been completed.

d. confirms action item 6 will be followed.

e. reports the final results and conclusions of tests conducted in response to items 2 and 3 above in accordance with attachment I within 30 days of such tests.

r-t.

10/12/88 DRAFT-SELB l

3. All addressees are required to provide a report, within 180 days of. receipt l- of this bulletin, that confirms that no molded case CBs have been. procured L for non-safety-grade applications as described in action item 4, or that describes the program requested under action item 4.

The written reports required above shall be addressed to the V. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, under oath or affirmation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shall be submitted to the appropriate Regional Administrator.

This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated average burden hour is 1000 man-hours per plant response, including assessment of these require-ments, searching data sources, gathering and analyzing the data, and preparing the required reports. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget, Room 3208, New Executive Office Building, Washington, D.C., 20503, and to the U.S. Nuclear Regulatory Commission, Records and Reports Management Branch, Office of Administration and Resource Management, Washington, D.C., 20555.

Charles E. Rossi, Director Division of Operatonal Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: Paul Gill, NRR (301) 492-0811 Jaime Guillen, NRR (301) 492-1170 Attachments: 1. Test program for Molded Case Circuit Breakers and Motor Controllers

2. Definitions of Teims

3. List of Recently Issued NRC Bulletins

. . - - _ _ . - - - - . - - - _ _ - - - - _ - - - - . - - - - }

.J e ATTACHMENT 1 TEST PROGRAM FOR MOLDED-CASE CIRCUIT BREAKERS 1.0- Test Program Objectives The. objective of this proposed test program is to verify the performance of molded-case circuit breakers (CBs) that were procured as commercial grade (non-class 1E) and later upgraded to safety grade (class 1E), or that were procured as safety grade in a manner described in Bulletin No.

88-XX such as to bring into question their safety grade classification.

All such CBs that are installed in class 1E systems should be tested-in accordance with this program. Also, all such CBs that are in storage should be tested in accordance with this program before they are installed in class 1E systems.

The purpose of the proposed tests is to provide a reasonable assurance that the tested CBs are suitable for the intended service. A minimum of one-half (1/2) of such CBs but not less than 50 CBs (pro-rated) should be tested every refueling outage until all CBs have been tested as outlined

.in this program.

For the safety of personnel and others involved with the activities re-lated to these proposed tests, appropriate safety practices (such as ANSI /NFPA 70E, Part II) should be followed.

The below listed tests proposed for the CBs have been based on tests described in industry standards, such as NEMA AB-1 (Molded Case Circuit Breakers), NEMA AB-2 (Procedures for Field Inspection and Performance Verification of Molded Case Circuit Breakers Used in Commercial and Industrial Applications), and UL 489 (Molded Case Circuit Breakers and CircuitBreakerEnclosures).

l L - ____- ____

2.0 Test Procedures for CBs' The following tests should be performed in the order of sequence listed.

2.1 Mechanical Test

'The CB should be tripped, reset and closed a minimum of five times to insure that the latching surfaces are free of any binding.

2.2 Time-Overcurrent Trip Test 2.2.1 Rated Current Hold-In Test This test should be conducted at 100% rated current and at an ambient air temperature of 40 c 3*c, or at 135% rated current and at an ambient temperature of 25*c 3 c.

Equal current should be applied to all poles of the CB; and CB must not trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for CBs rated 50 amperes or below and within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for CBs rated over 50 amperes.

2.2.2 Overload test This test consists of 1 operating cycle (i.e., closing action followed by an opening action) of the CB at 600% rated current. There shall be no alectrical or mechanical bteakdown of the CB during this test.

2.2.3 Time Delay Overcurrent Trip This test should be conducted at an ambient air temperature of 25 degrees c 3* degrees c.

'I 4

A current of 300 percent of~the marked rating should'be applied to each' pole of the CB. The trip time for each pole should be com-pared against..the time shown in,the CB manufacturer's. time-current curves. If the test trip times obtained for each pole are not with-in the time band shown on the CB manufacturer.'s. time-current curves, then the test trip must not. exceed the time specified.in table 1 and the accept'ance of CB evaluated with the criteria'as listed below:

TABLE 1 VALUES FOR OVERCURRENT TRIP TEST (AT 300% OF RATED CONTINUOUS CURRENT OF CIRCUIT BREAKER)

(REF. NEMA AB-2)

Breaker Range of Rated Voltage Continuous Current . Maximum Trip Time Volts Amperes In Seconds 240 15-45 50 240 50-100 70 600 15-45 70 600 50-100 125 240 110-225 200 240 250-400 300 600 110-225 250 600 250-400 300 600 450-600 350 600 700-1200 500 600 1400-2500 600 600 3000-5000 ,

650 Minimum trip times: If the minimum tripping kimes are lower than indi-cated by the manufacturer's time-current curve [ for the breaker under test, the breaker should be retested after it hhs been cooled to 25*C.

If the values obtained are still lower after retest, the coordination ,

with upstream and downstream breakers should be evaluated. If no ris-coordination is indicated, then the CB is acceptable.

1 1

l l

Maximum tripping time: If the tripping time exceeds the maximum tripping time shown on the manufacturer's time-current curves but is below the time shown in table 1 above, check the breaker time against the. protection re-quirements of the circuit (such as cable, penetration, etc.) to ensure that the CB provides the protection, as well as the coordination with up-stream and downstream CBs. If the CB provides the necessary protection and coordination, then the CB is acceptable.

Maximum allowable time: If the tripping time of the CB exceeds the trip time shown in the table 1 above, the breaker is unacceptable for class 1E applications.

2.3 Instantaneous Trip Test l

2.3.1 Fixed Instantaneous Setting CBs 'l Each pole of the CB should be tested for pickup of the instan-taneous unit. The average of the three readings for each pole must be between 80% and 120% of the instantaneous trip setting as shown on the manufacturer time-current curves. The trip time should not exceed .05 seconds (3 cycles).

- 2.3.2 Adjustable Instantaneous Setting CBs Same as 2.3.1 except that each pole must be tested at the lowest and highest setting.

The average trip value for the lowest setting should be between 75 percent and 125 percent, and the highest setting should be between 80 percent and 120 percent of the setting value shown on the manufacturer's time-current curves.

\

, _ ___ -y _ - _ _ - - - - - - - - - - - - - - - - _ - - _ _ - _ _ _ - - _ - _ _ _ _ - - - - - - . _ . - - - _ - - - - - - - - _ - - - - - - - --

1 2.3.3 Short-time trip setting test This test is applicable only if the CB is equipped with the short-time delay trip. This test should be conducted at an ambient air temperature of 25'c 3*c. The operation of the short-time delay unit should be within 90% and 125% of the~overcurrent' setting of j i

the CB as shown on the manufacturer's time-current curves, 2.4 Individual Pole Resistance Test The contact resistance of each pole of:the CB should be measured'at ambient temperature. The average of 3 readings for each pole should be calculated and compared with the manufacturer's data or with those of similar CBs of the same manufacturer. Also, the average reading of -

each pole should be compared with each other and the difference between the pole readings should not exceed fifty percent.

2.5 Dielectric Tests The dielectric test should be conducted at an ac test voltage of 1760 volts (0.8' x [2 x Rated Voltage + 1000 volts]), or 2500 volts DC for 1 minute withstand. The dielectric test should be conducted for (1) line to load terminals with CB open, (2) line to line terminals with CB closed, and (3) pole to ground with CB open and closed.

h-_--__.m__._____.-_ _ - - - _ _ _ _ . _ _ _ . _ - _

ATTACHMENT 2 DEFINITION OF TERMS

1. ORIGINAL' EQUIPMENT MANUFACTURER (0EM):

The manufacturing facility which actually produced the equipment being purchased.

2. VERIFIABLE TRACEABILITY:

Documented evidence such as certificate of compliance that establishes traceability of purchased equipment to the OEM. If the certificate of compliance is provided by any party other than the OEM, the validity of such certificate must be verified by the purchaser through an audit or other appropriate means.

3. DEDICATION PROCESS: ,

The process by which commercial grade (non-Class 1E) equipment is upgraded to safety-grade (Class 1E) and is thereby considered qualified for use in nuclear safety related applications. The dedication process must include:

a) A technical evaluation to determine the characteristics critical (

I to fulfilling the safety function (s) and b) An acceptance process to assure that those critical characteristics are met.

l

11/3/BB DW SELB N

NUCLEAR UNITED REACTOR STATESREGULATORY C D.C. 20555 OFFICE OF NUCLEARWASHINGTON E NOVEMBER XX,1988 nuclear power for construction permits Addressees: or licenses of operating All holders reactors. ke actions to request that addressees ding CBs ta used with mo P1rpgspi to original plant stored of this bulletin breakers is (CBs) includ as The purpose ase circuit s replacements or forare being na iters orig-assure that have which molded been c installed d during modifications, such a as IEEE,Underwrion controllers requirements ce-equipment,installecomply design Manufacturers of requested actions scope with Associat planttional Electr spares without verifiable tra Laboratory (UL),were Naprocured specifications. Thefrom safety any BM)1 as grade butsource original ker tManufacturer were procured asother than(C the inal1 tomanuf to acturer'smolded the original circuit breasafety CBM from a source case grade, a source CBM or fromI for safetyCB other or tha ability h dedicated upgraded totraceability to t e and later

' without verifiable safety related frombility to manufacturer.

Items procured asith scope verifiable traceafr excluded than the CBM are but w related applications furbished t of Defective Re July 21, 1 h umstances:88 46, " Licensee ReporSup Information " dated Notice No. July 8, 1988 and its NRC Breakers, of Terms Circuit for Definition attachment 2 1

refer to

}

11/3/88.~

' DRAFT SELB' UNITED STATES NUCLEAR REGU'_ATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON D.C. 20555 1

)

i NOVEMBER XX, 1988 )

l Addressees:

All holders of operating licenses or construction permits for nuclear power I reactors. j

Purpose:

The purpose of this bulletin is to request that addressees take actions to assure that molded case circuit breakers (CBs) including CBs used with motor controllers which have been installed as replacements for original plant equipment, installed during modifications, or are being maintained as stored

. spares comply with plant design requirements such as IEEE, Underwriter s Laboratory (UL), National Electrical Manufacturers Association (hD4A) or orig-inal manufacturer's. specifications. The scope of requested actions is limited to molded case CBs that were procured from any source without verifiable trace-ability to l the original circuit breaker Manufacturer (CBM)1 as comercial grade and later upgraded to safety grade, or that were procured as safety grade but without verifiable traceability to the CBM from a source other than the original manufacturer. Items procured as safety related from CBM or from a source other l

than the CBM but with verifiable traceability to CBM and dedicated for safety related applications are excluded from the scope of this Bulletin.

