ML20247J239
| ML20247J239 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/19/1989 |
| From: | Brach E, Mcintyre R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247J243 | List: |
| References | |
| 50-213-89-200, NUDOCS 8906010077 | |
| Download: ML20247J239 (37) | |
See also: IR 05000213/1989200
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INSPECTION REPORT
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
DIVISION OF REACTOR INSPECTIO!1 AND SAFEGUARDS
REPORT NO.: 50-213/89-200
-DOCKET N0.: 50-213
LICENSEE NO.: DRP-61
LICENSEE: Connecticut Yankee Atomic Power Company
P.O. Box 270
Hartford, Connecticut 06101
FACILITY: Haddam Neck Plant
INSPECTION AT: Haddam Neck, Connecticut
DATES: January 3 through February 10, 1989
INSPECTORS: // - <[ _ _
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Iratd
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chard'P. McIntfre, Team Leader
Vendor Inspection Branch (VIB) ,
S. D. Alexander, Equipment Qualification and
Test Engineer, VIB j
J. J. Petrosino, Quality Assurance Specialist, VIB
W. P. Haass, Senior Reactor Engineer, VIB
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R. C. Wilson, Senior Reactor Engineer, VIB
A. E. Finkel, Senior Reactor Engineer, Region I
CONSULTANTS: P. R. Farron, Nuclear Energy Consultants, Inc. (NEC)
F. C. Webb, NEC
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APPROVED BY:
E. WiH Ta'm Brac#, Chiet
w/ D6ter
///f
Vendor Inspection Branch
Division of Reactor Inspection and
Safeguaras
Enclosure 2
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l* Inspection Summary: l
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Inspection from January 30 through February 10, 1989 (Report No. 50-213/F9-200) l
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Areas Inspected: A special announced inspection was conducted by the NRC l
Vendor Inspection Branch to review the implementation of the licensee's vendor j
interface program and the program for the procurement of items for use in )
safety-related systems at the Northeast Utilities (NU)/ Connecticut Atomic Power j
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Company (CY) Haddam Neck Plant (HNP). The inspection team reviewed the doc-
umentation of specific vendor-related technical issues including 10 CFR Part 21
notifications received concerning the procurement of items utilized in ,
safety-related applications at HNP. l
Results: The NRC inspection team identified the following weaknesses in the
HNP procurement program and the interfaces between the licensee and its
vendors. l
a. The NRC inspectors identified instances in which the licensee installed
commercial grade items (CGls) in safety-related systems without adequately
evaluating their suitability for use in such applications. The licensee
procured such items without performing documented technical evaluations to
identify such attributes as the safety functions and critical characteris-
tics of the items. Verification of design and manufacturing / material
changes, or receipt inspection requirements beyond a part number verifi- ,
catiori and check for physical damage were not evident. Traceability to
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the original manufacturer was not always documented where applicable and
testing would not always have been adequate to verify critical charac-
teristics. This programmatic deficiency resulted in the installation of .
certain components of unverified quality and capability in safety-related l
systems.
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b. The NRC inspectors identified several instances in which the licensee
failed to specify the provisions of 10 CFR Part 21 as being applicable on
purchase orders (P0s) for items intended for use in safety-related
applications, that specified that the components or items purchased must
be in accordance with nuclear specifications or quality assurance require-
ments. Such procurement were not consistent with the definition of
commercial grade items in 10 CFR 21.3 and thus did not meet the require-
ments of 10 CFR 21.31 for specifying the applicability of 10 CFR Part 21
on nuclear safety-related procurement documents.
c. The NRC inspectors determined that until January 25, 1989, the licensee
had not established a formal, documented site-level program, for the
receipt, evaluation, and implementation of recommended corrective actions
for incoming technical information received from vendors. As a result,
Power Pointers (PPs) and Maintenance Instructions (Mis) received from the
emergency diesel generator (EDG) manufacturer, General Motors / Electro-
Motive Division (GM/EMD), did not receive a documented evaluation for
their applicability to the HNP. Additionally, the licensee did not
maintiain the EDG maintenance and operating manuals in an up-to-date
condition.
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d. The NRC inspectors identified four vendor communications describing
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potential safety concerns that were received at HNP but were improperly
and/or incompletely assessed for their applicability to HNP. In all four
cases, the licensee initiated corrective action before completion of the l
inspection to address NRC concerns. l
e. While reviewing procurement activities for services and components
provided by Bechtel Power Corporation (BPC) as part of the upgrade and
modifications of the vital battery and associated components, the
inspectors questioned the adequacy of Bechtel's dispositioning and closing
out of deviations identified in procurement activities. Bechtel, acting
as designee for Northeast Utilities Service Company (NUSCO), was perfor-
ming the battery modification for CY at the HNP. The inspectors could not
determine if the licensee was adequately controlling the disposition of
deviations and nonconformances identified during this HNP battery upgrade
and modification; therefore, this issue is unresolved. j
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Conclusions: The HNP procurement and vendor interface program deficiencies '
have been classified as Potential Enforcement Findings 50-213/89-200-01,02,
03, and 04 and Unresolved Item 50-213/89-200-01. These findings will be
referred to the NRC Region I office for appropriate action.
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I. PROCUREMENT
The NRC inspection team reviewed the licensee's program for the procure- ,
ment of parts, components, and equipment to be used in safety-related !
applications at the HNP. This review addressed the procedures that govern
the procurement process, as well as the methods used to upgrade commercial
grade items (CGIs) for use in safety-related applications. A program
description and the results of a review of the HNP procurement procedures
are contained in Appendix B to this report. To evaluate the implementa-
tion of the program, the NRC inspectors reviewed selected HNP procurement
of items to be used in safety-related systems, that were procured both as
commercial grade and as nuclear safety grade from approved suppliers
having a 10 CFR Part 50, Appendix B, Quality Assurance (QA) Program.
The NRC evaluated the effectiveness of HNP's program as implemented for
procurement of materials and services for safety-related systems and I
equipment by reviewing three types of procurement: nuclear safety grade l
(HNP procurement levels (PLs) -A and -B) and commercial grade to be l
dedicated under procurement level C (PL-C). HHP procurement levels are
discussed in more detail in Appendix B of this report. The inspectors
assessed the program effectiveness for assuring compliance with NRC
regulations and its implementation by reviewing selected procurement for ,
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items installed, and/or available for installation, in safety-related
applications. The inspectors evaluated compliance with regulatory
requirements and HNP procedures, with emphasis on the three key issues
listed below to determine if the component selection, procurement,
receipt, and (for CGIs only) dedication process were appropriate to the
circumstances,
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Were appropriate programs implemented to meet the 10 CFR Part 50,
Appendix B, Criterion III requirements for selection and review for 4
suitability of application of materials, parts, equipment, and k
processes that are essential to the safety-related functions of
systems, components, and structures?
Were appropriate programs implemented to meet the 10 CFR Part 50, 4
Appendix B, Criterion VII requirements for assuring that equipment
conforms to the procurement documents with appropriate provisions to
ensure that objective evidence of quality is furnished to the
licenesee and evidence produced by licensee actions, such as examina-
tion of products upon delivery, is maintained to document that the
requirements and specifications are met?
Were the requirements of 10 CFR Part 21 imposed in procurement i
documents when required for manufacturers / suppliers to ensure as a !
minimum that nonconformances or failures to comply with requirements i
would be reported to the licensee so that the licensee could evaluate
such deviations in accordance with 6 21.21 of 10 CFR Part 217
A. Procurement Package Review
A 4-volume master list of safety-related HNP equipment and components
entitled, " Connecticut Yankee; Quality Assurance; Material, Equipment,
and Parts List" (MEPL) (described in more detail in Appendix B of
this report) identifies safety-related, structures, systems, and
components controlled under HNP's 10 CFR Part 50, Appendix B, quality
assurance (QA) program. During the procurement review, the NRC
inspectors refered to Revision 4 of the MEPL, dated, August 26, 1988.
The inspectors selected for review, primarily, examples of procure-
ments of materials actually installed in safety systems and
equipment, and secondarily, those materials procured for stores and
available for use in such applications. To this end, the inspectors
obtained maintenance records for jobs on selected safety systems
listed in the " Expanded Work Order Report" computer printout from
HNP's " Plant Maintenance Management System" (PMMS), historical
database. Among the systems selected were: the Class 1E, 4160-VAC, l
480-VAC,120-VAC,125-VDC electrical systems (including station !
batteries, chargers, and inverters); the reactor protection system !
(RPS); and several mechanical / fluid systems (safety systems and
non-safety systems with certain safety-related components) such as
the emergency diesel generator (EDG), the residual heat removal (RHR)
system, the service water system, the main feedwater system, the high
and low pressure safety injection (HPSI and LPSI) systems, the
auxiliary feedwater (AFW) system, and the chemical and volume control
system (CVCS). From these maintenance records (completed work
orders), the inspectors determined which safety-related components ,
(as identified in the MEPL) were actually replaced or which of their
parts were replaced. From the associated material issue forms (MIFs)
filed with the work orders (W0s), the inspectors identified the
numbers of the material receipt inspection reports (MRIRs) on which
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. the receiving activities for the replacement components and/or parts 1
were documented. The MRIRs referenced the associated purchase j
requisitions (prs) and purchase orders (P0s) from which the j
inspectors could determine the suppliers, the procurement levels 1
(PLs),'and the; conditions of purchase imposed on the suppliers. !
-The licensee was able to provide the inspectors with' documentation
L review packages consising of W0s, MIFs, MRIRs, prs, and P0s.: l
L However, records germane to documentation of. traceability, such as a
invoices, packing slips, and shipping and intermediate receiving
documents, were not included .in records available on site. In
addition to these documents in the review packages, the inspectors
reviewed-test procedures _and results, drawings, and other technical
documentation in'certain cases. Certificates of comformance or com -
pliance:(C0Cs)andothervendorcertificationswere'reviewedwhen-
applicable, and. vendors were checked for inclusion on the Approved
Suppliers List (ASL) maintained by the NUSCO Quality Services Depart-
ment ~(QSD)atNUheadquartersinBerlin, Connecticut.
