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
8907270121
. NRCB 88-10, Supplement 1
August 3, 1989
Page 2 of 4
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
. NRCB 88-10, Supplement 1
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.
. NRCB 88-10, Supplement 1
August 3, 1989
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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
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