Description of Circumstances:

i NRC Information Notice No. 88-46, " Licensee Report of Defective Refurbished Circuit Breakers," dated July 8, 1988 and its Supplement 1, dated July 21, 1988, l

1. refer to attachment 2 for Definition of Terms

1

. \

11/3/88 DRAFT SELB I

discussed a report by Pacific Gas and Electric which indicated that the Diablo Canyon Nuclear Power Plant had been supplied 30 CBs by Anti-Theft Systems, Inc.

through a local electrical distributor. These CBs (Square 0 molded case, type i KHL 36125) were intended for use in non-safety-grade applications at the Diablo Canyon Nuclear Power Plant. Square D Company reported that the inspection and testing of these breakers determined that the CBs were refurbished Square D Company equipment. Further, Square D reported that many of the circuit breakers tested did not comply with Square D or UL specifications for all of the elec-trical tests performed. Information Notice No. 88-46 also listed several California companies that were involved in supplying surplus and possibly defective refurbished electrical equipment to the nuclear industry.

During an NRC inspection of NSSS Inc., Jackson, Mississippi in August 1988, it was determined that NSSS, Inc., had sold several hundred CBs to Niagara Mohawk for use at the Nine Mile Point Unit 2 site. These CBs were obtained from several of the California companies referenced above. A high percentage of these CBs failed calibration and/or dielectric tests.

An NRC inspection at Spectrum Technologies USA, Inc. (ST), Schenectady, NY identified that ST had supplied several hundred CBs to Philadelphia Electric

, Company after upgrading them for safety related service. These CBs were pro-cured through a distributor (WESCO) and could not be traced to the CBM. Several CB's were rejected by ST as a result of deficiencies identified during receiving inspection /upgradv>g. These deficiencies (incorrect amp ratings on breaker handle, incorrect markings) were of the type indicating that the breakers may have been refurbished.

These examples indicate a potential safety concern regarding electrical equip-ment supplied to nuclear power plants. The NRC is concerned that the equipment procured as being new and assumed to meet all applicable plant design

11/3/88 I

' DRAFT SELB requirements and/or' original manufacturer's specifications may, in fact, not conform to these requirements and specifications.

The actions requested in this bulletin are only related to molded case CBs due to their widespread use and applications and the potential impact of their failure. Molded case CBs are tested and calibrated at the manufacturer's plant in accordance with recognized industry standards (UL-489-Molded Case Circuit Breakers and Circuit Breaker Enclosures and NEMA-AB1-Molded-Case Circuit Breakers). Since molded case CBs have factory-calibrated and sealed elements, any unauthorized modification or refurbishing of the CBs could jeopardize their capability and reliability, as well as invalidate the manufacturer's warranty.

Therefore, reliable operation of refurbished molded case CBs installed in nuclear i power plants needs to be verified due to lack of assurance of uniformity of parts. l materials and workmanship used in unauthorized refurbishing activities.

The NRC is concerned about refurbished CBs purchased as commercial grade (non- l Class IE) for later upgrading to safety-grade (Class 1E) applications, because these CBs may not meet the minimum commercial grade standards. In addition, the NRC is concerned about commercial grade breakers that are upgraded to safety-grade

~ because of observed inadequacies in the dedication process and the significant number of failures found during testing of these breakers. In order to dedicate electrical items procured as commercial grade and subsequently used in safety-grade systems, the dedication process should build from the commercial grade quality, and include proper evaluation of seismic and environmental qualification, as well as confirmation of critical operating parameters and functional testing as appropriate.

When CBs are upgraded to safety-grade applications, the NRC is concerned that the observed dedication process as currently used by licensees and others may not be adequate for properly evaluating the acceptability of the components for safety-grade service.

11/3/88 DRAFT SELB The safety-grade electrical equipment purchased as Class 1E from the CBM or a corporate division associated with the CBM is of lesser concern, since this equipment is controlled under quality assurance (QA) programs which conform with Appendix B of 10 CFR 50. The controls imposed by these QA programs are more stringent than the controls exercised in procurement of commercial grade equipment. While the upgrading programs of CBM or a corporate division associated with the CBM may vary in quality, the controls exercised over the procurement and manufacturing provide reasonable assurance that improperly refurbished components have not been introduced and passed through the upgrading process. Further, the redundancy of safety systems and the in-service use of these components provide a reasonable basis for accepting installed replacement componentsk.hathavebeenprocuredassafetygradefromtheCBMorfrom.a corporate division associated with the CBM.

The NRC believes that the actions described in this bulletin need not extend to the electrical equipment (Class 1E and non-Class 1E) originally installed, at this time. This equipment appears to have been procured during plant construction from original manufacturers with full certification. The large quantities of electrical assemblies or components procured under bid packages minimizes the

, possibility of vendors doing refurbishing having supplied original equipment.

The NRC expects that all addressees will participate sin a joint industry program for non-safety-grade molded case CBs which have been installed as replacements for plant equipment, installed during modifications' or are being maintained as stored spares, that were not procured from the origfnal breaker manufacturers or whose original source has not been determined, to assure that they are suitable for the intended service. A joint industry report describing the program is expected within 180 days of receipt of this bulletin.

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11/3/88 DRAFT SELB l u

The actions requested in this bulletin apply only to all molded case CBs being maintained as stored spares or procured within the last five years from the date of this bulletin for replacement for plant equipment or for plant modifications, as indicated in action items below. However, the NRC investigation of this issue is not complete. A supplement to the bulletin may be issued to include other electrical equipment or a longer review period for procurement if warranted by the results of the ongoing evaluation or the results of testing called for by this bulletin.

Actions Requested

1. All addressees are requested to review their records of purchases to identify the total number, manufacturer and model of molded-case CBs which are being maintained as stored spares for safety-related applica-tions or commercial grade CBs maintained as stored spares for future dedication to safety-related application. If the number of stored spares CBs is "less than 50 per nuclear unit, then records of purchases for additional CBs may be included from CBs purchased within the last five years and which have been installed as replacements or modifica-tions to make a minimum sample of 50.

2. Verify the traceability of the CBs identified in item 1 for those that were:

a. procured from any source as commercial grade without verifiable traceability to CBM and later upgraded for safety related application or .

b. procured as safety related from any source other than CBM without verifiable traceability to CBM.

i 11/3/88 SELB DRAFT l

If 90 percent or more CBs are traceable to the CBM, continue with action l item 3 otherwise proceed to action item 4.

l This review should be completed by March 1,1989.

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3. All addressees that identify 90 percent or more CBs traceable to the CBM are requested.to test those CBs that are not traceable to the CBM in accordance with the test program described in attachment 1. If more than 20 percent of CBs tested fail any of the tests described in attachment 1, continue with action item 4 otherwise proceed to action item 6. The testing program should be completed prior to startup after the first refueling outage after March 1,1989 (For cps, the testing program should be completed prior to fuel load).

4. All addressees that identify less than 90 percent traceability of CBs to the CBM per action item 2 or identify more than 20 percent failure rate of CBs tested per action item 3 are requested to review their records of purchases for the last 5 years from the date of this bulletin to identify the number, manufacturer, model and applications of CBs which have been installed as replacements or installed during modifications. Verify trace-ability of these CBs in accordance with action item %, (a) and (b).

5. All holders of operating licenses that identify installed CBs per item 4 above are requested to replace these CBs with qualified components, or to test 2 (and replace failed components) in accordance with the test >

2. The Underwriters Laboratory and National Electrical Testing Association have stated to the NRC that the test option should be primarily used for cases where replacement breakers are not available and should not be used j in an application where replacement CBs are readily available or an untested l parameter (such as fault clearing capability) could by itself prevent accom- j' plishment of the safety function.

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11/3/88 ,

SELB DRAFT program described in Attachment 1. The replacement or the tesc program, whichever'is selected, should be completed prior to startup after the second refueling' outage after March 1, 1989 with one-half but no less than a total of 50 of the identified CBs replaced or tested at each re-fueling shutdown af ter March 1989 (for all holders of cps, the CB re-placement or testing should be completed prior to fuel load).

6. Within 30 days of completion of action item 2, but no later than April 1, 1989, prepare a JC0 for the period during which all action items will have been completed.

7. Information generated during the completion of items 1,2,3,4,5 and 6 above shall be documented and maintained for possible NRC audit.

8. Molded case CBs installed after the date of this Bulletin in safety related applications 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, meeting applicable industry standards and upgraded to Class 1E by the licensee or others using an acceptable dedication program.

Tests equivalent to those of Attachment I are acceptable for a dedi-cation process of CBs traceable to the CBM. Seismic or environmental qualification requirements are addressed by additional testing or analysis based on plant-specific considerations.

11/3/88 DRAFT SELB-Reporting Requirements:

1.- All holders of operating licenses are required by April 1,1989 to provide a written report that:

a. confirms that no molded case CBs are being maintained as stored spares for safety-related applications or commercial CBs being maintained aC stored spares for future dedication for safety-related applications as described in action item 1, or for-wards the results' of the information described in action items 1 and 4.

b. -confirms that the actions requested in action items 2,3,4,5 and 6 have been completed, or confirms that the schedule will be adhered to.

c. confirms action item 8 will be followed.

d. reports the final results of and all conclusions of tests conducted in response to items 3 and 5 above in accordance with attachment 1 within 30 days of such tests.

2. All holders of construction permits are required by April 1,1989 to provide a written report that:

a. confirms that no molded case CBs are being maintained as stored spares for safety-related applications or commercial CBs being maintained as stored spares for future dedication for safety-related applications as described in action item 1, or forwards the results of the information described in action items 1 and 4. q

11/3/88 DRAFT

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b. confirms that the actions requested in action items 2,3,4,5 and 6 will be completed prior to fuel load.

c. confirms action item 8 will be followed,

d. reports the final results and conclusions of tests conducted in response to items 3 and 5 above in accordance with attachment I within 30 days of such tests The written reports required above shall be addressed to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, under oath or affirmation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended. In addition, a copy shc11 be submitted to the appropriate Regional Administrator.

This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated burden hour is 1000 and 10,000 man-hours per plant response, including assessment of these require-ments, searching data sources, testing, and analyzing the data, and preparing

. the required reports. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget.

Room 3208, New Executive Office Building, Washington, D.C., 20503, and to the U.S. Nuclear Regulatory Commission, Records and Reports Management Franch, Office of Administration and Resource Management, Washington, D.C., 20555.