The deficiencies noted during the procurement review fell'into two-
major categories: .(1) Those PL-A and PL-B procurement that did not
contain the required 10 CFR Part 21 reference and/or adequate QA
requirements, and (2) PL-C procurement for-which adequate dedication
was not' accomplished or documented. Dedication deficiencies were
predominantly the -lack of adequate review for suitability for-
application (including defining safety functions.and critical charac-
teristics), lack of documented, verifiable, traceability of, CGIs to
their original manufacturers, and lack of adequate inspection and/or
testing to verify critical characteristics. In most cases of
deficient dedications,. receipt inspection consisted of no more than
part number verification' and examination for quantity, damage,
cleanliness and appropriate marking. This constituted the standard-
HNP " minimum receipt inspection," as defined in CY administrative
control' procedures (ACPs)ACP1.2-4.1and7.1. Although some testing
wasconductedbeforeand/orafterinstallation(ratherthanreceipt
. testing), such testing was often. inadequate ~for. verifying. critical
characteristics. A subset of PL-C procurement that generally' lacked
documentation were those in which parts that had been purchased under
PL-D for non-safety applications, for which the original P0's were
mostly not available, and which did not receive formal, documented
receipt inspection were " upgraded" to PL-C by performing a receipt
inspection and documenting it on an MRIR in accordance with HNP
procedure ACP 1.2-2.5.
1. The following are examples of PL-C (commercial grade) procure-
ments of items installed in safety-related systems without
ddequate dedication:
a. P0 SWEC 1721-1/CY E49969, dated April 14, 1986, for Marathon
terminal blocks purchased by Stone & Webster Engineering
Company (SWEC) from Allied Electric for NU's Millstone
Plant, Unit 3, and later transferred to HNP and installed
in safety-related (classified by HNP as " Category I") vent
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damper controls under WO number CY 86 06296. HNP minimum
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receipt' inspection was documented on MRIR 86-448. . Although
the P0 stated that this was a PL-B procurement, no QA
specifications or invocation of 10 CFR Part 21 appeared-
l; on the procurement documents, although both were addressed
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on the manufacturer's COC for equipment environmental
' qualification (EEQ). No documentation to establish trace-
ability to the manufacturer or. its_ C0C through' A111ed
Electric was evident.
b. 'P0 848173, dated November 1986, for a Westinghouse (W) "X"
relay purchased from W Electric Corporation general-sales
office in Hartford, Connecticut, was ~ installed in Category
I ground device number GND-BKR-1 under WO'CY 88 01696. The
P0 identified the procurement level as PL-C, yet contained
QA requirements. A COC from W that addressed QA and even
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10 CFR Part 21, was on file, Eut the wording was not clear
and traceablilty for the parts to W and to the C0C was not
established. Dedication consisted only of HNP minimum-
receipt inspection which was documented in MRIR 85-183-3.
WO number CY 88 01696 indicated that post-installation,
functional
consisted ofverification
multiple cycling testing of
hadthebeen
ground performed,(which
device a type
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of circuit breaker). However, it was not clear from the WO
whether or how the X relay was electrically tested.
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c. P0 849541, dated April 17, 1986, was issued to Lasher
Supply Company for Jenkins, 2-inch, bronze gate valves
(with nickel alloy wedge) to replace valves in a
safety-related section of the service water system. Since
the original manufacturer was no longer in business, the
new valves were procured from a different manufacturer as
CG1s under PL-C, rather than as nuclear safety-related
items. The procurement documentation file did not provide -
sufficient information to support an appropriate dedication.
A short evaluation, included with the P0', concluded that
the original and replacement valves were compatible based j
on the commercial catalog specifications. No other design,
material, or quality information was requested or received
from the vendor to establish that this substitute valve was
a suitable replacement.
d. P0 778152, dated September 8, 1987, was issued to T.F. Cushing,
Incorporated of West Springfield, Massachusetts for two
Agastat 7012PD 5-to-50-second time delay relays, for use in
AFW automatic initiation circuits. The relays were accepted
by HNP quality control (QC) on MRIR 87-217-A and -B with
only the HNP minimum receipt inspection. The file did ,
contain a CY engineering telephone record, dated June 2, !
1987, discussing the shelf life of Agastat 7000-series
relays with the manufacturer, Amerace Corporation. The
relay was installed in the EDG load shedding sequencer
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panel as relay number.1062-4 where.it was located by the
- NRC ' inspector during the_walkdown conducted in evaluating
thw HNP actions in response to NRC Information Notice-
87-66. A.1987. CY work order showed post installation
testing was conducted, but no other design, material, or-
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quality information was requested or received from the
vendor to establish that these relays were a; suitable
replacement.
e. P0 101681, dated November 25, 1987, to Westinghouse
Electric Supply Company (WESCO) for four W type A251K11CA
reversing contactors. No special requirem_ents were-
identified on the 90. -The dedication was based on HNP
minimum receipt inspection documented on MRIR 87-979 and
post-installation testing per the retest section of
procedure SUR 5.7-64, "No Flow Test of Core Cooling . a
Systems," Revision 3, dated November 15, 1986. lA stated j
purpose of the procedure was to demonstrate operability of '
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safety injection isolation valves SI-M0V-861A through D and
core deluge valves SI-MOV-871A and B under no flow
conditions. 'No C0C or testing information from W was
evident. The validity of the SUR 5.7-64 test, is-
questionable under no flow conditions because the test does--
not duplicate actual operating parameters and, therefore,
would not demonstrate contactor operability under all-
design conditions detailed in the HNP Final Safety Analysis
Report (FSAR).
f. P0 681057, dated October 29. 1984, to Raychem Corporation,
Woburn, Massachusetts for Raychem type 25-CPK-01-00 cable
preparation kits. The P0 imposed 10 CFR Part 21 and stated
~ that the purchase was safety-related ~and that " Product
acceptability will be verified during receipt inspection or
post installation. testing at nuclear plant...." Each kit-
contains 1 strip of aloxite carborundum 120 grit metal
abrasive cloth (emery cloth) and several trichloromethane
and perchloroethylene solvent wipes. ' A Raychem COC, dated
November 16.-1984, in the file stated, in part "... Parts
are in compliance with SCD-10032...are commercial grade
products as defined in 10 CFR Part 21.3... issued in accor-
dance with AMPAC QA program... Inspection and test Reports
are available...." The kits were used in conjunction with '
Raychem WCSF-N heatshrink splice insulation sleeves
procured on CY PO 680631, dated October 24, 1984, and used
on the motor electrical cable connections for motor
operated valve numbers SI MOV-861A/B/C and D, MOV-200 and
MOV-298. Although Raychem is an approved supplier,. the
supplier of the solvents was not; therefore, the unsubstan-
tiated assertions of this subtier supplier without other
objective evidence was found to be an insufficient basis to
demonstrate that the kits would be suitable for use on the
particular plant wiring for which they were intended. '
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g. P0 857232, dated February 6,1987, was placed with O'Keefe
Controls for 12 commercial grade ASCO solenoid operated
valves (S0Vs) for use in the feedwater control system as
SOV numbers FRV-1301 through 1304. The currently installed
50Vs (ASCO model 200925-2RF) are a different model from the
S0Vs originally installed (ASCO 8200 series). Documented
dedication beyond HNP minimum receipt inspection and a
post-installation test of valve cycling upon energization
was not evident. No evaluation was documented to determine )
whether the substitute 50V was a suitable replacement. '
During the inspection, HNP contacted the manufacturer to
obtain information with which to evalutate the similarity
between the two models of S0Vs to verify suitability.
Although HNP did confirm that neither environmental nor
seismic qualification requirements applied to these S0Vs,
basic suitability for the HNP system application was not .'
established.
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h. P0 243601, was placed with Lasher Supply Company in 1972, !
according to receipt records, for four, commercial grade
valve discs for 3-inch, 900-psi Powell check valves used in
the AFW system. Two of these valve discs were installed in
valves FW-CV-135-2 and -135-3 in 1986. The licensee could
not produce a copy of P0 243601, thus traceability of the
installed discs to the manufacturer as well as to any
certified material test reports (CMTRs) for pressure '
retaining components could not be established. The
dedication consisted of HNP minimum receipt inspection and
a leak test in November 1987, to verify functional
performance. However, since not all critical
characteristics were verified, HNP opened a controlled
routing (CR) and committed to refit the affected valves
with discs that have documented traceability during the
next refueling outage.
i. PO 779266, dated September 24, 1987, was issued to Lasher
Supply Company for gaskets and pressure seals for 3-inch,
900-psi, Powell check valves in the AFW system. The
materialswerepurchasedasCGIs(PL-C)anddedicatedfor
this safety-related application based on HNP minimum
receipt inspection only.
J. P0 747822, dated August 25, 1986, was placed with Koppers
Company for a commercial grade flex coupling replacement
for the Terry turbine-driven AFW pump "A." No documented
evaluation was performed to determine whether this coupling
was a suitable replacement. Dedication consisted of j
minimum receipt inspection and post-installation opera- -
tional testing of the AFW pump and turbine. During the
inspection, HNP contacted the turbine and coupling vendors
to determine if the installed coupling is the recommended
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replacement. Although HNP had received telephone confir- .
mation from the vendor that the installed coupling was a l
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suitable replacement, they had not received documented
confirmation by the end of the inspection.
k. PO 064292, dated August 12, 1987, to WESCO, East Hartford,
Connecticut, for W type EH2015 molded case circuit breakers
in panel number DE-PNL-A for circuit MSR/MCB-F.
