Bulletin 88-10: Supplement 1, Nonconforming Molded-Case Circuit Breakers

                                                  OMB No.:  3150-0011
                                                  NRCB 88-10, Supplement 1

                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                      OFFICE OF NUCLEAR REACTOR REGULATION
                             WASHINGTON, D.C.  20555

                                 August 3, 1989


NRC BULLETIN NO. 88-10, SUPPLEMENT 1:  NONCONFORMING MOLDED-CASE 
                                       CIRCUIT BREAKERS


Addressees:

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

Purpose:

The purpose of this bulletin is to inform addressees that based on a prelimi-
nary review of responses to NRC Bulletin No. 88-10, the NRC staff has deter-
mined that many responses do not adequately satisfy the provisions of Bulletin 
No. 88-10 and that some addressees may need to take additional actions.  This 
supplement also provides specific examples of common deficiencies identified 
during the preliminary review of responses.

Description of Circumstances:

NRC Bulletin No. 88-10 was issued on November 22, 1988, to request that ad-
dressees take actions to provide reasonable assurance that molded-case circuit 
breakers (CBs) purchased for use in safety-related applications perform their 
safety functions.  In addition, the bulletin required that addressees submit 
certain information to the NRC regarding CBs that could not be traced to the 
circuit breaker manufacturer (CBM).  

An NRC staff review of the written reports submitted by addressees in ac-
cordance with Bulletin No. 88-10 revealed several common deficiencies. In 
addition, the NRC staff has received requests for positions on specific issues 
that were not explicitly addressed in Bulletin No. 88-10.  The NRC analyses 
and positions on these issues are provided in this supplement.

During the preparation of this supplement, the NRC received comments from the 
National Electrical Manufacturers Association (NEMA) and the Nuclear 
Management and Resources Council (NUMARC).  NEMA reaffirmed its position that 
neither the tests delineated in Bulletin No. 88-10, a visual inspection, nor a 
combination of testing and inspection, are adequate to ensure the performance 
of non-traceable CBs.  Similarly, NUMARC raised concerns about and advised 
against the use of nontraceable CBs from known refurbishers, regardless of 
whether 




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or not they have passed the tests delineated in Bulletin No. 88-10.  However, 
the NRC judgement on the adequacy of bulletin testing to justify continued use 
of nontraceable CBs remains as stated in Bulletin No. 88-10.

NRC Positions:

1.   If CBs are traceable to an original plant construction order and the CBs 
     were received prior to August 1983, there is reasonable assurance that 
     the CBs are acceptable and no additional traceability is required.  

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

3.   Item 4 of the actions requested in Bulletin No. 88-10 applies only to CBs 
     that were purchased and installed after August 1, 1983.  
     
4.   If an addressee identifies any CBs as nontraceable during the review 
     requested by Bulletin No. 88-10, it should take appropriate corrective 
     actions as required by Criterion XVI of 10 CFR Part 50, Appendix B.  As 
     part of these corrective actions, the NRC expects addressees to assess 
     the acceptability of all installed safety-related CBs that were procured 
     under the same purchase orders as the nontraceable CBs. 
     
5.   In an effort to limit the number of nonconforming CBs in safety-related 
     systems, nontraceable CBs that were installed or are being maintained as 
     stored spares as of August 1, 1988, and that successfully pass all tests 
     specified in Attachment 1 of Bulletin No. 88-10 are considered acceptable 
     for use only as replacements for safety-related CBs that are found to be 
     nontraceable during the review requested by Bulletin No. 88-10.  These 
     breakers may not be used as safety-related replacements during other 
     activities such as planned plant modifications or routine maintenance.

6.   For CBs stored as spares that were not procured directly from the CBM, 
     each individual CB should be reviewed in order to establish proper 
     traceability, regardless of the number of CBs. 

7.   All safety-related CBs from the same procurement order are considered 
     traceable provided that 1) the order was procured directly from a CBM 
     having a quality assurance program in accordance with 10 CFR Part 50, 
     Appendix B, 2) the CBM has been audited by the addressee in accordance 
     with Appendix B, 3) the CBs were ordered as safety-related, and 4) 
     documented evidence has been furnished to the addressee, such as a 
     
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                                                  August 3, 1989
                                                  Page 3 of 4


     certificate of compliance.  However, if safety-related CBs were procured 
     from a vendor other than the CBM, a certificate of compliance by itself 
     is not considered an adequate basis for establishing traceability.  In 
     such cases, traceability of individual procurement orders should be es-
     tablished through the review of procurement or shipping records back to 
     the CBM.  Telephone discussions with the CBM or vendor are not acceptable 
     for establishing a basis for traceability.  Traceability to a warehouse 
     facility controlled by the CBM is considered equivalent to traceability 
     to the CBM.

Actions Requested:

In response to the aforementioned circumstances, addressees are requested to 
perform the following actions within 90 days from the receipt of this 
bulletin:

1.   Review written reports submitted to the NRC in accordance with Bulletin 
     No. 88-10 and verify that the responses meet the bulletin provisions as 
     clarified by this supplement.

2.   Prepare and retain documentation for possible audit that indicates that 
     item 1 of the actions requested has been performed as requested.  

Reporting Requirements:

Addressees are required to provide a written report documenting any 
appropriate corrections to previous responses to Bulletin No. 88-10.  

The NRC may conduct inspections at selected nuclear power plant sites in order 
to verify that issues associated with Bulletin No. 88-10, and as clarified by 
this supplement, have been adequately resolved.

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 appro-
priate Regional Administrator.

This request is covered by Office of Management and Budget Clearance Number 
3150-0011, which expires December 31, 1989.  The estimated burden hours, which 
includes the original bulletin requests, is 1,000 to 10,000 person-hours per 
plant response, including assessment of these requirements, searching data 
sources, testing, analyzing the data, and preparing the required reports.  
Send comments regarding this burden estimate or any other aspect of this 
collection of information, including suggestions for reducing this burden, to 
the Records and Reports Management Branch, Division of Information Support 
Services, Office of Information Resources Management, U.S. Nuclear Regulatory 
Commission, Washington, D.C. 20555; and to the Paperwork Reduction Project 
(3150-0011), Office of Management and Budget, Washington, D.C. 20503.

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




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


Technical Contacts:  Uldis Potapovs, NRR
                     (301) 492-0984

                     Jaime Guillen, NRR
                     (301) 492-1170


Attachment:  List of Recently Issued NRC Bulletins