Charles E. Rossi, Director Division of Operatonal Events Assessment Office of Nuclear Reactor Regulation

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11/3/88-SELB DRAFT Technical Contacts: Paul Gill, NRR (301) 492-0811 Jaime Guillen, NRR (301) 492-1170 l

Attachments: 1.- Test program for Molded Case Circuit Breakers and Motor Controllers

2. Definitions of. Terms

3. List'of Recently Issued NRC Bulletins 9 O k

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ATTACHMENT 1 TEST PROGRAM FOR M0LDED-CASE CIRCUIT BREAKERS 1.0 Test Program Objectives The objective of this proposed test program is to verify the performance of molded-case circuit breakers (CBs) that were procured as commercial grade (non-class 1E) and later upgraded to safety grade (class IE), or that were procured as safety grade in a manner described in Bulletin No.

88-XX such as to bring into question their safety grade classification.

All such CBs that are installed in class 1E systems should be tested in accordance with this program. Also, all such CBs that are in storage should be tested in accordance with this program before they are installed in class IE systems.

T_he purpose of the proposed tests is to provide a reasonable assurance that the tested CBs are suitable for the intended service. A minimum of one-half (1/2) of such CBs but not less than 50 CBs (pro-rated) should be tested every refueling outage until all CBs have been tested as outlined in this program.

For the safety of personnel and others involved with the activities re-lated to these proposed tests, appropriate safety practices (such as

-- ANSI /NFPA 70E, Part II) should be followed.

The below listed tests proposed for the CBs have been based on tests described in industry standards, such as NEMA AB-1 (Molded Case Circuit Breakers), NEMA AB-2 (Procedures for Field Inspection and Performance Verification of Molded Case Circuit Breakers Used in Commercial and l Industrial Applications), UL 489 (Molded Case Circuit Breakers and Circuit Breaker Enclosures), and NETA STD ATS-1987 (National Electrical l- Testing Association. Acceptance Testing specifications).

2.0 Test Procedures for CBs The following tests should be performed in the order of sequence listed.

Breakers failing any of these tests should be considered unacceptable for class IE service.

2.1 Mechanical Test 1

The CB should be operated, reset and closed a minimum of five times to insure that the latching surfaces are free of any binding.

2.2 Individual Pole Resistance or Milivolt Drop Test (Ref. NETA STD ATS-1987 & NEMA AB-2)

'The contact resistance of each pole of the CB should be measured at ambient temperature. Three readings of each pole should be taken with breaker operated without load between each reading. The average of 3 readings for each pole should be calculated and compared with the manu-facturer's contact resistance data or with those values of similar CBs of the same manufacturer. Also, the average value for each pole should be compared with the average of the other poles and the difference between the pole values should not exceed fifty percent of the lowest value, or The milivolt drop test may be performed by applying a direct-current across the closed circuit breaker contacts and measuring the voltage drop due to the contact resistance. The milivolt drop test should be performed at room temperature. Direct-current should be applied across each pole and milivolt drop and test current recorded for each pole.

Three readings of each pole should be taken with breaker operated with-out load between each reading. The average of three readings for each i pole should be calculated and compared with the manufacture's value for acceptance of the breaker.

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2.3 Rated Current Hold-In Test (Ref. NEMA AB-1 & UL 489)

This test should be conducted at 100% rated current and at an ambient air temperature of 25*c 3'c, and followed by a test.

-at 135% rated current and at an ambient temperature of 25'c 3'c.

Equal 100% rated currents should be applied to all poles of the CB.

The CB must not trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for CBs rated 50 amperes or below, and within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for CBs rated over 50 amperes. At the end of the time'specified for the 100% rated current test,.the current should be' increased to 135% and tripping should occur within the times stated above.

2.4 Overload test (Ref. NEMA AB-1 & UL 489)

This test consists of 1 operating cycle (i.e., closing action followed by an opening action) of the CB at 600% rated current. This test should be conducted at low voltage. There shall be no electrical or mechanical breakdown of the CB during this test. '

2.5 Instantaneous Trip Test (Ref. NEMA AB-1 & UL 489) 2.5.1 Fixed Instantaneous Setting CBs (Ref. NEMA AAB-1 & UL-489)

Each pole of the CB should be tested for pickup of the instan-taneous unit. Each pole must be between 75% and 125% of the instantaneous trip rating. The trip time should not exceed 0.1 seconds (6 cycles).

2.5.2 Adjustable Instantaneous Setting CBs (Ref. NEMA AB-1 & UL-489)

Same as 2.3.1 except that each pole must be tested at the lowest and highest setting.

The average trip value for the lowest setting should be between 75 percent and 125 percent of the lowest setting, and the highest

- setting should be between 80 percent and 120 percent of the highest setting.

2.5.3 Short-time trip setting test (Ref. NEMA AB-1 & UL 489)

This test is applicable only if the CB is equipped with the short-time delay trip. This test should be conducted at an ambient air '

temperature of 25 c 3 c. The operation of the short-time delay unit should be within 90% and'125% of the overcurrent setting of the CB..

2.6 Time Delay Overcurrent Trip (Ref. NEMA AB-2)

This test should be conducted at an ambient air temperature of 25 degrees c 3" degrees c.

A current of 300 percent (at low voltage) of the marked rating should be applied to each pole of the CB. The trip time for each pole should be compared against the time shown in the CB manu-facturer's time-current curves. If the test trip times obtained for each pole are not within the time band shown on the CB manufacturer's time-current curves, then the test trip must not exceed the time specified in table 1 and the acceptance of CB evaluated with the criteria as listed below:

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l TABLE 1 VALUES FOR OVERCURRENT TRIP TEST (AT 300% OF RATED CONTINUOUS CURRENT OF CIRCUIT BREAKER)

(REF. NEMA AB-2) l Breaker Range of. Rated Voltage Continuous Current Maximum Trip Time Volts Amperes In Seconds 240 15-45 50 240 50-100 70 600 15-45 70 600 50-100 125 240 110-225 200 240 250-400 300 600- 110-225 250 600 250-400 300 600 450-600 350 600 700-1200 500 600 1400-2500 600 600 3000-5000 650 Minimum trip times: If the minimum tripping times are lower than indi-cated by the manufacturer's time-current curves for the breaker under test, the breaker should be retested after it has been cooled to 25'C.

If the values obtained are still lower after retest, the coordination with upstream and downstream breakers should be evaluated. If no ais-coordination is indicated, then the CB is acceptable.

Maximum tripping time: If the tripping time exceeds the maximum tripping time shown on the manufacturer's time-current curves but is below the time shown in table 1 above, check the breaker time against the protection re-quirements of the circuit (such as cable, penetration, etc.) to ensure that the CB provides the protection, as well as the coordination with up-stream and downstream CBs. If the CB provides the necessary protection and coordination, then the CB is acceptable.

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TABLE 1 '

VALUES FOR OVERCURRENT TRIP TEST-(AT 300% OF RATED CONTINUOUS CURRENT OF CIRCUIT BREAKER)-

(REF. NEMA AB-2)

Breaker- Range of Rated Voltage Continuous Current Maximum' Trip Time Volts ' Amperes In Seconds 240 15-45 50 240 50-100 70 600 15-45 70 600 '50-100 125 240 110-225 200 240 250-400 300 600 110-225 250 600 250-400- 300 600 450-600 350 600 700-1200 500 600 1400-2500 600 600 3000-5000 650 Minimum trip times: If the minimum tripping times are lower than indi-cated by the manufacturer's time-current curves for the breaker under test, the- breaker should be retested after it has been cooled to 25'C.

If the values obtained are still lower after retest, the coordination with upstream and downstream breakers should be evaluated. If no mis-coordination ic indicated, then the CB is acceptable.

l Maximum tripping time: If the telpping time exceeds the maximum tripping time shown on the manufacturer's time-current curves but is below the time shown in table 1 above, check the breaker time against the protection re-quirementsofthecircuit(suchascable, penetration,etc.)toensure that the CB provides the protection, as well as the coordination with up-stream and downstream CBs. If the CB provides the necessary protection and coordination, then the CB is acceptable.

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. Maximum allowable tine: [If the tripping time of the CB exceeds. the trip:

. time shown in the' table 1 above, the breaker is unacceptable for class 1E. '

applications. ,

2.7 Dielectric Tests (Ref. NEMA AB-1 & UL-489)

The dielectric test should be coeducted at an'ac test voltage of 1760 volts (0.8x[2xRatedVoltage+1000 volts]),orat2500voltsDC ifor 1 minute withstand. The dielectric test should be conducted for ]

(1) line to load terminals with CB open, (2) line to line terminals with CB closed, and (3) pole to ground with CB cpen and closed. l

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ATTACHMENT 2 DEFINITION OF TF M -

1. CIRCUIT BREAKER MANUFACTURER (CBM):

The manufacturing facility which actually produced the circuit breaker being purchased. 4

2. VERIFIABLE TRACEABILITY:

Documented evidence such as certificate of compliance that establishes traceability of purchased equipment to the OEM. If the certificate of compliance is provided by any party other than the OEM, the validity of such certificate must be verified by the purchaser through an audit or other appropriate means.

3. DEDICATION PROCESS:

l The process by which commercial grade (non-Class IE) equipment is upgraded to safety-grade (Class IE) and is thereby considered qualified for use in '

nuclear safety related applications. The dedication process must include:

a) A technical evaluation to determine the characteristics critical to fulfilling the safety function (s) and b) An acceptance process to assure that those critical characteristics are met.

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UNITED STATES NUCLEAR REGULATORY ComIS$10N OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 i

November xx, 1988 g, i.

WRC Bulletin No. 88-xx: NONCONFORMING MOLDED-CASE CIRCUIT BREAKERS

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Addressees:

All holders of operadng licenses or construction permits for nuclear power reactors.

Purpose:

The purpose of this bulletin is to recuest that address CBs used with motor controllers purchased for use in safety grade i 8N) without verifiable traceability to the circuit breaker manu acturer perform their safety functions. I Description of Circumstances- !

NRC Information Notice No. 88-46, " Licensee Report *of Defective Refurbished Circuit Breakers," dated Jul) 8,1988 and Supplement 1 thereto, dated July 21, 1988, discussed a report by Pacific Gas and Electric Company that indicated that its Diablo Canyon Nuclear Power Plant was supplied 30$quare These C8s CBs by(Anti-Theft D

Systems. Inc. through a local ' electrical distributor.

molded-case, type KHL 36125) were intended for use D Square inCompany non-safety-grade reported app 11-cations at the Diablo Canyon Nuclear Power Plant.that an inspectio Furthermore, Square D reported that refurbished Square D Company equipment.

~ several of the circuit breakers tested did not comply with Square D or Under-

. writers Laboratories, Inc. (UL) specif1' cations for all of the electrical tests performed. Information Notice No. 88f46 also listed several California com-

. panies that were involved in supplyirig ' surplus refurbished and possibly defective refurbished electrical equipment to the nuclear industry.