Traceability was not documented. Dedication was based on l
HNP minimum receipt inspection. A potential operability ;
concern was that the breakers may not isolate the 125-VDC 1
vital bus from fault on the non-vital moisture separator
reheater condenser air ejector steam control valve bus
supplied by one of these breakers. The post installation
test shown on WO number CY 88 01512 was'to verify no trip
under normal load instead of the instantaneous overload
trip. These breakers were listed in the supplements to NRC
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1. PO 851466, dated June 12, 1986, to WESCO East Hartford, for !
W type A250-MICAC, 3-phase reversing starters (contactors),
Tnstalled in panel C4CR. .HNP minimum receipt inspection ]
was shown on MRIR 86-479, but traceability was not estab-
lished. Adequate testing was not documented. The potential ]
existed for failure of these starters to jeopardize the l
ability to isolate feedwater to the' steam generators. The
starters were installed in circuits FW ISOL-SG-1, through -4,
for motor operated valves FW-MOV-11B, -128, -138, and -14B
under W0s CY 86 06354, 5, 6, and 06358. These starters were
also listed in NRC Information Notice 88-46 supplements.
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m. P0 325328-(believed to be correct PO) to GE, PSMBD,
Malvern, PA, for "HEA" type trip coils installed under W0
number CY 87 07611 as auxiliary overvoltage and
undervoltage relay numbers 27-Y-5 and MCR-A4(BO) and (BP).
Documentation was incomplete. The MIF referenced MRIR 996,
but MRIR 996 lists the material received as HGV15A21 :
undervoltage relay. In this instance, coils of unverified )
quality could potentially degrade voltage excursion !
protection capability for Class 1E busses and l
safety-related equipment. !
n. Dedication for the following commercial grade procurement y
was also found to be inadequately conducted and documented !
and these procurement were discussed with HNP during the
inspection:
Purchase Order Manufacturer Items Procured
(1)685449 General Electric U/V lockout relay
(2)763130 Telemechanique contact block and
relays
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(3)616437 Kunkle Valve Co. EDG relief valves
(4) 719581 Sorrento radiation
. Electronics monitoring equipment
(5)723976 Technology for Endevco
Energy Corp. accelerometers
(6)555700 Connecticut EDG drain valve
Piping Co.
2. The following are examples of installations in safety-related
applications of non-safety-grade material, procured PL-D, for
which there was no original documentation (with one exception),
and upgraded to PL-C by virtue only of documentation of an HNP
minimum receipt inspection on an MRIR, in accordance with HNP
procedure ACP 1.2-2.5," Classifying and Upgrading Spare Parts."
a. No P0. Upgraded on MRIR 87-767, from unknown source,
Mallory type 760Z SOLA transformer capacitors were
. installed in 125VDC-to-120VAC vital bus inverters IV-1A, C,
and B under W0s CY 86 01578, 01580, and 01582 respectively.
b. No P0, no MRIR, no upgrade, and no testing, were evident
for a SOLA transformer installed in 120VAC semi-vital bus
power supply output transformer / regulator "T-SVN" under WO
CY 86 02109. Transformer T-SVN was listed as Category I
equipment in the MEPL, but the Category I block was marked
"N/A" on the MIF. Failure of this equipment could degrade
the s m -vital power supply.
c. No P0. Upgraded on MRIR 87-767 were Mallory 860Z SOLA
transformer capacitors for semi-vital automatic bus
transfer device SV-ABT.
d. No P0, no upgrade, no MRIR, no traceability, and no
testing, were evident for a type 1529458-C closing coil for
a DB-50 reactor trip breaker in circuit MCC1MCC4-BUS 4/4C.
e. Gaskets and pressure seals were purchased under PL-D for !
3-inch, 900-psi, Powell check valves similar to those I
purchased under PL-C on PO 77296 above. Although the file i
contained PO 736671, dated April 21, 1986, issued to Lasher
Supply Company for this material, this procurement was non-QA,
PL-D and upgraded to QA-Category I, PL-C, in August 1987,
solely on the basis of an HNP minimum receipt inspection.
Section A.1 and A.2 above identify examples of inadequately
dedicated CGIs which, at the time of the inspection were con-
sidered to be of unverified quality and capability to perform >
their safety functions under all postulated / design service
conditions. These items were installed in safety-related systems
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and equipment. The licensee promptly commenced an operability -
evaluation because no documentation existed to verify suitability
for application, and the safety functions and critical charac-
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teristics were not identified or verified.
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The inspectors reviewed the comercial grade application
evaluations and dedication justifications performed by the
licensee during inspection and concluded that adequate
assurance was provided for continued use of these items in the
plant, pending successful completion of dedication activities.
/it the conclusion of the inspection, HNP still required certain
information and documentation from vendors to complete the
dedication justification for some of the items. In addition to
reviewing the specific examples of inadequate dedication
identified during the inspection, HNP committed to review
procurement level-C purchases made from January 1985 to July of
1988 on a sample basis. The results of this review will
determine if additional evaluations over a longer period need to
be conducted.
3. The following are examples of PL-A and PL-B purchase orders on
which the licensee failed to specify, as was required, that the
provisions of 10 CFR Part 21 were applicable:
Purchase Order Date Manufacturer / Vendor
a. 911285 2/22/87 NAMC0 Controls
b. 741436 6/11/86 AMP Special Industries
c. 739354 5/20/86 Morrison-Knudsen
d. 770119 .ombustion Engineering
e. 856540 12/19/86 John Fluke Manufacturing
. Company
f. 739896 5/27/86 Control Products /Amerace
Corporation
B. Assessment of Implen,entation of Procedure ACP 1.2-4.2, " Commercial
Trade Procurement, Upgrade, and Dedication Process"
HNP has been introducing commercial grade dedication requirements
into its procurement process since Revision 19 of procedure ACP
1.2-4.1, " Procurement Document Review," was issued in September 1987.
Refinements were added in Revision 20 of ACP 1.2-4.1; Revisions 0 and
Revision 1 of ACP 1.2-4.2; Revision 0 of ACP 1.2-4.3; and most
recently in NUSCO procedure NE0 6.11. In addition to reflecting the
Electric Power Research Institute (EPRI) HP-5652 guidelines for
utilization of commercial grade items in safety-related applications,
this sequence of procedures provides a basis for dedication.
Training was also initiated, although at the time of the inspection,
general training activities were still being conducted.
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In order to assess the effectiveness of HNP's implemented commercial
grade program, the inspectors reviewed 10 purchase requisition (PR)
packages that were prepared after procedure ACP 1.2-4.2, Revision 0
was issued on June 19, 1988. Only two P0s had been issued in
-
response to these. prs at the time of the inspection. Each of the 10
prs did specify procurement requirements including either receipt
inspection or post-installation acceptance testing. Each PR was
accompanied by a com)1eted form, " Attachment 8.2 Commercial Grade l
Evaluation." In eac1 case, the licensee determined that the new I
equipment constituted a like-for-like replacement. Accordingly, the
inspectors reviewed a completed Attachment 8.1 form, " Substitute
Part/ Component Evaluation," dated January 18, 1989.
k
As might be expected with the beginning of a new program, the 10 new {
PR packages reflected, in some aspects, an incomplete implementation i
of the HNP procedural requirements for commercial grade dedication.
Also, the requirements were underspecified rather than being overly i
prescriptive. Documentation was not complete in all cases; however,
the inspectors concluded that a reasonable effort has been made to
establish an adequate commercial grade dedication program and HNP ,
appears to be well on its way to implementing such a program. .
1
Specific examples of areas where the commercial grade PR packages ,
appeared to be incomplete are as follows: !
1. Like-for-like determinations for which the basis was generally
not adequately documented:
a. prs 10482 and 10486 covered fastener kits and levering-in !
screws for circuit breakers. The basis for like-for-like
determination was stated as Bill of Materials (BOM) package
E-063, which contained only parts lists. There were no
drawings or other descriptions of the breakers or parts to
permit determination of similarity between the list parts
and the parts used in the installed breakers. The BOM
package did reference manuals that contained further infor-
mation, however, and the licensee stated his intention of
sending a letter to the parts supplier (WESCO), requesting
a similarity statement.
b. PR 10400 covered a plastic cell-locating and separating
strip for station batteries. The referenced BOM package
(E-062) contained no description of the part except length
and generic material (" plastic"); there were no drawings.
2. Critical characteristic evaluations (including identification of
safety functions) that were vague and incomplete:
a. prs 10482,10486,and10400(allcitedabove)definedthe
safety function as " failure of the part could affect the
safety-related function of the breaker (or battery)" and
the critical characteristics as "part integrity." These
statements would have been more nearly adequate if the
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p [ .specified acceptance tests thoroughly tested. the replace-
1; ment part, but, as is discussed below, that may not always
, happen. Clearly. definition of safety functions and
critical characteristics is a broad-ranging activity.
"L requiring some judgment. It is also an area that could
- , benefit from expanded procedural and training guidance.-
k _b.. PR 6449 covered ball bearings to be procured for plant.
spares. The safety function was specified as "to provide
shaft support" and the listed critical characteristics were
,
inside diameter, outside diameter, and width.. The parts
% were specified by a particular manufacturer's part number
"or equivalent replacement," and the only acceptance tes-
ting specified was visual inspection for dimensions. .No
app 1_ication information was provided. In this._ case, the
unspecified application and "or equivalent" part specifi-
cation represented vague procurement information that would
require additional evaluation of critical characteristics
and more complete acceptance testing to support dedication
of the parts.
3. Acceptance testing, the acceptance method employed.for all of
.the. packages reviewed (although procedures allow source verifi-
cationasanalternative),andmostoftenimplementedby
post-installation testing, in which it was not clear that the
critical characteristics would be properly verified:
a. PR 10400 for a plastic cell strip for station batteries is
noted above. For a post-installation test, the PR called
i. out procedure SUR 5.5-16, the surveillance procedure for
weekly station battery checks. This procedure checks cell
'
voltage, electrolyte specific gravity, and electrolyte
level. None of these checks are made with the battery
loaded as it would be when performing its safety function,
and seismic excitation, which would presumably be necessary
to verify critical characteristics for such a component, is
not applied in this operational surveillance procedure.
