ML17304B098

Forwards Interim Response to NRC Bulletin 88-010, Nonconforming Molded Case Circuit Breakers (Mccbs). All safety-related MCCBs Purchased Directly from Cbm Unless Dedicated.Final Response to Bulletin by 891231

ML17304B098
Person / Time
Site:	Palo Verde
Issue date:	03/30/1989
From:	Karner D ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
161-01808-DBK-J, 161-1808-DBK-J, IEB-88-010, IEB-88-10, NUDOCS 8904170270
Download: ML17304B098 (10)

Text

ACCEMPXTED Dl 8 t 'TlON DEMON 5

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ACCESSION NBR:8904170270 DOC.DATE: 89/03/30 NOTARIZED: YES DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION KARNER,D.B.

Arizona Nuclear Power Project (formerly Arizona Public Serv RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards interim response.to NRC Bulletin 88-010, I

"Nonconforming Molded Case Circuit Breakers."

D DISTRIBUTION CODE: "IE21D'OPIES RECEXVED:LTR ENCL SIZE:

TITLE: Bulletin Response 88-10 Nonconforming Molded Case Circuit Breakers.

S NOTES:Standardized plant.

Standardized plant.

Standardized plant.

05000528 j 05000529 05000530 g RECIPIENT XD CODE/NAME PD5 LA CHAN,T DAVIS,M.J.

INTERNAL: AEOD/DOA NRR DOEA/GCB ll NRR GUILLEN,J NRR STONE,J'.C.

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MIE TO ALL "RICS" RECIPXENZS PLEASE HELP US K) KZQCZ WASTE!

CCbTACr 'IHE DOCUMEtG'Gb'CAROL DES>i, RQCY. Pl-37 (EXF. 20079)

TO ELIMINATE YOUR NAME FRY DISTKCBUZIQN LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

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Arizona Nuclear. Power Project P.O. BOX 52034

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PHOENIX. ARIZONA85072-2034

~.. 161-01808-DBK/Jt'Q Yiarch 30, 1989 Docket Nos. 50-528/529/530 U.S. Nuclear Regulatory Commission.

Attn:

Document Control Desk Mail Station Pl-137 Washington, DG 20555

Reference:

Letter from NRC to All Holders of Operating Licenses or Construction Permits for Nuclear Power Reactors dated November 22, 1988.

Subject:

NRC Bulletin 88-10; Nonconforming Holded-Case Circuit Breakers

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,.2, and 3

Response

to NRC Bulletin 88-10; Nonconforming-Holded Case Circuit Breakers File:

89-056-026; 89-070-026 Attached is the PVNGS interim response to NRC Bulletin 88-10.

The final response to the bulletin's requested actions 'is scheduled to be submitted by December 31, 1989.

If you have any questions on this matter, please call Hr.

A.

C.

Rogers of my staff at (602) 371-4041.

Very truly yours, D. B. Karner Executive Vice President DBK/JMQ/vlb Attachment cc:

J.

B. Hartin (all w/a)

G, W. Knighton H. J. Davis T. J. Polich F'1~~<041 702r 0 pn033<>

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STATE OF ARIZONA

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COUNTY OF HARICOPA)

I, Donald B. Karner, represent that I am Executive Vice President of Arizona Nuclear

,Power

Project, that the foregoing document has been signed by me on behalf of Arizona Public-Service Company with full authority to do so, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true.

Donald'. Karner Sworn to before me this

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day of / '/I ( /'

1989.

K

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Notary 'P blic My Commission Expires:

My Cuomir w. ui i'@ J~ae >, i>'2

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ATTACHMENT INTERIM RESPONSE TO NRC BULLETIN 88-10 The safety related procurement,,

application",

dedication and maintenance program at PVNGS offe'rs a high degree of confidence in eliminating the use of counterfeit/unknowingly refurbished Molded-Case Circuit Breakers (MCCBs).

PVNGS safety related procurement program requires that all traceability documentation be part of the purchase order requirements.

Safety related shipments without the proper required documentation will not be accepted by quality control receipt

- inspection and will be quarantined accordingly pending further evaluation.

All safety related MCCBs have been purchased directly from the CBM unless they were dedicated.

The. PVNGS commercial grade dedication

program, starting October 31,

1984, allowed the dedication of commercially procured equipment/components for Safety Related (SR) service based on evaluating the critical characteristics of such equipment/components via an Equipment Change Evaluation (ECE) documenting the dedication requirements and characteristics, performing receipt inspection, handling and installing the items in accordance with quality related pr'ocedures, and testing, if appropriate.

,PVNGS'earch for commercial grade dedication evaluation involving MCCBs revealed only four (4) evaluations from October 31, 1984 through August 1,

1988.

The above'ommercial grade MCCB evaluations coupled with PVNGS testing program provides assurance that although the evaluated MCCBs may not be traceable to the circuit breaker manufacturer, they will perform their safety related function as required.

The subject bulletin's required actions include performing research activities covering August 1,

1983 through August 1,

1988 time frame.

The PVNGS'rocurement/dedication program as mentioned earlier, was in effect since October 31, 1984.

The August 1,

1983 through October 31, 1984 period was'overed by the Bechtel.

(A/E) program.

As a

result, Bechtel was contracted by APS to identify and evaluate any MCCB upgrades for the above period of time.

The Bechtel investigation concluded that during the August 1, 1983 through October 31; 1984 time frame there was no program that allowed the upgrade of commercially obtained MCCBs for SR applications.

In

fact, based on the application procedures that.were in effect at the time, stringent controls were administered to ensure that only safety related components were used in safety related applications.

The Bechtel investigation also included the scanning of all the Non-Safety Related (NSR) purchase orders for their application determination.

As a

result, the majority of the NSR purchase orders were traced to their final application and no NSR purchase orders were found to be related to safety related applications.

Based on the Bechtel findings, a reasonable assurance exists that NSR MCCBs procured commercially (possibly without verifiable traceability to the MCCB manufacturer) between August 1,

1983 and October 31, 1984 were not used in safety related applications.

As a result of the

above, APS has determined that no non-traceable or non-dedicated MCCBs were utilized in safety related applications.

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Attachment Page 2

APS will respond to the requested actions in NRC Bulletin 88-10 and any forthcoming NRC supplements thereto to add additional assurance to the validity of APS and Bechtel procurement, application and dedication programs.

In order to completely respond to the bulletin's requested

actions, an additional time period will be required.

Therefore, the expected final response date to NRC Bulletin 88-10 is December 31, 1989.

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