During recent NRC inspections, additional examples were identified that '

indicate a potential safety concern regardi,ng electrical equipment to nuclear power plants.

as new and assumed to meet all applicable plant design requirements and/or original manufacturer's' specifications may, in fact, not conform. to these requirements and specifications.

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1. Refer to Attachment 2 for Definition.of Terms .

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Pag Teof" ~

The actions requested in this bulletin are limited to molded-case C8s. Mo16d-case .CBs are Jested and calibrated at the manufacturer's plant in accordance with recofjnized industry standards, such as UL-489. " Molded Case Circuit Breakers -

and Circutt Breaker Enclosures." and National Electrical Since molded-case ManufacturerI C8s have ation (NEMA)-AB1. " Molded-Case Circuitunauthorized Breakers." modification or re-factor -calibrated and sealed elements, agair design capability and reliability.

i furbis ing of these CBs could jeopardize The NRC is concerned that the reliability and capabilities of refurbished CBs purchased as comercial grade (non-Class 1E) for later upgrading to safety-grade standards.

(Class 1E) applications may not meet the minimum come capabilities of comercial grade on breakers upriraded process and numerous In order to failures to safety properly found during the testing of some of these breakers. )

dedicate electrical items procured as comercial grade for subsequent use !

in safety-grade applications, the dedication process should mental qualification, confim critical parameters, and include testing as j appropriate.

Safety-gr e electrical equipment l purchased as Class /1E f

'the CBN neern this or /-

corporat divisions sesociated ality (th the CB . is of esser ass ance (QA progr ms tha confo '

equipme is contro The co trols im% ed by these Qams prog /rm ins to Appe ixBofI}iedunderCFR Part 5 . fal g aremorestringen than thos exercised Irams n the swiufactu ing of CBMs. r corpo ate visions I gradejequipment. While the pgrading j y vary in va ity. he con is exe cised over the

/

assofiatedvith procurement he an CBMs.

manufactur ng activi es provi e uced reasoandable as ranc that n intro passe through imfroperly re rbished c ponents urthennoh, ethe notre ndancy f safety sys and the e upgradin process. cepting reason le basi for grade fro u) n-service e of thes component provide ured as afe nstalled r placement omponents hat have een p ,

the CBM o from co , rate divis ons associated wi h the C The NRC currently believes that the concerns ' addressed in this bulletin do not apply to electrical equipment (safety, grade and comercial gra installed in plants. The large quantities of construction from CBMs with full certification. electrical assemblies o construction reduce the possibility of any priginal plant equipment being supplied by vendors doing refurbishing.

participa in a jo t indus progr a t 'at The MR xpects al addressees

s. which y have n in all ensure that non. fety-grade ided-case int,a ed a t as re; acements, nstalled du ng modific tons, or M. re bein sesor inal or hW stor $ spares a that were et procure from the ry sou e has not een determ ed. are su able for heir int ded st ice,ys A./

y re int indus thisgortd cribing th program i expecte withly180 A

of receipt o ullet n. .

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Insert 1 Molded-case CBs purchased from the CBM or that can be traced to the'CBM are of lesser concern than other molded-case CBs because circuit breakers'from the CBM, whether safety grade or commercial grade, are manufactured under controlled conditions to conform to a proven design. Safety grade CBs purchased as Class 1E from the CBM are controlled under qus11ty assurance (QA) programs that conform to Appendix B of 10 CFR Part 50. While upgrading programs may vary in quality, the controls exercised by the CBM over the manufacturing activities-provide reasonable assurance that improperly refurbished components have not been introduced and passed through the upgrading process. Furthennore, the redundancy of safety systems and the in-service use of CBs provide a reasonable I basis for accepting installed replacement CBs that have been procured from the j

CBM or that can be traced to the CBM.

l Insert 2 ,

Although the actions requested in this bulletin do not apply to non-safety grade molded-case CBs, the NRC intends to monitor industry programs to ensure that non-safety-grade molded-case CBs, which may have been installed as

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replacements, installed during modifications, or are being maintained as stored spares, are suitable for their intended service. Utilities are encouraged to participate in a joint program. If industry programs are either not timely or not sufficient, additional regulatory actions will be taken, as appropriate. '

gM g Addition to Address OGC Coments l

The non-destructive testing, in conjunction with the other actions requested by this bulletin, will provide reasonable assurance of adequate protection of public health and safety.

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The NRC requested and received coments from the Nuclear Management and Resources {

ation (NDE), and Council (NUMARC), the National Electrical Manufacturers Assoc <

the Underwriters Laboratories. Inc. (UL), during the preparation of this bulletin.

These coments were considered and some were appropriately incorporated t. into this bulletin. .

4 NEMA has comented to the NRC that determination of the critical performance characteristics of durability and short-circuit capabilities of circuit breakers requires destructive testing of selected Becausebreakers that breaker a refurbished are representative may not have of breakers to be placed in service. ~

been refurbished under controlled conditions to confom to a proven design, destructively testing selected breakers will not infer anything about ,

i furbished breaker. In addition, they stated that, "it is UL's opinion that the of this bulletin.

test program is not adequate to provide assurance that theThe tested, non-traceable, NRC agrees ,

circuit breakers would be suitable for their intended purpose."The non-de

. with these coments. ,

bulletin, however, is directed at ensuring that the circuit breakers will l perform those functions most important to ensuring reacto l can only be verified by destructive testing rwscA ~5 A supplement to this f The NRC investigation of this issue is not complete. ment or a longer pro- I bulletin may be issued to include other electrical equi curement review period if warranted by the results of tie ongoing evaluations l

. j or the results of testing requested in this bulletin.

Actions Requested:

1. . All addressees are requested to perfom the following review by March 1,1989:

a. Identify all molded-casa CBs purchased prior to August 1,1988, that are being maintained as stored spares for safety-grade (Class IE) applications or comercial grade CBs that are being maintained as stored spares for future use in safety-grade !

applications; this includes C8s purchased from a CBM or from l If the number of these stored spare CBs is '

' any other source.less than 50.at a nuclear p'lant site, then randomly select CBs purchased between August 1,1983 and August 1,1988 that have teen installed in safety-grade applications as replacements or ;

modifications to form a minimum sample of 50 CBs. I Verify the traceability of these CBs. den \ 4e4 m L Q.

b.

Identify the number, manufacturer, model n r, and to the extent c.

possible the procurement chain for all)CBs that cannot be,t l to the CBM. _- )

they are/were installed.

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November an. 1988 Page 4 of -

2. All holders of operating licenses who identify installed C8s per item 1 above that cannot be traced to a CBM are requested to prepare, within 30 days of the completion of item 1 above, an analysi g, have been completed. ..

3. All addressees who identify 80 percent or more CBs traceable to the C8M per item 1 above are requested to test the C8s that are not traceable toA the CBM in accordance with the test program described in Attachment 1.

installed C8s that fail any of these tests should be replaced with components 4 that meet the criteria of item 7 of the actions requested or that1. pass schment If all !

tests in accordance with the testing program described in Ati escribed in more than 10 percent of the CBs tested fail any of the tests 6 of the Attachment 1. continue with item 4; otherwise, proceed to 1 C_b actions requested.

Holders of operating licenses are requested to comple Holders of construction permits are requested to complete this testing program before fuel load.

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 th following actions: ,

a. Identify.all molded-case CBs that have been purchased between August 1 1983 and August 1.1988, and installed in safety-grade 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 th nnot be traced to the C8M.

' fer all those CBs kat idenca%e6 W b a..

5. All addressees who identify instalfed CBs that cannot be traced to the C J meet the criteria of item 7 of Me actions requested or accordance with the program described in Attachment 1; CBs that fail anythi '

of these tests should be replaced with components,11 tests in accordance of item 7 of the actions requested or that pass a with the test program described in Attachment 1. ( C %

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November xx,1988 Page 5 of t .

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 i installed C8s before startup from the first refueling outage beginning after March 1, 1989. The remaining breakers should be replaced or tested before startup from the second refueling outage beginning after March 1, 198g.

Holders of construction permits are requested to replace or to test these installed breakers before fuel load.

5. Information generated while perfonning the actions requested in items 1, 2, 3,4, and 5 above should be documented and maintained for possible NRC audit for a period of 5 years after the completion of all requested actions.

7. With the exception of actions taken in response to items 3 and 5 of the actions requested above, molded-case C8s installed in safety-grade app 11- ;

' cations after August 1,1988 should be: .

l

a. Manufactured by and procured from a CBM under a 10 CFR 50 Appendix !

8, program; or ,

b. Procured from a CBM or others w1O verifiable traceability to the CBM, in conpliance with applicable industry standards, and upgraded i to safety-grade by the licensee or others using an acceptable dedi-cation program. Tests equivalent to those in Attachment 1 are acceptable for a dedication process of CBs traceable to the CSM.

In addition, seismic and environmental qualification requirements should be addressed by additional testing or analysis based on plant-specific considerations.

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.

Reporting Requirements:

1. All holders of operating licenses re required to provide a written

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report by April 1,1989, that: .,P::

Confirms that only molded-case

a. of the actions requested.are being CBs that meet the criteria of item 7 maintained as stored spares for future use in safety-grade applic~ations.

b. Summarizes the total number *, manufacturer, model number, and to the extent possible the procurement chain of those CBs that could not For be traced to the CBM in items 1 and 4 of the actions requested.

instaUed installed.

CBs, also identify each system in which they ar a

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. November Jute 1988

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by April 1. 1989, due to the schedule for tests in item 3 of the actions requested. this information should be updated within 30 dvs of the completion of item 4 to address those additional 3 C8s that could not a traced to the C8M. ..

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Confirms that items

1. 2. 3. 4. 5. 6 and 7 of the actions. requested

c. have been completed or will be implemented as requested.

2.

All holders of operating licenses are required to submit a report th somnar4assavailable 3 and 5 of the actions requested results withinof 30 tests daysconducted after startup infromaccordance the wit These first and second refueling outages beginning after March 1.1989.

reports should include the number, manufacturer, Formodel C8s that number, fail and to the extent possible the procurement chain of C8s tested. .

these test parameter test s)(s),(these at which they re' failed. ports should indicate the test (s

3. All holders of construction permits are required to provide a written report by April 1, 1989, that:

a. Confirms 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-grade applications.

b. Sumarizes the total number, manufacturer, model number, and to the extent possible the procurement chain of those C8s that could For not be traced to the CSM in items 1 and 4 of the actions requested.

installed installed.

CBs. also identify each system in which they are/w by April 1.1989, due to the schedule for tests in item 3 of the actions requested, this infonnation should be updated within 30 days of the completion of item 4 to address those additional C8s

~

that could not be traced to the'C8M.

c. Confirms that items 1. 3. 4. 6. 6 and 7 have been completed or will ,

l be taplemented before fuel .oad.