Although the safety function (s) and critical
characteristics of the cell strips were not adequately
defined, they would not be verified by-the checks in SUR
5.5-16. Without complete design information on the parts
and their application, the adequacy of the test was not
established.
b. PR's 10482 and 10486 covering circuit breaker parts are
discussed above. A more elaborate post-installation test
was specified by plant maintenance procedure PMP 9.5-16,
but in the absence of a documented design evaluation, the
adequacy of the test was not established.
c. PP. R09549 (P0 915816) requisitioned pressure gauges for an
et.specified application, and prescribed a post-receipt
calibration. Process fluid temperature, mounting
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, orientation, and other design parameters that could affect
the ability to perform a safety function were not
addressed. Therefore, the adequacy of the test in this' !
instance also was not established.
1
C. Corrective Action on Nonconforming Material and Parts
c A concern was identified during the review of Bechtel Power Corpora-
tion (BPC) purchase order packages regarding the method in which HNP
controls its responsibilities under 10 CFR Part 50, Appendix B,
Criterion XV, " Nonconforming Material, Parts or Components," and
Criterion XVI, " Corrective Action." These criteria require that
measures be established to control items that do not conform to
requirements in order to prevent their. inadvertent use or-
installation, and that appropriate procedures be established and
executed to control identification, documentation, and disposition of
deviations. Additionally, they require. that measures be ' established
to assure that conditions adverse to quality are identified and
co'rrected.
The concern was whether NUSCO, or its designee, BPC is adequately'
controlling deviations and nonconformances which are identified
during procurement activities. . Review of procurement of the new HNP
vital battery and associated components revealed an anomaly in the
method of dispositioning deviations, in particular, the manner in
which they are. closed out. BPC is the licensee's designee for
performing the vity battery modification and associated procurement
activities at the MNP. Identified deviations are. typically
documented on Bechtel's Supplier Deviation Disposition Requests
(SDDRs) which are closed out by a "Bechtel Acceptance / Signature."
Review of several closed-out SDDRs revealed that two categories of
SDDRs may be closed out on the basis of the BPC Acceptance / Signature
alone, even though the deviations have not been completely or
adequately dispositioned. The SDDRs are categorized according to
.whether or not Bechtel engineering accepted the vendor's recommended
disposition of the deviation.
Both categories of SDDRs that were reviewed had been " accepted" by a
BPC signature even though the deviations have not been fully disaosi-
tioned, controlled and corrected in accordance with procedures t1at
meet the intent of 10 CFR Part 50, Appendix B. An example in the
first category was SDDR E-518-2, in which the vendor of a .
safety-related motor control center, in effect, recommended '
acceptance of a nonconforming condition as is. The vendor stated
that, contrary to the P0 requirement for a C0C certifying that
material specifications were met for certain components (including
cable), the vendor could not obtain certified material reports for
any electrical material other than bus supports, bus barriers, and
bus insulators. However, BPC accepted this indeterminate,
l nonconforming condition without documenting an analysis of the
possible adverse effects and/or justification for acceptability of
the material without the requested certifications.
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The other category of improper acceptance consisted of SDDRs for
which the vendor disposition was rejected by BPC engineering, yet the 1
SDDR was still " accepted" by BPC signatures. Examples of these
included: SDDRs E-554-13 (unmarked field wires found on a constant ,
voltage transformer), E-554-14 (poor workmanship in SOLA transformer {
splices, i.e., solid wire leads used solder only for splices), i
E-554-15 (inverter IEEE-650 documentation requirements not met), and
E-554-8 (vendor tests of inverter indicating efficiency less than P0
specification). The BPC disposition appears to have been a recommen-
dation rather than a requirement that the vendor comply with the
specifications which was an insufficient basis for acceptance and
closeout of these SDDRs.
Based on the findings cited above, the NRC inspectors questioned the
effectiveness of Bechtel's (and HNP's) handling of procurement devia-
tions. However, the information available to review during this
inspection was insufficient to define the scope of the problem, and
further review will be required to confirm that deviations in vendor-
supplied components are being controlled, corrected and dispositioned
consistent with HRC regulations. Accordingly, this issue is desig-
nated as Unresolved Item 50-213/89-200-01.
D. Molded Case Circuit Breakers
In light of the NRC's recent inspection findings regarding misre
resented and/or. refurbished molded case circuit breakers (MCCBs)p-,(as
promulgated in NRC Information Notice 88-46 and its Supplements 1 and
2) and licensee actions mandated by NRC Bulletin 88-10, particular
emphasis was placed on this area during this procurement / vendor
interface inspection at HNP. The inspection of this area at HNP
concentrated on the following aspects of HNP's practices regarding
,
(1) Evaluation of procurement and dedication procedures and their
implementation to determine:
(a) fundamental adequacy for assuring quality of replacement
MCCBs for safety-related applications and
(b) effectiveness of the process in identifying misrepresented /
refurbished MCCBs and preventing their use in the plant in
safety-related applications.
(2) Evaluation of HNP's actions in response to NRC Information Notice
88-46, Supplements 1 and 2, and any other correspondence concerning
misrepresented / refurbished MCCBs.
(3) Determination of the status of HNP's actions in compliance with
NRC Bulletin 88-10, including establishing traceability of installed
MCCBs to their original manufacturers, establishing traceability of
MCCBs in warehouse storage, and testing of non-traceable MCCBs.
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1. MCCB Dedication
The NRC inspectors reviewed HNP's program and its implementation
regarding dedication of MCCBs, including procedures, inspection, I
test methods and practices, specifications, and test results, l
and also observed testing of an MCCB procured as a CGI and j
intended for a safety-related application. The MCCB test sample j
was drawn from supplies purchased for the new HNP switchgear
building project. Consistent with HNP's established practice,
these MCCBs, although not receipt-tested, were being tested in
accordance with HNP plant maintenance procedure PMP 9.8-88 prior
to installation. Further tests were to be performed following
installation.
Thefollowingplantmaintenanceprocedures(PMPs)wereincluded
in the MCCB dedication review:
PMP 9.5-41, " Testing of Molded Case Circuit Breakers,"
Revisions 1 (1/7/79) through 6 (8/2/88)(current) which is
used by HNP electrical ma.intenance technicians for routine
pre-installation testing.
PMP 9.8-88, " Testing of Molded Case Circuit Breakers and
Motor Circuit Protectors," Revision 1(12/31/88)(current)
which is used by NUSCO construction electricians for
pre-installation testing of MCCBs for HNP's new switchgear i
building.
FMP 9.5-16, "50DHP-250 Breakers," Revision 10(9/22/88).
SPL 10.8-9, " Testing of Molded Case Circuit Breakers in
AccordancewithNRCBulletin88-10," Original (2/9/98)
which was approved for use by HNP electrical maintenance
l
technicians for testing of untraceable MCCBs in accordance
j with NRCB 88-10, Attachment 1.
l
The routine, pre-installation testing observed was conducted in
'
accordance with the procedures, however, the review of the
procedures revealed that some lacked important tests and some
l acceptance criteria were not included, or were incomplete.
a. PMP 9.5-41, Revisions 1, dated 7/2/79 through 5, dated
7/15/86, included an overcurrent trip test at 300 percent
of rated load, which is normally intended to be a
functional verification of the thermal, inverse-time,
overcurrent trip function of the MCCB. The other test
,
included in these revisions was an overcurrent trip test at
i
1500 percent of rated load, which could be considered a
functional check of the instantaneous magnetic overload
trip. The acceptance criterion for the 300-percent test
was that the MCCB trip within the maximum and minimum
thermal trip times given for various W MCCBs in Table II
on Attachment 2 to the procedure which appeared to have
been photocopied from a W MCCB technical publication. The
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acceptance criterion for the 1500.. percent test was that the
MCCB trip in less than 1 second. {
Although these two tests are important field verification
functional checks, not all critical characteristics neces-
sary to be verified in order to consider an MCCB suitable l
for general purpose or unrestricted application in Class IE q
circuits are verified. The trip times listed in Table II :
applied to certain models of W MCCBs only, and no guidance
was given for other MCCBs. Tfie " Test Procedure" steps
printed beside the tables in Attachment 2 called for the
300-percent test to be done at 77*F (25"C) ambient tempera-
ture, and required the use of test leads of a certain
length, sized according to Table I of the attachment, in
order for the trip times given to be valid. However, there 3
were no mandatory prerequisites or procedural steps that i
required verification and/or recording'of ambient tempera-
ture, or that required test leads to be in accordance with
the attachment. Additionally, the 1500-percent overcurrent
trip test did not include.a requirement to attempt to
reclose the MCCB immediately after tripping to verify that
the thermal trip did not actuate and cause the trip. This
is particularly important since the procedure called for no
waiting time between the thermal and magnetic test for a
given pole and the thermal trip may remain warm from the
300% test. The NRC inspector did note, however, that this
practice.was followed by NUSCO electricians during the
observed testing. !
Other
Nationaltests prescribed
Electrical in industry
Manufacturers standardsNEMA)
Association [(including the
Standard AB 1, the NEMA MCCB field verification guide, (AB
2),andUnderwritersLaboratories(UL)StandardUL-489]and
categorized as necessary for complete field verification
Revisions 1 through 5 of PMP 9.5-41.
.
were not required
Such tests include by(1) manual trip function checks, (2) ;
continuity checks for each pole and any auxiliary switches l
with contacts open and closed, (3) insulation resistance
(IR) checks between phases, from phases to ground, and
open-breakerline-to-load,(4)contactresistance(or
millivolt drop) checks diagnostic of worn, corroded,
pitted, loose or misaligned contacts and/or low contact
pressure,
performance (5) within
complete thermal
design calibration
trip curve to verify (6)
specifications,
verification of no tripping or " hold-in" at 100 percent of
rated load at ambient temperat,ure for the standard minimum
operating times, and (7) magnetic calibration (pulse or
run-up) test of the instantaneous overcurrent trip to
verify proper pickup current values and design trip tines.