4. All holders of construction permits are required to submit a report that summarizes the results of tests ' conducted in'accordance with items 3 and of the actions requested within 30 days after fuel load.

include the number, manufa'cturer, and model number of all breakers tested.

For C8s that fail these test (s),(the report should indicate th and the values of test parameter s) at which they failed.

The written reputs required above shall be addressed to the U. S. Nuclear Regulatory Comission. ATTN: Document Control Desk. Washington.sD.(. 2 under oath or affimation In under the provisions addition, a copy of be shall Section 182a.

submittef t6 Atomic the Energy Act of 1954, as amended.

appropriate Regional Administrator. ]

/

e

yy o o November xx 1988 Page 7 Gf This request is covered by Office of Management and Budget Clearance Nu 3150-0011 which expires December 31,1989.

] to 10,000 man-hours per plant n sponse, including assessment of these require-ments, searching data sources, testing, and analyzing the data, and preparing E Comments on the accuracy of tsis estimate and suggestions !

the required reports.to reduce the burden may beL.,C.,

Washington, directed 20503,to andtheto Office the of Managem l

Room 3208, Nsw Executive Office Building,ds and Reports Management Branch. Office U.S. Nuclear Regulatory Commission, Recor of Administration and Resource Management. Washington, D.C., 20555.

If you have any questions regarding this matter, please co MRC regional office.

DR9fT Charles E. Rossi, Director Division of'Optratonal Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: Paul Gill, NRR (301)492-0811 Jaime Guillen, MRR .

(301)492-1170 Attischments: .

1. Test Program for Molded Case Circuit Breakers

2. Definition of Tems

3. List of Recently Issued MRC Bulletins R

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1 Power '

N o"p't' ember 2, 1988 3F0988-02 U. S. Nuclear-Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NRC Bulletin 88-05: Nonconforming Materials Supplied by Piping' Supplies, Inc.

at Folsom, New Jersey and West Jersey. l Manufacturing Company at Williamstown, New Jersey Dear Sir Florida Power Corporation hereby M information. in . response to the requires that all Piping Supplies, (FPC) provides subject IE Bulletin. the -The following Bulletin-Inc. (PSI) and West Jersey !

Manufacturing Co. (WJM) supplied material be identified and that a determination applications.

be made as to its suitability for the intended or actual FPC's record search indicated that the subject material was located in the storeroome . and also installed in the Nuclear Service and Decay Heat Seawater (RW) System. The storeroom material is in a " hold cage" until further notice from the NRC. An EQUOTIP portable hardness tester was used to established the ultimate strength of the installed material. The EQUOTIP hardness number obtained was then expressed in terms of a Brinell Hardness Number using the EQUOTIP conversion tables.

The lowest hardness value obtained to date is 115HB without the EPRI temperature correction factor.

fall within the acceptable range for ASTM A-105 This hardness material. value did not An analysis to justify continued operations was performed because of the substandard material, but did not require a report under 10 CFR 50.72. However, notification to the NRC Operations Center was made within 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months on the dates of July 13th and July 27th por Supplcmont 1 to Bulletin 88-05. The analysis demonstrated that the subject materials are suitable for the intended service.

6$ N$ Yf d

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GENERAL OFFICE: 3201 Mrty. fourth Street South

P.o. Box 14042

St. Petersburg, Florida 33733 * (813) 866 5151 A Florida Progress Company 1

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September 2, 1988

[ 3F0988-02

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( Page 2 Enclosed are material worksheets which list the PSI and WJM supplied materials that are found not to be in conformance with the applicable code requirements or procurement specifications.

Sincerely, Rolf C. Widell, Director Nuclear Operations Site Support RCW/GMF/adr Enclosures xc: Regional' Administrator, Region II

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senior Resident Inspector \

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STATE OF FI4RIDA COUNTY OF CITRUS Rolf C. Widell states that he'is the Director, Nuclear Operations Site Support for Florida Power Corporation; that he. is authorized on the part of said company to sign and file with the nuclear Regulatory Commission the information attached hereto; and that all such statements made the best of his and matters knowledge, set forth therein information, are true and correct to and belief.

Rolf C.[ Widell,\Director Nuclear Operations Site Support

~

O Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 2nd day of September,.1988.

b3 1$b 7 tary Public Notary Public, State of Florida at Large, My Commission Expires: June 21, 1991 0

.s-NRC 88-05

(* ~

MATERIALS WORKSEEET Plant CRYST- Unit 3-'

Line Item 1 Heat-Lot -CFY -ASME Class.3'-

Commodity FLG Diameter 2:00 Schedule 40 Rating 150 Type SW Spec 105 Grade N/A Source PSI Vender (WJM or PSI) P CMTR Date 9/30/87 NCA-3800 (Y/N) Y Secondary Supply Chain ....

Supplier Dubose Supplier Dubose Quantity 1 Quantity In Stock 0

-Installed-Access 1 Installed--Not. Access 0 TEST DATA, ERESRIrr Test .lesults For Line Item. 1 Specimen ID (Required) 1 Test Data CMTR Data Tensile Strength 84,725 Yield Strength 53,890 Percent Elongation 35.0 Percent Reduction In Area 67.8 Hardness (BHN) HB166 Not Specified Carbon .25 Manganese 1.35 Silicon .27 Phosphorous .010 Sulfur .039 Chromium N/A Nickel N/A l

Molybdenum N/A Heat Treatment N/A

_ ,- REMARKS 1. Test temp 85 - 105 F j

2. Temp. correction applied '

-_m -- -

NRC 88-05 f] . .

MATERIALS WORKSEEtt Plant CRYST Unit .3 Line Item 2 Heat-Lot 6027949 ASME Class 3 Conunodity FLC Diameter 24:00 Schedule N/A Rating 150 Type SO Spec 105 Grade N/A Source PSI Vendor (WJM or PSI) P CMTR Date 7/9/87 NCA-3800 (Y/N) Y Secondary Supply Chain .... , -!

Supplier Dubose supplier Dubose

' Quantity 2 Quantity In Stock 0 8

l

, Installed-Access 2 Installed--Not Access 0 TEST DATA WORKSHEET Test Results For Line Item 2 Sp'acimen ID (Required) 2 Test-Data CMTR Data-Tensile Strength 77,000 Yield Strength 46,700 Percent Elongation 34.0 Percent Reduction In Area 59.0 Hardness (BHN) HB142/HB144 N/A Carbon -

.27 Manganese .86 Silicon .20 Phosphorous .011 Sulfur .014 Chromium N/A Nickel N/A Holybdenum N/A Heat Treatment N/A

'r3 REMARKS 1. Test temp 85 - 101 F L) 2. Temp correction applied

<. e w co i esug7a t; .e5jrse 3e13Ae3 - woog

'R7v.iicd 7/26/88 Ph? IIRC 84-03 VV ..

MATERIALS Wonrmerer Plant CRYST Unit Line Item 3 Heat Lot CFY ASME Class 3 Cossmodity PLO Diameter 2:00 Senedule N/A Rating 150 Type So. Spee; 105 Grade N/A Source PSI

, Vendor (WJM or PSI) ? CMTR Date 10/13/87-NCA-3800 (Y/N) Y Secondary supply Chain ....

Supplier Dubose Supplier Dubose Quantity 8 Quntity In Stock 4 -1 Installed-Access 0 Installed--Not Access 0 TEST DATA WORESIIr!

Test Results Por Line Item 3 Specimen ID (Required) -3 Test Data ClffR Data l Tensile Strength 84,725 Yield Strength 53,890 Percent Elongation 35.0 Percent Reduction In Area 67.8 Bardness (BEN) Not Specified Carbon .25 Manganese 1.35 Silicon .27 Phosphorous .010 Sulfur .039 Chromium N/A Nickel N/A Molybdenus N/A l l Heat Treatment N/A REMARKS: 1. No testing conducted

2. 4 items unaccounted for

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) R3 vised-7/26/88

+

NRC 88-05 0 .

Plant CRYST-

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Unit 3 Line Item 4 Heat-Lot -CFY ASME Class N/A Conunodity FLG Diameter 2:00 Schedule N/A Rating 150 Type SO Spec 105 Grade N/A Source PSI Vendor (WJM or PSI) P CMTR Date 10/6/87 NCA-3800 (Y/N) y Secondary Supply Chain ....

Supplier Dubose Supplier Dubose Quantity 15 Quantity In Stock 0 Installed-Access 15 Installed--Not Access 0

~

TEST DATA WRESHERT Test Results For Line Item 4 Specimen ID (Required) 4 '

Test Data CMTR Data Tensile Strength 84,725 Yield Strength 53,890 Percent Elongation 35.0 Percent Reduction In Area 67.8 Hardness (BHN) HB 119/138 Not Specified Carbon -

.25 Hanganese 1.35 Silicon .27 Phosphorous .010 Sulfur .039 Chromium N/A Nickel N/A Molybdenum N/A Heat Treatment N/A ;

REMARKS: 1. Test temp. 85 - 108 F l

2. Temp. correction applied

-- . -- -- -. . _ . _ . . ~ , .

. . W

e NRC 88-05 h .

MATERIALS WORKSHIrf l

Plant CRYST Unit 3 Line Item 5 ,

Heat-Lot CPC ASME Class 2 I '

Comodity FLG Diameter 6:00 -

Schedule N/A Rating 150 Type BL Spec 105 Grade N/A Source PSI 1 ,

Vendor (WJM or PSI) P CMTR Date 7/24/87 NCA-3800 (Y/N) y l Secondary Supply Chain ....

Supplier Dubose Supplier Dubose Quantity 1 Quantity-In Stock 1 Installed-Access 0 Installed--Not Access 0 TEST DATA WORKSHEET Test Results for Line Item 5 Specimen ID (Required) 5 Test Data CMTR Data Tensile Strength 76,596 Yield Strength 39,313~

Percent Elongation 25.0 Percent Reduction In Area 57.0 Hardness (BHN) N/A Carbon .29 Manganese .76 Silicon .23 Phosphorous .017 Sulfur .030 Chromium N/A Nickel N/A Molybdenum N/A Heat Treatment N/A I REMARKS No testing conducted O ,

l

__ __ -- - i

.v m av me o m . m m e .o a c au u v e mse-co we y em NRC 88-05 J .

MATERIALS WoernmnrT Plant CRYST Unit Line Item 6 Heat-Lot CTY ASME Class '. .

Commodity FLG Diameter 2:00 Schedule N/A Rating 150 Type SO Spec 105 Crade N/A Source PSI Vendor (WJM or PSI) P CMTR Date 10/13/87 NCA-3800 (Y/N) Y Secondary Supply Chain ....

Supplier Dubose Supplier Dubose Quantity 8 Quantity In Stock 8 Installed-Access 0 Installed--Not' Access 0 TEST DATA WORKSHEET Test Results For Line Item 6 Specimen ID (Required) 6 Test Daca CMTR Data Tensile Strength 84,725 Yield Strength 53,890 Percent Elongation 35.0 Percent Reduction In Area 67.8 Hardness (BHN) Not Specified Carbon .25 Manganese 1.35 Silicon .27 Phosphorous .010 Sulfur .039 Chromium N/A Nickel N/A Molybdenwn N/A Heat Treatment N/A FEMARKS - No testing conducted l

_ - - - - _ - - . - . . - _ . _ _ . - _ . - - _ . _ b

1: .

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Revis d 7/26/88 NRC 88-05 NATERIA13 WORKSHEET

. Plant CRYST Unit- 3 Line Itam 7 Heat-Lot COL ASME Class 3 Conunodity FLG Diameter' 2:00 Schedule N/A Rating 150 Type BL Spec 105 Grade N/A Source PSI Vendor (WJM or PSI) P CMTR Date 11/4/87 NCA-3800 (Y/N) Y Secondary Supply Chain .... .

Supplier Dubose Supplier Dubose

Quantity 3 Quantity,In Stock 0 f

Installed-Access 2 Instaned--Not Access 0 TEST DATA W0ernaut?

Test Results For Line Item 7 Specimen.ID (Required) 7 TestDa(a CMTR Data -

Tensile Strength 95,680 i

' Yield Strength 64,123

)

Percent Elongation 26.0 l Percent Reduction In Area 51.0 ,

1 Hardness (BHN) B 140/B 129 None Specified {

Carbon .29 Manganese .76 Silicon ,

.027 Phosphorous .033 Sulfur .034 Chroeium N/A Nickel N/A

-Molybdenus N/A l Heat Treatment N/A REMARKS 1. Test temp. 107 F

2. Temp. correction applied

3. Only installed items tested (2 itams)

4. One (1) used in Non-Related application l

(test Fixture) not available for test. I I

e, e y,vo wor se vo e e a. c e ivaenee -o i

NRC 88-05 h . MATEILIA13 WORKSHEET Plant CRYST Unit 3 Line Item 8 Heat-Lot AAY-40 ASME Class 2 Commodity FLG Diameter 1:00 Schedule 40 Rating 150 Type SW Spec 105 Grade N/A Source PSI Vender (WJM or PSI) P CMTR Date 11/30/87 NCA-3800 (Y/N) Y Secondary Supply Chain ....

Supplier Dubosa Supplier Dubose Quantity 4 Quantity In Stock 4 Insts.11ed-Access 0 Installed--Not Access 0 g- TEST DATA WORKSIDtET Test Results For Line Item

~

8 Specimen ID (Required) 8 Test Data CMTR Data Tensila Jtrength 81.235 Yield Strength S2,499 Percent Elongation 24.0 Percent Reduction In Area 43.0 Hardness (N04) N/A Carbon .28

, Manganese .78 Sillcon .23 Phosphorous .018 Sulfur .029 Chromium N/A Nickel N/A Molybdenum N/A Heat Treatment N/A O RtsinxS 1. No testia. conducted

__ ,____--n- - _ - - - - - - - - - - - - - - - - - - - - - - -- - - - - - -

.w, e .c v , v ., , - n u , e avu m g e e,ne c . -e ci e

3r- }2 NRC 88-05 I'Y .MATEltIAIA if0RKSHErr V ,

Plant CRYST Unit 3 Line Itam 9 Heat-Lot CND ASME Class N/A Commodity FLC DLameter 6:00 Schedule N/A Rating 150 Type SO Spee 105 Grade N/A Source PSI Vendor (WJM or PSI) P CMTR Date 10/13/87 NCA-3800 (Y/N) Y Secondary Supply Chain ....

Supplier Dubose Supplier Dubose Quantity 1 Quantity In Stock 1 Installed-Access 0 Installed--Not Access 0 TEST DATA WORESHEET Test R.esults For Line Item 9 Specimen ID (Required) 9 Te t Data CMTR Data Tensile Strength 78,444 Yield Strength 46,365 Percent Elongation 30.0 Percent Reduction In Area 47.0 Hardness (BHN) N/A Carbon .28 Manganese .75 Silicon .23 Phosphorous .015 Sulfur .011 Chromium N/A Nickel N/A Molybdenum N/A Heat Treatment N/A

, REMARKS 1. No tests conducted

_ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -/

v, a ev n w w en y e co u v e ~eenes www d

h. NRC 88-05 MATERIA 1A WORKSHEtt Plant CRYST Unit 3 Line Item 10 Heat-Lot CND ASME Class N/A Connodity FLC Diameter 4:00 Schedule N/A Rating 150 Type 80 Spec 105 Crade N/A Soures PSI Vendor (WJM or PSI) P CMTR Date 10/13/87 NCA-3800 (Y/N) Y Secondary Pupply Chain ....

l Supplier Dubose Supplier Dubose

' Quantity 1 Quantity In Stock 1

, Installed-Access 0 Installed--Not Access 0 TEST DATA WORESHErr Test Results For Line Item 10 Specimen ID (Required) 10 Test Data CMTR Data "

Tensile Strength 78,444 Yield Strength 46,365 Percent Elongation 30.0 Porcent Reduction In Area 47.0 Hardness (BHN) N/A Carbon .28 l

Manganese .75 !

Silicon .23 Phosphorous .01S ,

i Sulfur .011 i Chromium N/A Nickel N/A l 1

Molybdenum N/A I Heat Treatment N/A REMARKS 1. No tests conducted )

e

-4 I

r- NRC 88-05

( -

MATERIALS WORKSEHrr Plant CRYST Unit 3 Line Item 11

. Heat-Lot 4871 ASME Clans 2 Comodity FLG Diameter 4:00 Schedule N/A Rating 900 Type BL Spec 105 Grade N/A Source WJM Vendor (WJM or PSI) W CMTR Date 5/17/83 !

NCA-3800 (Y/N) Y Secondary Supply Chain ....

Supplier Guyon Alloys Supplier Guyon Alloys Quantity .2 Quantity In Stock 2 Inst'alled-Access 0

~

Installed--Not Access 0 TEST DATA W3RKSHErr Il v Test Results For Line Item 11 Specimen ID (Required) 11 Test Data CMTR Data Tensile Strength 74,953 Yield Strength 44,943 Percent Elongation 27.4 Percent Reduction In Area 56.5 Hardness (BHN) N/A j Carbon .20 i

Hanganese .90 Silicon .19 Phosphorous .021 1 1

Sulfur .028 1 Chromium N/A Nickel N/A Molybdenum N/A l

Heat Treatment Normalized to 1650 F for 1 hr par inch )

REMARKS 1. No tests conducted 1

1 .eo e- ww w .o ee, ee m a e- c e vee -ee -e c e.

3 j NRC 88-05 0 .

Plant CRYST

u= =

Unit 3 Line Item 12 Heat-Lot A66 ASME Class 2 Commodity FLG Diameter 6:00 Schedule'N/A. Rating 600 Type BL Spec 10S Grade N/A Source WJM Vendor (WJM or PSI) W CMTR Date 5/17/83 NCA-3800 (Y/N) Y i i

Secondary Supply Chain ....

Supplier Guyon Alloys Supplier Guyon Alloys Quantity 2 QuantLty In Stock. 2

~

j Installed-Access 0 Installed--Not Access 0 TEST DATA WORKS 1 ten Test Results For Line Item 12 Specimen ID (Required) 12 Test Data CMTR Data Tensile Strength 81,354 Yield Strength 51,344 Percent Elongation 27.8 Porcant Reduction In Area 61.8 Hardness (BHN) N/A Carbon .26 Mar.ganese '

.89 Silicon .026 Phosphorous .013 Sulfur .011 Chromium N/A Nickel N/A Molybdenum N/A Heat Treatment Nomalized to 1650 F and held one hr per inch REMARKS 1. No tests conducted O

w m- cv, w we- se- m w mwna na vnwa - wvec e-

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gA NRC 88-05

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MATERIALS WORKSEErr Plant CRYST Unit 3 '

Line Item 13 Heat-Lot 45786 ASME Class 2 Consmodity FLG Diameter 20:00 Schedule N/A Rating 150 Type SO Spec 105 Grade N/A Source WJM Vendor (WJM or PSI) W CNrR Date 11/18/80 NCA-3800 (Y/N) Y Secondary Supply Chain ....

Supplier ITT Grinnell Supplier ITT Grinnell

' Quantity 4 Quantity In Stock 0 Installed-Access 4 Installed--Not Access 0 TEST DATA WOprRamtT Test Results For Line Item 13 '

Spectinan ID (Required) 13 Test Data CMTR Data Tensile Strength 75,242 Yield Strength 43,524 Percent Elongation 27 Percent Reduction In Area 59 Hardness (BHN) HB 130, HB 137 Not Specified HB 133. RB 145 Carbon .22 Manganese 1.04 Silicon .023 {

Phosphorous .016 Sulfur .018 Chromium N/A l

Nickel N/A ;

Holybdenus N/A Heat Treatment N/A O arxiRxS 1. re.t tem, 5 - 9. r

2. Temp correction applied

UN ERWRIT LAB 5RATOPIES INC, me er... stsu noo noet e: a.rtumois pen-sees

.' - an independent, notfor-profit organization testingfor public safety .

.e October 25, 1988 ,

Mr. Paul Gill ~

Electrical Systems Branch Mail Stop 8D20 Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, Maryland 20852

Dear Mr. Gill:

Subject:

NRC Draft Bulletin Dated October 12, 1988

Re: Rebuilt Circuit Breakers Attached please find Underwriters Laboratories' comments on the above subject Draft Bulletin from NRC.

Please feel free to call' ae if you have any questions, of if I can be of assistance to you in any way.

Sincerely, M M'\LNbCs.

S. Joe 9hatia Vice 1zesident Governmental Affairs SJB: sir cc: Nilliam Brach-NRC Alex Marion-NUMARC Russell Bell-NUMARC Jack Bono-UL Bob Baird-NEMA i

Look For The @ Listing or Classification Mark On The Product FAI see.: ptM 3734199 tem Teens Nea SteeH3M3 esO taas seu 364 3943 Cseer 4AssC MORTNDm008t. E phone p1M 3F da / [34000 giM y

( ) .U??.ERWRITERS

. .... . _ .. _ _ . _ LABORATP"IES

.__ _ INC.;

en independent, notfor-profit organization tutingfor puMic safety t

i October 25, 1988 .