Tests of such accessories as bell alarms, shunt trip
attachments, and undervoltage trip attachments may also be
required.
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b. -In' Revision 6 of PMP 9.5-41, dated 8/2/88, HNP incorporated
a test of: phase-to-phase and open-breaker line-to-load IR
g .(Meggering) and also incorporated a phase (equivalent to
contact) resistance test.- However, the procedure still did
not require measuring phase-to-ground IR, either using a
simulated bench ground plane or the actual MCCB enclosure.
It was not evident from completed W0s whether-post-instal-
lation tests included this check. Also, no acceptance
criterion was given for the phase (contact) resistance
- >
test.
!: c. PMP 9.9-88', Revision 1, dated 12/31/88, the performance of
which the inspectors observed, was significantly more
? complete, as it included a much more comprehensive list of
"
thermal trip times, magnetic calibrations, a short time
trip test, a phase-to-ground IR test, and an acceptance
criterion for the contact resistance test. However, it '
,
< still. lacked a hold-in test at 100 percent of rated load.
Note that, depending on the safety function of.the MCCB in a
particular application and the' critical characteristics defined
accordingly, functional dedication tests, such as the hold-in
test at full rated load, would be required'to be conducted under
all expected variations .in service _ conditions (e.g., at breaker
. enclosure full-load operating temperature with loss of air
conditioning and/or ventilation and at minimum and maximum line
,
voltage) in order to verify satisfactory performance of safety
function under all normal design conditions.
Verifying other critical characteristics such as short circuit
current-interrupting capability, requires destructive testing of
a prototype to confirm capability of the design and determine
its susceptibility to common-mode failure (such as may be due to
design defects or overrating). Finally, confirming consistency
of production quality contol and trending the expected rate of
random failure in service often requires destructive testir.g of
a statistical sample of production MCCBs.
Additionally, verifying acceptable performance of the MCCB under
design-basis accident.(DBA) conditions (including seismic and/ot-
agingandharshenvironment)requiresdestructiveorseverely
degrading qualification testing of a prototype for design i
verification against susceptibility to environmentally induced
coamon-mode failure.
Normally, not all critical characteristics are verifiable by
inspection and nondestructive testing alone; and, since the
extent to which destructive testing of samples reliably predicts
performance of an installed MCCB de3 ends on the similarity of
the installed MCCB to the sample, w11ch, in turn, depends, on .
the homogeneity of the production lot of the installed MCCB, i
traceability to the manufacturer is required. Although commer- !
cial grade MCCBs may be manufactured without benefit of a 10 CFR
Part 50, Appendix B, QA program, traceability to the manufactu-
rer's known production QC program is also required to ensure the
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, validity of manufacturers'= certifications of quality and appli- I
cability of testing as well as the validity of evaluations of
design, material, and manufacturing process change history.
.c
Therefore,in addition to testing that was inadequate to verify
all MCCB critical characteristics, another deficiency was iden-
~
tified in HNP's program for dedicating-commercial grade.MCCBs: . ;
"
The' program does not assure the establishment of traceability of j
commercial grade MCCBs to their original manufacturers. As .j
discussed above, this is considered an essential element in an 1
adequate dedication program and the. issue of .MCCB traceability l
l. is also addressed in NRC: Bulletin 88-10. Bulletin 88-10 permits-
'
use of MCCBs in safety-related applications without full
,
,
. traceability if they have been successfully tested in accordance
with Attachment 1 to the bulletin. HNP's actions in response to i
l NRC Bulletin 88-10 were in progress at the time of,the inspection, j
l and are discussed in paragraph III.E.7 below.
!
-'
During the course of the NRC review of commercial grade procure-
.
ments, several safety-related applications of commercial grade 1
MCCBs were identified in which the dedication had been inade-
quate in terms of receipt and testing activities as.well as lack
of traceability. The potential tharefore existed for certain
'
MCCBs of unverified quality to. affect the operability of the-
safety systems in which they were used. Accordingly..HNP
't
initiated an operability determination for the affected systems
and components already thus identified, agreed to prepare justi-
fications for continued operation as required, and assigned
these MCCBs first priority for replacement with MCCBs for which
traceability is established or ones successfully tested in
accordance with Attachment I to NRC Bulletin 88-10.
II. NUSCO VENDOR AUDIT PROGRAM
The inspectors reviewed the licensee's quality assurance (QA) audit
program of vendors of nuclear safety grade materials,. equipment and
services. Vendor audits for HNP are the responsibility of the Procurement
Quality Services _-(PQS) group of Northeast Utilities, headquartered in
Berlin, Connecticut. These audits are performed utilizing either PQS
audits, or QA consultant firms such as Kaiser Engineers, Southwest
Research Institute and Quality Systems, Inc. A review of the 1989 PQS
audit schedule indicated a total of 65 audits were scheduled to be
performed. The results are used to maintain and update the PQS Approved
SupplierList(ASL). The ASL identifies those vendors evaluated by PQS as
having- an approved QA program that is acceptable to the licensee. Vendors
that are conditionally approved or scheduled for evaluation may elso be
included on the list wit 1 appropriate notations. PQS performs annual
evaluations of each of its 212 currently approved vendors. Implementation
of approved and conditionally approved vendor QA programs are verified
initially and every three years thereafter. The approved status of
vendors on the ASL is maintained and based on the results of the PQS
audits and other factors including qualification as an ASME Nuclear ,
'
Certificate Holder, ASME Code Case Register results, NRC inspection
l
9
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reports and generic communications, and the results of the other licensee
surveys.
Additionally, other PQS group activities that contribute to the bases of I
the ASL were reviewed. They included performance of source inspections,
supplier evaluations, comprehensiveness of supplier audit reports, )
accuracy of audit report letters when compared with audit findings, and I
degree of PQS management involvement with its programs. PQS appeared to j
have conducted source inspections in accordance with the PQS inspection .
packages as required. The inspectors reviewed several audit reports and I
determined that PQS paid appropriate attention to detail in the inspection !
attributes that were delineated. Overall, the audit reports appeared i
satisf actory. Discussions with PQS management personnel indicated that
they were very involved and knowledgeable with respect to the specific
activities and goals of the grcup. The PQS group is currently implemen-
ting certain program changes to shift its emphasis to address NRC and
industry concerns regarding fraudulent and substandard components that
have infiltrated the nuclear component supply system. Based on their
review, the inspectors found that the overall effectiveness of the PQS
supplier auditing program appeared satisfactory, based on procedural
review and the above discussions.
III. LICENSEE / VENDOR INTERFACE
A. Processing of Incoming Vendor Technical Information
The inspectors reviewed the licensee's system for receiving,
tracking, and evaluating incoming vendor information. Specifically,
the inspectors reviewed the processing of technical information
received from Westinghouse (W), General Motors / Electro-Motive
Morrision!Knudsen (M-K), the Institute for Nuclear
Division (GM/EMD)(INP0), the NRC, and other vendors of nuclear safety
Power Operations
grade equipment and components for safety-related applications.
The licensee / vendor interface programs at HNP are established by NU
corporate and CY plant-specific procedures. A new CY procedure
providing additional guidance for the review, evaluation, and
recommended disposition of vendor-generated technical information was
implemented January 25, 1989, just before the start of the
inspection. The controlling procedures are:
ACP 1.2-6.14,
ADM 1.1-45, " VendorDatabase
" Relational Information Routing" (RDP)
Processor
Commitment Tracking, Controlled Routings, and Red Folders"
N0P-1.06, "Vice President-Nuclear Operations Commitment Program"
NE0 2.06, " Operating Experience Assessment and Utilization"
N0P-R-2.04, " Nuclear Regulatory Commission Correspondence"
N0P-R-2.02, Operating Experience Assessment and Feedback"
NE0 2.25, " Identification and Implementation of NRC
Reporting Requirements (10 CFR 50.73, and 10 CFR 50.9)"
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Procedures ADM 1.1-45, ACP 1.2-6.14 and N0P-R-2.02 describe those )
items that the plant is primarily responsible for assessing and the )
methods for controlling the processes. In general, the plant is
assigned
system' vendor ~ the(Westinghouse
responsibility)for assessing
bulletins all nuclear steam
and plant-specific vendorsupply
issues not screened by the NUSCO Nuclear Safety Engineering Section
in Berlin, Connecticut. This encompasses all Westinghouse Technical ,
Bulletins and the majority of other vendor correspondence applicable l
to the site. The guidance for performing these evaluations and {
developing recommendations was just recently formulated in the newly
implemented procedure ACP 1.2-6.14 (January 25,1989). Before this .
procedure was issued, all evaluations and resulting recommendations J
were performed informally in accordance with procedure ADM 1.1-45 for
'
controlled routings.
NUSCO is responsible for evaluating NRC, INP0, 10 CFR Part 21, and
generic industry notifications. As required, the HNP personnel
support the corporate staff in their evaluations and resulting
recommended actions. The procedures listed above provide guidance
for performing these activities. Although the corporate program
appeared to be properly formalized, the plant evaluation process
lacked formal guidance until the recent implementation of procedure
ACP 1.2-6.14, " Vendor Information Routing."'
Implementation of procedure ACP 1.2-6.14 was a good first effort to
formalize a program at the plant; additional changes may be needed,
however, to include in the procedure minimum qualifications for
engineers' evaluating the information as well as the requirements
against which the information should be reviewed (plant design ,
basis). In spite of the lack of a formal program at.the site, plant
personnel were able to demonstrate that, in most instances, adequate
evaluations were being performed. Some notable exceptions of plant
and corporate evaluations are described in the sections that follow.
B. Vendor Technical Information
The inspectors reviewed approximately 50 vendor issues to determine
the adequacy of the screening and assessment process. The vendor
issues included those identified in Westinghouse Technical Bulletins
and letters, NRC information notices, incoming 10 CFR Part 21
notifications, INP0 Significant Operating Experience Reports (SOERs)
and other vendor issues. Additionally, the Power Pointers (PPs) and
Maintenance Instri.ctions (mis) from GM/EMD and/or M-K were reviewed.
During this review the inspectors found that out of approximately 82
PPs and 41 mis, only six of the issues covered in them had received a
formal documented screening and evaluation for their applicability to
HNP. The inspectors found that the licensee had established a formal
interface program only with Westinghouse (W). The licensee had not
established a formal interface program for receiving technical
correspondence from the Class 1E electrical switchgear and emergency
diesel generator (EDG) suppliers on a regular basis. In addition,
the licensee has not established a program for periodic informal
contact with vendors of other key safety-related plant equipment and
components.
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The lack of a formal interface arogram with the EDG vendor, M-K (and
+
previously GM/EMD), coupled wit 1 the lack of a site-level' procedure
for handlir(incoming vendor information, most likely led to the
licensee's. failure to evaluate the PPs and mis for HNP applicability.
C. Nuclear Steam Supply System (NSSS) Vendor Interface
The NRC inspectors reviewed a sample of the licensee's screening and
evaluation ~of Westinghouse technical bulletins (tbs) and letters.
' Issued by W Nuclear Services Integration Division (NSID), these
l' communications generally describe problems experienced at W plants .,
L -and recommend corrective actions that may be applicable to other {
l- plants of which W was-the NSSS vendor.- The inspectors identified the l
-following tbs, in which the HNP evaluations'and/or disposition were ;
found to be inadequate and/or incomplete:
1. Westinghouse Technical Bulletin TB-86-07, " Auxiliary Pump 1
1 Assembly Hold Down Bolting Requirements," described instances in -;f
which safety-related auxiliary pumps hold-down bolts were made i
from different materials.than are specified in the design 4
documentation. W recomended that if hold-down bolts were of
.the wrong material or of indeterminate material, they should be i
replaced with the minimum acceptable material needed to meet the '
equipment seismic qualifications.
-In the initial screening, licensee personnel identified 44 pumps
at the HNP that needed to be investigated.because the bolts were
of potentially indeterminate material. A spot check of a few
pumps by the licensee showed that the hold-down bolt material
was not as specified and the actual bolts were unmarked. Since
it was felt that this was not an NRC issue, no further action
was taken and the Controlled Routing'(CR) Acti , was closed out
in July 1987.
The reasonableness of this action was discussed with the
licensee during the inspection. The NRC inspectors felt that
the seismic qualifications of the affected equipment may be ,
questionable and further review by the licensee was needed.
Plant personnel subsequently reopened this issue and committed
to the following actions until the specific bolting requirements
are known:
a. The PMMS database information for the affected pumps would ,
be modified with the following statement:
PUMP AND DRIVER HOLD DOWN BOLTS MUST BE INSPECTED AND
MEASUREDTHENEXTTIMETHEUNITIS00S[outofservice]FOR
AN EXTENDED PERIOD OF TIME. CONTACT ENGINEERING FOR
FURTHER INFORMATION.
(CR 89-155 was issued to the HNP mechanical maintenance depart-
ment to track this effort.)
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b .. Once the bolt size and length is detennined, any standard l
size bolt would be replaced ~with a traceable bolt of a
'
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material to be determined by the HNP. station engineering I
group. Odd-sized, special-order bolts would be ordered and
replaced as parts and equipment become available..
.(CR 89-156 was issued to the engineering group to track this -
effort.)
- 2. Westinghouse Technical Bulletin TB-86-08, " Post-LOCA Long. Term ,
Cooling: Boron Requirements," described a problem in which
during certain accident conditions, the emergency core cooling- ]
systems. (ECCS) may. spray / inject unborated water. into the-
'
containment and reactor vessel. During this phase .of emergency
injection, the boron concentration may decrease ~enough for the
reactor to again become critical. W recomended that plants ,
perform an analysis to determine the minimum boron requirements
necessary to maintain the reactor subcritical with all rods out
and no. xenon present, for the most reactive time in core life.
Once this is calculated, all sources of unborated water that
,
would or could be injected into the reactors during a
loss-of-coolant accident (LOCA).should be' identified to
determine if the potential exists for the reactor to go critical'
again. If this can occur, plants need to. adjust boron
concentrations or take other action to mitigate this event as
'
well as revise the plant emergency operating procedures (EOPs).
Initial evaluations by NUSCO personnel indicated that unborated
water would be injected into the reactor vessel via~the contain-
ment spray system during certain accidents while executing the
E0Ps. Boron concentration would be reduced from 2200 ppm to
2000 ppm within 3.3 minutes. HNP requested NUSCO to assist in
resolving this issue, rather than changing the actions' developed
for the E0Ps. In December 1988, the problem still had not been
resolved, and NUSCO had not performed any analysis to justify
.
the actions in the E0Ps. At this point, HNP decided to close
out the issue without any further action based on the plant
design basis for the containment.
This evaluation was inadequate because the E0Ps are intended for
use outside the plant design basis and are written with the
understanding that operator actions, in some instances, inten-
tionally take the plant outside the design basis to eventually
stabilize conditions. The inspectors discussed these-concerns
with the li:ensee, and plant personnel committed to reopen and
resolve the issue in a timely manner through initiation of a
Controlled Routing Action Plan.
3. Westinghouse Technical Bulletins TB-83-02 and 83-03. W
TB-83-02, dated April 24, 1983 recommended a comprehensive
maintenance and testing program for DB-50 reactor trip breakers
(RTBs) that would give new special attention to the undervoltage
trip attachment (UVTA) including: (a) a revised lubrication
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procedure and reconnended lubricants, (b) a special UVTA manual l
-
test, and (c) cycling' the UVTA 10 times and the shunt trip
attachment (STA) at least once. TB-83-03 called for separate
independent-functional verification of the UVTA and STA.
Revision 1 of TB 83-02, September. 13, 1983 corrected and
expanded the lubrication procedures and lubricants and estab-
lished a 200-cycle lubrication interval for the.VVTAs. On the
basis of recent W testing, Addendum 1 to Revision 1, of
TB-83-02,' dated November 29,1983,' established a 1250-cycle UVTA
lifetime and forwarded lubrication kits to customers.
Revision 5 of plant maintenance. procedure PMP 9.5-23. " Preven-
tive Maintenance of Reactor Trip and Isolation Breakers," dated
July 17, 1983 only incorporated the UVTA lubrication provisions
of TB 83-02. Revision 5 of PMP 9.5-40 " Periodical Functional
Test of RTBs, also dated July 15, 1983, incorporated the
provision of TB 83-03 requirement to test the UTVA and STA
independently, and also incorporated the lubrication provisions
(generally) of TB-83-02. However, CY memorandum PMSM-83-198,
dated July 12, 1983, reconnended closeout of Controlled Routing
(CR)83-418dealin
(inappropriately) g with
that the TB-83-02 and
CR dealt with -03,(83-03
83-02 statingwas not
mentioned),andconcluding: "We have reviewed this bulletin and
made one or two minor changes to our: procedures. These
revisions have been approved by the Plant Operational Review .
Connittee ,(PORC) and no further action is planned. This CR !
should therefore be closed out." This constitutes an inadequate
review and disposition of the CR because not all of the
provisions of the'W technical bulletins had been addressed
~
and/or incorporated in the procedures.
Revision 8 (major) to PHP 9.5-23, dated May 6,1985, first
incorporated the special manual UVTA test prescribed in TB 83-02
and also the expanded and revised detailed lubrication provi- l
siens of TB 83-02, Revision 1, and the life-cycle information of
Addendum 1.
Revision 6 of PHP 9.5-40, dated February 24, 1984, incorporated
the requirement of TB 83-02'to trip the DB-50 ten times by
deenergizing the UVTA, referencing TB 83-03 and Revision 1 of TB
83-02. However, the procedure deviated from the technical
bulletin in that the 10 cycles of the UVTA were prescribed to be
done in conjunction with tripping the RTB with the STA device as
well. This practice is still reflected in the current revision
(Rev. 8) of PHP 9.5-40. According to the information available
to the NRC inspectors during the inspection, the intent of the
10 UVTA trips was not merely to exercise the UVTA but to confirm i
lack of binding following multiple operations as had been
observed in post-ATWS testing of RTBs at Salem. However,
according to reactor protection system (RPS) diagrams, confirmed
by HNP personnel, and as implied by licensee submittals pursuant
to NRC Bulletin 83-01, the RPS logic at HNP differs from the
standard W design in that both the STAS and the UVTAs act to
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. trip the RTBs on an automatic reactor trip signal as well as a
manually initiated trip signal. This would suggest that
10-cycle testing of the UVTA independently is not as critical at
HNP, but this matter needs to be clarified. HNP agreed to
cbtain clarification of this pnint from W NSID.
D. Emergency Diesel Generator Interface
The two emergency diesel generators (EDGs) 2A and "3 for the HNP were
manufactured by General Motors / Electro-Motive Division (GM/EMD), and
installed in 1975. The engines, Model 20-645E4, are designed for
2-cycle operation, are turbo-charged, have 20 cylinders in a "V"
arrangement, and are rated for 2850 KW at 900 rpm. Since
installation, each engine has accumulated about 850 hours0.00984 days <br />0.236 hours <br />0.00141 weeks <br />3.23425e-4 months <br /> of
operation. Until late 1987, the licensee had dealt directly with
GM/EMD for service information and assistance, and for spare and
replacement parts. Since that time, the Morrision-Knudsen Company
(M-K) has served as the exclusive authorized distributor for sales,
service, and replacement parts for GM/EMD stationary EDGs, including
those at HNP. Up to the time of the inspection, no formal structured
system had been establir,hed on site to process information provided
by the vendor for service and operational recommendations for the
EDGs. This situation is expected to change as a result of the
issuance, on January 25, 1989, of HNP's new procedure for evaluating
and tracking the disposition of this type of vendor information.