I Electrical Division Branch (SELB) office of Nuclear Reactor Regulation U. 8. Nuclear -Regulatory Commission Washington, DC 20555 l

Attention: Mr. Paul Gill' I subject: Nuclear Regulatory Commission Draft Bulletin Dated l October 12, 1988 - Molded-Case Circuit Breakers

Dear Mr. Gill:

The performance requirements for circuit breakers as outlined in the UL Standard for Safety, Molded-case circuit 1 Breakers and Circuit Breaker Enclosures (UL489), and in UL's Follow-Up service Programs include extensive testing at-fault-current levels. such fault-current level tests are necessarily destructive and a very important part of a full evaluation of a molded-case circuit breaker's acility to perform as intended.

The stated purpose of the bulletin UL was asked to review is to establish a test program for the evaluation of molded-case circuit breakers for which there is no verifiableThe traceability to the original circuit breaker manufacturer.

goal, as we understand it, is to have a test program which will provide some assurance that tested, nontraceable, circuit Since all breaksrs are suitable'for the intended service.

nontraceable circuit breakers which meet the performance tests are to be returned'to service, another goal of the program is to conduct only those tests which would not severely degrade the condition of the circuit breakers tested.

Since the proposed program is to be nondestructive in nature, it is UL's opinion that the test program is not adequate to provide assurance t,hst the tested, nontraceable, o .

l 1

Look For The @ Listing or Classifiestion Mark On The Product ca. ns c monmences, e, em v m u ru ..,en m4tw on== me mien so essa = ses asas

%291 BBa M&

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w

'OctcbDr' w 25,_1988-.

Pago 2 <

' circuit breakers would be suitable for tho intend:d purpoco.

Therefore, UL's comments on the proposed tests, which you requested, should not be construed as an endorsement.

. eeeeeeeees '

GENERAL TEST COMMENTS:

The methods of conducting the tests as outlined are not described. Since detailed procedures are needed to promote repeatability and insure usable test results, we recommend that the test methods be included or that reference be made to the test methods contained in the source standards.

The test program is identified as applicable to safetyThe test program s grade (C1&ss 1E) circuit breakers.

conducted on all circuit breakers regardless of their application as the ability of a circuit, breaker, commercial or safety grade, to sense and Therefore, operate under expected overload uny'nunuumpliance would conditions is import &nt.

show that the tested circuit breaker is ngt suitable for any application.

SPECIFIC TEST COMMENTSt 2.1 Mechanical Test The described test can be used to determine that the circuit breaker latch and unlatch mechanism is mechanically functioning.

2.2 Tlme-Overcurrent Trip Test This series of tests is intended to demonstrate the functioning of the circuit breaker in accordance with its time-current curve. !

2.2.1 Rated current Hold-In Test i At 100% rated current in a 40 degrees C ambient, the circuit breaker under test wo.uld not nuisance trip at maximum expected continuous currents.

. l i

10 Pt es. GE 1J0 C0d TEC l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . - - - - - - - - - - - - - - - i

$$Eobar257.5988~~

'POgo 3 The alternative test at 135% rated current in a 25 degrcOc c ambiert vould not be appropriate as a hold-in test. UL

' Listed dircuit breakers are required to trip within the time period given under the test conditions stated.

If it is desired t6 establish another point on that time-current curve, a separate overcurrent trip test at 135%

rated current in a 25 degrees C ambient would be appropriate with the waximum oc.e-hour and two-hour trip times.

2.2.2 Overload Test The test sesas to combine two features of circuit breaker performance.

At 600% rated current in a 25 degrees C ambient, the test would check another point on the time-current curve. For such a test, closing on the 600% rated current would not be necessary.

A single operation load test at 600% rated current though informative would not, in our opinion, sufficiently demonstrate

the normal load interrupting capabilities of the circuit breaker under test. The proposed test, it conducted at' rated voltage and 600% of rated current, could cause degradation of the circuit breaker tested.

2.2.3 Time Delav Overcurrent Tric This test is only suitable for evaluating additional points on the time-current curve of the circuit breaker under test.

2.3 Instantaneous Trin Test This test is only suitable for tvaluating additional points on the time-current curve of the circuit brecker under test.

2.4 Individual Pole Resistance Test This test, if performed as defined in the NEMA AB-2 standard, could give an indication of the condition of the contacts and internal connections in each pole of the circuit breaker under test. .

O e

red tcr terri es. se .tx

, Molded-Caco circuit 'reckcrs m

oct".b;r 25, 1988

'Page 4 2.5 Dielectric Test A dielectric voltage-with md test could give an indication of the condition ei ..e insulation system in the circuit breaker under test.

- 1 i

- - - - ete We hope these comments will be useful in addressing the expressed concerns over the operating capabilities of circuit breakers, not traceable to the original manufacturer which are l presently both in use and in stock. However, it is our opinion that tests intended to be part of an inspection and maintenance program are not a substitute for a full test program which )

fully evaluates the interrupting capability of the involved i circuit breakers.

Very truly yours, .

I j.ll. $7% .

j S. G. ROLL Vice President &

Chief Engineer i Electrical Division SCR:PLR 4

j i

S0d 10t EO:ri Be. r2 1)O

=---_________-______________________

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. [(M) Yhhingt5. D C 20037 i202)l57M00 Telex 904077 NEMA W5H.

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,. October- 24, 1988 , ,

~

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Mr. William Brach ,

Chief-of Vendor Inspection B .

Division of Reactor Ins on and Safeguards , . . , ' ,

U.S.-Nuclear Regulatory Commission M.' . , ,. ,

Washington, D.C. 20555 - .

SUBJECT:

Draft Bulletin Dated October 12, 1988 /

Ret Rebuilt Circuit Breakers

Dear Mr. Brach:

NEMA would like to offer the following comments regarding the subject draft bulletin:

GENERAL

.We believe that the term " circuit breaker manufacturer" should be substituted for " original equipment manufacturer" since the term " original equipment manufacturer" could also .

J apply to '. panelboard, switchboard or control equipment manufacturer-who has purchased circuit breakers elsewhere.

DESCRIPTION OF CIRCUMSTANCES NRC has limited the scope of this bulletin to only those breakers that have been. purchased as safety-gr3..ie, or purchased as commercial product for upgrade to safety-grade, within the last five years..

We do not feel that, considering the possible failure moder, such limitations should be applied.'Although, of course, breaker priority that should be given to safety-grade applications, any cannot be traced to the cricinal circuit breaker manufacturer should be removed from service for insoection and test. The manufacturer of the breaker in q2estion should be contacted for specific recommendations".

' ACTIONS REOUESTED

1) Time Table ,

The bulletin indicates a specific time table, for* records review, inspection, test and reporting. .

1 NEMA's 1988 Annual Meeting Prttsburgh, Pennsylvania November 13-16

.rgHb & -

j 1

Although we realize that such actions take time, we must '

reiterate our prior statement that tests of breakers collected from the companies in question seem to indicste that little calibration, testing, and inspection to ensure proper reassembly i was done after the breakers were rebuilt. Many of the praakers !

would not meet the original specifications for calibra. tion and performance and some experienced phase to phase faults at overload test levels. That would indicate that a serious hazard may exist where such breakers have been applied. Therefore, each rebuilt breaker should be removed from service for inspection and test.

Priority should be giver, to safety related applications. Therefore, we urge that,such actions be taken with all possible haste.

2) Addressees Recuested to Provide Testine/ Verification Procram Item 3 under " Actions Requested" requests licensees to undertake a testing program to assure the qualification of the equipment (or to assurance ccmpilance with the appropriate requirements). Item 2 on page 7, under reporting requirements, requests holders of construction permits to demonstrate that rebuilt equipment is ~ acceptable for such use.

l Regarding Item 3 (and, to the extent that the demonstration of acceptability for intended use involves testing, Iten 2):

An inspection and test program can give a reasonable degree of assurance of proper operation of a molded case circuit breaker only if the breaker has been manufactured under controlled conditions j to conform to a proven design. This is the basis of manufacture ,

of new circuit breakers.

A particular design of breaker is proven acceptable through inspections and type-tests. Included are both non-destructive and destructive tests (for performance characteristics such as endurance and short circuit capabilities) .

Assurance that ongoing production breakers will continue to perform as the tested breakers did is obtained by controlling the manufacture of these breakers so they they are built the same as the tested breakers. Additional assurance (both is obtained non-destructive and through periodic destructive) inspection and testof representative products by both the m and by a third-party certifying authority such as Underwriters Laboratories.

There is no assurance that a rebuilt breaker has been rebuilt under controlled conditions to conform to a proven design.

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on the contrary, each rebuilt breaker may be a unique combination of parts. Lubricants and sealants may be of the wrong type, wrong amount, improperly applied, or missing completely. Parts may be missing. Parts may be worn to near and of life. Parts may have been taken from breakers of several different designs or vintages. F Non-destructive tests and external inspections of a sealed breaker cannot detect such internal.nonconformances which may adversely affect durability and short-circuit interrupting capability.

Because each rebuilt breaker _can be unique, it is not possible to infer anything'about the performance of a rebuilt breaker by destructively testing another breaker, whether that breaker is new or rebuilt.

To summarize our comments regarding the request that a test program be provided:

Determination of the critical performanen characteristics ;

1.

of durability and short-circuit capabilities of circuit i

breakers requires destructive testing.

2.

Such destructive testing must be performed on breakers known to be identical to the breaker to be placed in service.

3. The degres of similarity of rebuilt breakers to original l l

design requirements, or of one rebuilt breaker to another, is unknown.

4. Durability and short circuit capabilities of rebuilt breakers are, therefore, unknown.

Since testing alone of rebuilt breakers does not assure that the breaker will meet all performance requirements, references in the Information Notice to a generic testing program to assure qualification, or to ensure compliance with the appropriate requirements, should be eliminated.

The very most that could be expected from the testing program noted in the Information Notice, is a negative screening effect which would simply provide an indication that some of the breakers tested are definitely deficient. Such a program alone could not a'dequately assure that those breakers that passed the tests were acceptable for commercial service, much less for use in safety grade applications. .

3

- Further, and for the samo rcocono, evaluations by the NRC of the suitability of rebuilt circuit breakers should not be based on testing of the rebuilt breakers. Nor should thay be based on similarity of the rebuilt breakers to

~

original equipment breakers unless they can be shown to be identical in all respects.

3) Unerades in Breaker. Performance Must Be considered Users of rebuilt circuit breakers must also be aware that some circuit breaker interrupting ratings have been increased over the years. For example, a certain circuit breaker which currently has a 480 volt interrupting rating of 50,000 amperes was originally rated at 35,000 amperes. A rebuilt breaker, of that same type, acquired today might well be an older model with 35,000 amperes interrupting capacity, yet be installed on an application requiring 50,000 amperes interrupting capacity. The rebuilt breaker could meet all of its original design requirements, yet fail disastrously in service.