1. Review of EDG Manuals and Procedures
The inspectors reviewed the following manuals applicable to the
emergency diesels:
"EMD 645E4 Engine Manual," GM/EMD Turbocharger Engine
Maintenance Manual, 2nd Edition, August 1967; revised
February 1972; contains Section 0-14
" Turbocharger Engine, 645E4B, Maintenance Manual," GM/EMD,
1st Edition, November 1979; contains Section 0-15
" Operating Manual, 999 System, Generating Plant," Model
999-20, CYAPCo, October 1969, contains Woodward Bulletin
37708C, "EG-BIO Hydraulic Actuator"
The licensee stated that the EDG operating and maintenance
manuals at the HNP are uncontrolled, but the appropriate
procedures are controlled. Although GM/EMD had issued service
information since the manufacture of the diesel engines in the
formofPowerPointers(PPs)andMaintenanceInstructions(mis),
it was apparent that the licensee had not incorporated any of
this information into the manuals by pen-and-ink changes, as is
recommended by the vendor. Examples of revised information for
which licensee could show no evidence of evaluation and
incorporation into the manuals include mis 926 (Rev. F), 927
(Rev. E), 174B (Rev. D), 1757 (Rev. D), 1760 (Rev. G), and 9660.
_ _ _ _ _ . _ _ _ _
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Mc 6 Allsthese mis were issued subsequent to November.1979 and
i therefore are not included in..the most recent maintenance.
9~ manual. .The manuals governing the operating and. maintenance
activities for the EDGs therefore,.'are not considered to be
i. up-to-date.. In fact, the first-listed manual above is obsolete
and was superseded by the second-listed manual. The licensee
stated-that major maintenance and design modifications regarding ,
the EDGs are performed under.the direction of an EMD or M-K- !
technical representative.
.The licensee has prepared and issued procedures to govern.the
maintenance, testing, and operation of EDGs. .The licensee
'
'
states that these procedures are updated in a controlled manner
so that they.can be relied upon as the authoritative source of
the most recent information for plant personnel. The inspectors
included the following plant maintenance procedures (PHPs) for i
the EDGs in their review:
PMP 9.5-90, " Maintenance of Emergency Diesel Air Start
>
< Motors #1, 2, 3, 4"
PMP 9.5-43, " Emergency Diesel Cooling Water Heat Exchanger"
PHP 9.5-36, " Inspection and Preventive Maintenance of the !
Emergency Diesels"
All of these procedures referenced the uncontrolled vendor
manuals. The latter procedure also referenced mis 1742, 3327,
and 4523, but the latest revision of each of these mis was not
indicated in the procedure. The inspectors concluded that
because these revisions were not. indicated, the procedures also
were not maintained in an up-to-date condition.
,
2. Review of GM/EMD PPs and mis
The licensee could not provide documented evidence that it had
received and evaluated all the PPs and mis applicable to the
HNP. Although the licensee did produce some of the PPs and mis
received from GM/EMD, no assurance could be given that all such
vendor information had been received. The licensee took the
necessary steps to obtain a complete set of all such documents
from the M-K and, in fact, the complete set was received on
February 6,1989, while the inspection was still in progress.
, The. license committed to review all this information and-
document the disposition of each vendor recommendation
applicable to the HNP EDGs using new procedure ACP 1.2-6.14
.
" Vendor Information Routing." This procedure creates a Station
Technical Bulletin Coordinator (STABC) who will maintain a log j
of all such information inputs, ensure that affected department
- heads review the information for applicability, and ensure
L implementation as a necessity. The licensee's processing of
future EDG PPs and mis will be governed by this new procedure.
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The inspectors reviewed a . list of major EDG changes recomended
by M-K and referenced in various PPs and Mls. .The inspectors
'
alsoreviewed17HNPPlantDesignChangeRequests(PDCRs)to-
determine if they. had incorporated-any of the PPs and mis.
PDCR-416 addressed six major corrective actions and recomenda-
tions promulgated in PPs and mis, but no other records were
available to demonstrate.that PPs.and mis had been considered
for implementation._ Nevertheless it was evident from review of
the various EDG procedures, that many of the PP and M1 recommen-
dations had been incorporated.
l
3. EDG. Modifications-
'
The inspectors reviewed records of a number of other modifica-
tions that the licensee had made to the EDGs including the '
following: j
_
a. PDCR 487: Added' local frequency and kilowatt meters.
b. PDCR 598: Replaced air compressors C-14-1A and 18.
'
c. PDCR 312: Changed the loss-of-voltage. trip initiation logic
to two-out-of-three logic.and undervoltage protection.
d.- PDCR 304: Modified Alarms. ,
e. PDCR 221: Installed the starting air system cross-connect
..line.
f. PDCR 118: Modified starting air system piping,
g. PDCR 785: Diesel start system upgrade (filters)
No problems were identified with these completed modifications.
4. Training
The inspectors reviewed the licensee's practice regarding the
use of its personnel.for performing maintenance and' service
activities on the emergency diesel generators. The approach
. utilized is to perform the routine maintenance, service, and !
preventive maintenance activities with HNP personnel. For major i
maintenance or overhaul activities,' assistance was originally
contracted from GM/EMD and currently from M-K. EDG technicians
at HNP are trained by NUSCO personnel at NU's EDG training
center located at the Millstone nuclear power station. The
NUSCO instructors receive their training by attending courses
given by the vendors, including GM/EMD, M-K, and the Woodward
Governor Company. Used and spare equipment items serve as
.
training aids. The EDG training program is relatively new at
HNP, but its objective is to maintain a minimum of five EDG i
maintenance technicians at the "Q-level (qualified level). At !
the time of the inspection, three HNP personnel had achieved the
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'"I"-level (intermediatelevel)ofqualification'asEDG .
I
technicians; however, none were. qualified at the Q-level.
The curriculum also included use of-event reports and defect
reportssuchaslicenseeeventreports(LERs),NRCinformation-
notices and bulletins,10 CFR Part 21. reports, and. INPO Safety
Evaluation Reports-(SERs) and Significant Operating Experience o
. Reports (S0ERs) to keep personnel apprised of current EDG (
problems and solutions. l
"
\ ~5. . NRC'Information Notices Affecting.the EDGs
H The inspectors reviewed the licensee's records regarding the
receipt, evaluation,.and implementation of emergency diesel-
'
generator' design and operating experiences as described in NRC' !
'informationnotices(ins).: The inspectors reviewed the records
'
.
for 10 of'the most recent ins and found,that,all had been ,,
addressed and implemented as necessary. In the case of ins !
87-42, 86-07, and 84-69, the licensee had implemented procedural i
changes to correct for conditions' described in these notices.
In the remaining seven instances, the conditions either did not
apply _ to HNP, or they had previously been addressed. The .
inspectors found the licensee'.s handling of_ NRC ins involving
the EDGs to be acceptable. !
6. Procurement of Spare'and Replacement Parts for EDGs
The Material, Equipment, and Parts List.(MEPL) (described in
-Appendix.B_of this report) stated that the EDGs and station
batteries are classified as QA Category I, i.e., safety-related,
and are relied upon as the only sources of _ safety-related
station power. However, individual parts of the_EDGs are not
' listed separately in the MEPL, but rather they are listed in the
bill of material associated with each EDG drawing. _The licensee-
is presently in the process of determining which parts are to be
categorized as safety-related and which are not. Any piece /part
of the diesel engine driver.whose failure could cause a reduc-
tion in power output or a complete loss of. the engine will be
classified as QA Category I. The HNP Maintenance Department
established criteria for the initial determination and has done
the first screening. The initial selections will then be
finally categorized according to the " Spare Parts Evaluation >
Check List" and the " Piece /Part QA Determination" which are-
attachments to ACP 1.2-2.1. This appears to be a'significant
step in upgrading the procurement of spare and replacement parts
for the EDGs. ,
E. Incoming 10 CFR Part 21 Reports and Vendor and NRC Correspondence l
The inspectors reviewed several evaluations of 10 CFR Part 21 reports j
snd vendor letters to determine whether the licensee had taken appro- 4
priate action. Some of the letters sent to the licensee were not
specifically identified as 10 CFR Part 21 notifications, but involved
issues that would have an effect on plant safety. These letters ;
.
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however, did alert the licensee that the issues should be asses ed
for potential effect on the plant. The inspectors also reviewed
selected licensee assessments of HRC correspondence possibly affec- ;
ting equipment at HNP. l
1. Valcor Engineering Corporation sent a letter, dated April 16,
1986, to NU notifying them of instances in which valves with
17-7PH stainless steel springs f ailed af ter a year or two of ,
service in pressurized water reactors (PWRs). The valves were j
exposed to reactor coolant water above 440*F, and apparently the ;
spring failure was caused by hydrogen embrittlement. The
licen"e determined that valves using this spring material were
in se ice as reactor head vent and pressurizer vent valves at
HNP. A substantial safety hazard evaluation was performed and
identified the potential for these valves to fail, but minimized
the importance of their function. Specifically, the evaluation
stated the head vent valves are beyond the design basis of the
plant and minimized the importance of these valves in providing
an isolation function.
These valves were installed as part of the Three Mile Island
'
action plan to vent off hydrogen following a small-break loss-
of-coolantaccident(LOCA). The valves perform an important
safety function and must operate in the closed direction as
well, so as not to cause a LOCA. Subsequent review by the
licensee did identify their importance as evidenced by a
September'10, 1986, internal memorandum that stated, in part:
"These failures will not produce an SSH, but are unacceptable
based on common sense engineering judgement." The licensee has
since replaced the most susceptible valves and will replace
other valves during the next outage. However, corrective action
,
would have been taken in a more timely manner had the SSH
[ evaluation appropriately addressed the significance of these
valves originally.