PROPOSED TEST PROGRAM once again, we do not believe that the suggested test program will assure adequate performance in all of the critical areas addressed by UL 489 and manuf acturers test procedures.

For example, intentional or inadvertent modification of the inside construction details of the circuit breaker could result in catastrophic failure under short-circuit conditions but would not be detected by the abbreviated program suggested. Removal of the mechanism lubrication by cleaning solvents could result in early failure to operate, but again would not be detected by the proposed test program. Assurance of full performance through testing could only be established by a complete UL 489 test program, which would be destructive in nature.

The following comments address the suggested program as written and not its adequacy in assuring performance. The paragraph numbers refered to are those included in the proposed procedure.

Please note that special equipment, special laboratories, and trained personnel will be required to reliably implement even this abbreviated test program; particularly in regard to the proposed full-voltage overload test program.

CAUTION: Fault currents achieved during full-voltage overload tests can approach maximum available fault current levels.

Such tests are normally conducted only in high-current laboratories by trained personnel utilizing special equipment and safety techniques. .

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.2.0 - Test Procedures for circuit Breakers-

-Tests must be conducted according to UL 489 with regard to procedure, wire size, set-up, equipment, etc. Experience has shown that. test programs not closely following UL 489 and up using incorrect' conductor sisgs and test methods.-

This paragraph states that tests should be performed in the_ order of the_ sequence listed. We suggest modifying the sequence to place the overload test 2.2.2, after completion of all calibration tests and before the dielectric test. The overload test, at full voltage, will require a special set-up in a high voltage laboratory. There is no point'is incurring the.' expense ;

in' time and dollars if~the breaker will not pass calibration tests. Also the rated current _ hold-in !

test, 2.2.1,.with its long test times, should be placed after the time delay over-current trip,-2.2.3. The ,

attached copy of the test "rogram shows the suggested test-sequence.

2.2.1 - Rated Current Hold-In Test The first paragiaph0is in error in proposing a 135%

rated0current at 25 C. It should be 110% rated current at-25 C.

j We recommend, however, that the test described in the first paragraph be run at loot rated current at 250C-as recommended in NEMA AB-2.

The second paragraph requires the' test to be conducted for one-hour for circuit breakers rated 50 amperes or below.and two hours-for circuit breakers rated over 50 amperes. We recommend that the ampere rating be 100 amperes in both cases, in accordance with AB-2. .{

2.2.3 - Time Delav~over-current Test t I

The final paragraph states th&t if a circuit exceeds the trip time shown in- Table 1 it is unacceptabis for Class 1E safety-grade applications. It is our opinion that a breaker exceeding the trip times in Table 1 is unacceptable for ADy application.

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2.3.1 - Fixed Instantaneous Settina Breakers 2.3.2 - Adiustable Instantaneous Settina circuit Breakers In instantaneous testing of circuit breakers, we recommend that'the maximum trip time be set at .167 seconds ,.

(10 cycles) in accordance with NEMA AB 2. t The tolerance on instantaneous trip settin as m' percent

-of that shown on the manu f ac t urer's trip t me curves should apply only to factory or laboratory tested circuit breakers, again per AB 2..If breakers are to be tested in the field, the broader tolerances of 140% and 70%, as listed'in NEMA AB-1, should be used. This broader tolerance is necessary because of less controlled test conditions and equipment typically used for field testing. In any case, instantaneous tests should be run by the pulse method, and not the :

so called run-up method. While the run-up method utilizes.

simpler, less expensive, equipment, it relies heavily on the skill and experience of the operator and can ;

produce erratic results.

2.4 - Individual Pole Resistance Test

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Experience has shown that measurement of the very small contact resistance of each pole is unreliable and depends heavily on the precision of the instruments used.. A better approach is to check and compara millivolt drop readings with data provided by the manufacturer. We known of no basis for disqualifying breakers where the differences in readings from pole to pole exceed 50%.

We strongly suggest that the pole resistance test be replaced by a connector temperature test. When the rated current hold-in test (2.2.1) is being run, a temperature probe can be used to measura line and load connector temperatures. They should not exceed a 500 C rise over the ambient. Such tests would give a much better indicator of potential overheating than either contact resistance or millivolt data.

2.5 - Dielectric Tests We knew of no basis for the use of 2,500 volts D.C. as a dielectric test. We recommend the A.C. test since similar or equivalent tests are run by the manufacturers and because test equipment is much more rehdily available.

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SUMMARY

OF COMMENTS

1) Tests have indicated that serious hazard may exist where rebuilt circuit breakers have been applied.

2)

We believe that any breaker that can not be traced back to the original circuit breaker manufacturer should be removed from service for inspecti6n and test regardless of age or application. The original circuit breaker manufacturer should be contacted for i

specific recommendations.

3) Performance of rebuilt breakers can not be assured through use of a generic non-destructive test program.

Only destructive testing would provide the necessary assurances. The proposed test program would provide only a first-cut negative screening.

4)

Even as a first-cut negative screen, the proposed test program has some technical errors which should be addressed. Further, the proposed test program involves tests which require special personnel, equipment, and safety techniques.

We appreciate the opportunity to comment on the draft' bulletin and stand ready to work with NRC in bringing this issue to a speedy resolution.

If you have any questions regarding our comments, please feel free to give me a call.

^

Sincerely, ME R6bert W. Baird Division Staff Executive Attachment cc: J. Bhatia, UL P. Gill, NRC A. Marion, NUMARC T. F. on Rebuilt Breakers 5-AB Section 3

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, __________.____q 2-N/sMh9 ,

WW**** 9.

w b 2.0 Test Procedures for CBs The following tests should be performed in the order of sequence listed.

2.1 Nechanical Test gg The CS should be t-i

/,d, reset and closed a minimum of five times to r

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insure that the latching surfaces are free of any binding. I 2.2 Time-Overcurrent Trio Test _

2. A L Rated Current Hold-In Test This test should be conducted at 100t35, rated ratedcurrent current and at an ancient air temperature of 40'c : 3*c. or at '

,l and at an amoient temperature of 25'c e 3*c. gjg Ecual current should be appliec to all poles of the CB; and C3 N amperes or below and must not trip within I hcur for C5s rats.d

)anperes.

within 2 hcurs for C5s rated over

/po .

f 0;G;E' Overload test This test consists of 1 operating cycle (i.e., closing action follcwed There shall by an opening action) of the CS at 600t rated current.

be no electrical or mechanical breakdown of the C3 during this test.

2./ $;Ger Tire Delav Overturrent Trin This test should be conducted at an ambient air temperature of 25 degrees c : 3* degrees c.

A-/

"kcurrentof300percentofthemarkedratingshou?dbeappliest The trip time for each pole should be com-each pole of the C8. i urrent pared against the time shown in the CB manufacturer's ~ t ith- t :n If the test tr*p times obtained for each pole are nc w curves.

in the time band shown or, the C8 manufacturer's in LebIs 1 and time-curr then the test trio must not exceed the time specified d below:

the acceptance of C5 evaluated with the criteria as liste TABLE 1 VALUES FOR OVERCURiiENT TRIP TEST M00% OF 3REF.

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RATED CCffiiNUQU5 CURREN NEMA AS-2) I I

Range of Rated Maximum Trip Time Breaker Continuous Current In See:nds Voltace Ameeres _

I Volts _

50 15 45 70 240 50-100 240 70-15 45 1:5 6CO 50-100 6CC 200 110-2:5 3:0 240 250 400 240 250 110-225 300 6CC 250 400 250 6C0 a50-6CO - 500 l

600 700-1200 6CO !

600 1400-2500 65C - '

6C0 3000-5000 600 If the minimum tripping times are lower than indi-Minimum trio timesi breaker under cated by the manufacturer's time-current curves for thehas been c test, the breaker should be retested after it

' dination '

If the values obtained are still lower after

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l ted.retest,If nothemis-ccor with upstream and downstream breakers should be eva ua ,

coordination is indicated, then the'CB is acceptable. t

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em um amme - .

'PMax4 cum tripoino ' time:

If the tripping time exceeds the maximum tripp'ng time shown on the manufacturer's time-current curves but is below the time shown in table 1 above, check the breaker time against the protection re-quirements of the circuit (such as cable, penetration, etc.) to ensure that the CB provides the protection, as well as the coordination with up-stream and downstream CBs. If the CB provides the necessary prctaction and coordination, then the CB is acceptable.

Maximum allowable time: If the tripping time of the CB exceeds the trip time shown in the table 1 above, the breaker is unacceptable,' :L._ ^.;

spp h th.5.

2.3 Instantaneous Trio Test

. 2.3.1 Fixed Instantaneous Settino CBs yg Y

/ N' Each pole of the AS should bedested for pickup of the instan- .

taneous unit. he aversge of the three readings for each pole must be between C% an'd h' of the instantaneous trip setting as shewn on the manufacturer time-current curves. The trip time should net exceed .05 seconds (3 cycles).

2.2.2 Ad'ustable Instantaneous Settine CBs S Same as 2,3.1 except that each pole must be tested at the lowest and highest setting. / f# ' -

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The average tri ue for the lowest setting should be between[!

percent and h percent, and the highest setting should be beween

20) percent of the settir.g value shewn on the

[ h percent and manufacturer's ce-current curves. ,

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2.3.3.,$hort-time trip settino test This test is applicable only.if the CB is equipped with the short-time delay trip. This test should be conducted st d'elay en ambient air temperature of 25'c s 3*c. 'The operation of the short-time unit should be within 90t and 125t of the c"Srcurrent E setting g the CB as shown on the manufacturer's time-current cur <

2,4 Individual pole Resistance Test The contact resistance of each pole of the CB should be measuj The average of 3 readings for each pole should ambient temperature.

be calculated and compared with the Also, themanufacturer's average reading of data or w l of similar CBs of the same manufacturer.

each pole should be compared with each other and the differe the pole readings should not exceed fifty percent.

2.4 ~~

A- Dielectric Tests The dielectric test shculd be conducted at an ,fer ac test voltage volts (0.8 x [ x Rated Voltage + 1000 volts])

h.Z I

The dielectric test should be conducted for 1 minute withstand.

(1) line to load teminals with CB open,d closed. (2) line to line tem with CS closed, and (3) pole to ground with CS open an .

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IA-88-607, Forwards Revised Proposed Bulletin Re molded-case Circuit Breakers

Text

SUBJECT:

Enclosures:

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Response

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Dear Mr. Gill:

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Dear Mr. Gill:

SUBJECT:

Dear Mr. Brach:

SUMMARY

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