2. A 10 CFR Part 21 notification was issued by Gamma-Metrics (G-M)
-
on February 22, 1989 concerning defective solder connections in
the cable conduit assembly on the excore neutron flux detectors.
The licensee had several internal memoranda and other correspon-
dence on file regarding the G-M 10 CFR Part 21 notification, but
it had not been entered into the vendor information routing
sy stem. According to a record of an April 8, 1988, telephone
conversation on this subject between NUSCO personnel, HNP has no
G-M cable assemblies on site because 'ts excore neutron detector
system is not yet installed. In a letter from G-M to HNP, dated
April 7, 1988, that was in the file, G-M stated that the fabri-
cation process that caused the problem had been corrected and
also committed to deliver cable assemblies to HNP that are free
of any known defects. However, it was not clear from the
correspondence on file whether the cable assemblies to be
shipped to HNP were of the modified design described in the
updated 10 CFR Part 21 letter from G-M, dated May 10, 1988. The
inspector expressed the concern to the licensee that, although
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. the soldering process had been corrected, the modified design
had not yet been satisfactorily environmentally qualified. The
licensee agreed to obtain clarification from G-M on this point
prior to installing the new cable assemblies in the plant and
acknowledged the need to ensure that the system be fully quali-
fied before it is required to be placed in service per HNP's
NRC-approved, Regulatory Guide 1.97 implementation schedule.
3. Two 10 CFR Part 21 reports issued by M-K potentially affecting
the GM/EMD 20-645E4 Type 999 EDGs at HNP were reviewed by the
inspectors. The licensee had received these reports (dated
February 14, 1985 andOctober5,1988),evaluatedthem,and
appropriately dispositioned them to address the issues.
The report of October 5, 1988, described the unexpected opening
of the 100-ampere General Electric field circuit breaker for the
EDG at the Browns Ferry plant, thereby tripping the diesel. It
was determined that the circuit breaker rating and associated
wiring were marginal due to the high ambient air temperatures.
The 10 CFR Part 21 notifications recommended that the circuit
breakers and wiring be upgraded to preclude the problem. As of
the time of the inspection, the licensee had evaluated the
10 CFR Part 21 report and decided that the corrective action
should be performed at HNP. Controlled Routing Action Plan
sheets, dated December 9, 1988 and December 30, 1988, had been
initiated -to perform the upgrade and track the modification
until the breakers are replaced.
4. NRC IE Information Notice 84-83, "Various Battery Problems,"
discusses potential concerns with batteries. Among the most
significant are solvent-induced case cracking and the cumulative
effect of a number of small loads added to the DC bus over an
extended period of time.
An inspection of the batteries and their associated areas did
not identify any cracks in the battery cases or conditions that
could introduce hydror.arbon-based grease or solvents to the
battery cases (e.g., painted racks, grease on terminals,
procedures allowing cleaning without cautioning personnel not to
use hydrocarbo.n-based cleaning compounds). Discussions with HNP
maintenance personnel indicated that only HNP electricians are
allowed to perform any work activities on or around the
batteries.
The cumulative loading of the HNP batteries appears to be
controlled by four NUSCO procedures: NE0-3.03, " Preparation,
Review and Disposition of Plant Design Change Records";
NE0-5.05, " Design Input, Design Verification, and Design Inter-
face Reviews"; NE0-5.06, " Preparation, Review and Approval of
Design Analyses and Calculations"; and NE0-5.11, " Design Change
Notices for Design Documents." An actual verification by means
of reviewing all of the loads added to a particular DC bus for a
certain period of time was not attempted due to time
_- __
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constraints. However, HNP is currently installing a new, larger
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capacity. emergency DC power supply system including batteries,
DC chargers, inverters, motor control centers, and related buses
and hardware. The HNP actions and disposition of the various
' potential battery problems appear to have been satisfactory.
,
5. NRC' IE Information Notice 85-74, " Station Battery Problems,"
discusses several deficiencies involving the maintenance and.
operation of station batteries that were found to be generic to
many sites and attributable to a variety of causes.
Discussion.with HNP station personnel and review of applicable
documentation indicated that a satisfactory action plan was
established to control the potential deficiencies. The dis-
position included revisions to station surveillance test pro-
cedures as noted on CY Memorandum CR 85-1257, dated September 23,
1986.
6. NRC Information hotice 88-04, " Inadequate Qualification and
Documentation of Fire Barrier Penetration Seals," discusses a
potential problem with the fire barrier penetration seal
as-built configurations being less conservative or having no ,
correlation to applicable fire barrier configuration qualifica-
'
tion test reports.
The inspec. tor determined that HNP has noted numerous problems in
this area. As an example, CY internal memorandum EN-88-187,
dated February 26, 1988, states,.in part: "CY is not in a good
position to defend the adequacy of our insta11cd penetration
fire seals. The major reasons for this include: (1) Lack of a
complete, technically sound, penetration fire seal qualification
package and (2) for several years our installation inspection
procedures did not provide for review of modifications to
existing seals to ensure that the modifications did not affect
the seal qualification. Recently, our procedures were revised
to require engineering review prior to the seal installation or
modification, but the technical information on fire seal
qualification parameters and limiting conditions still is not
available. In sumary, we still do not know what we.are limited
in doing with our fire seals or whether we have stayed in
compliance with the qualification tests...." HNP subsequently
conducted discussions with the NRC's Chemical Engineering Branch i
L (NRR) regarding this issue, and committed to perform a fire
barrier walkdown to identify the scope of its problem.
'
CY LER No. 050000213/89-001-00 described a nonconforming barrier
that was identified by the licensee during a walkdown, stating i;
that a supplemental LER would be issued at the completion of the '
fire barrier walkdown. Therefore, it appears that HNP should
have issued an LER under 10 CFR 50.73 in February of 1988.
However, HNP did discuss the issue with NRC personnel and
implemented measures to review the adequacy of the installed
)
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7. NRC Bulletin 88-10, " Nonconforming Molded Case Circuit 4
Breakers," requires licenseet to identify all MCCBs procured
for use in safety-related applications. Those for which
verifiable traceability to their manufacturers cannot be estab- l
lished are to be removed from service or from availability for t
service until they have been tested successfully in accordance !
with Attachment 1 to the bulletin. After receiving Bulletin
88-10, HNP identified 113 MCCBs in safety-related applications
and in stores, but were not able to establish traceability for
them using documentation available on site. HNP's planned
course of action was to contact the suppliers and manufacturers
of these MCCBs and attempt, to the extent possible, to obtain
such documentation. Concurrently with this task, HNP intended
to proceed with testin i
procedure (SPL 10.8-9)g MCCBs in the warehouse, using a newapprov i
by the HNP Plant Operational Review Committee (PORC) for testing
MCCBs in accordance with Attachment 1 to Bulletin 88-10. Those
spare MCCBs that passed the tests were to be used to replace the
untraceable MCCBs installed in plant safety systems. HNP's
commitments regarding inadequately dedicated coninercial grade
MCCBs installed in safety-related applications that were
identified by the NRC during this inspection are discussed in
paragraph II.D in the section of this report dealing with MCCB 1'
dedication.
8. NRC Information Notice 88-46, " Licensee Report of Defective
Refurbished Circuit Breakers," identified types of NCCBs (and
some other components) that were potentially fraudulently
refurbished and defective as well as identifying several sources
and intermediate suppliers. The disposition of IN 88-46 was
tracked under the licensee's N0A No. 9684, dated August 12,
1988. According to CY memorandum EN-88-845, dated October 12,
1988, HNP's actions in response to IN 88-46 consisted of a
review of purchasing records back to 1985. HNP concluded that
no new equipment listed in Attachment 2 to the information
notice was purchased from any suppliers listed in Attachment 1
although some items listed in Attachment 2 were purchased f rom
other suppliers. The same memorandum also described HNP's
disposition of Supplement 1 to IN 88-46, stating that the HNP
purchase orders referenced in the supplement (issued to a
supplier not listed in IN 88-46) were reviewed and the suspect
material in the warehouse (45 items) was held under nonconformance
report RC-88-166 pending resolution of the issue. However, HNP
determined that five reversing starters and one overload relay
had been previously drawn from the warehouse. An initial search
indicated (but did not confirm) that the six items were used in !
non-safety-related applications. The memorandum also stated
that HNP evaluated its maintenance practices and concluded that
although the station test and inspection procedures were not
intended to detect fraudulent / refurbished MCCBs, the procedures
would adequately screen out defective MCCBs. At the time of the
inspection, HNP was still evaluating IN 88-46, Supplement 2, in ,
conjunction with the disposition of Bulletin 88-10. The NRC '
inspectors' evaluation of HNP station MCCB testing is included
in paragraph I.D.3 of this report.
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APPENDIX A !
PERSONS CONTACTED
A. Connecticut Yankee Atomic Power Company
4
W. Romberg, Vice President Nuclear Operations
- D. Miller, Station Superintendent
- G. Bouchard, Unit Superintendent
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- E. Debarba,. Station Services Superintendent ;
- C, Gladding, Engineering Supervisor
- E. Nichols, Senior Engineer
T. Dente, Nuclear Operations Supervisor, NUSCO '
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B. Moyer, Material Supervisor
- D. Nordquist, Director, Quality Services Department, NUSCO
- D. McCory, Manager, Procurement Quality Services, NUSCO
- * P. L'Heureux, Engineer l
D. Ray, Oparations Supervisor
- S. Dates, Licensing, NUSCO
G. VanNoodenner, Licensing, NUSCO
- B. Danielson, Maintenance Supervisor
- R. Caminati, Assistant Maintenance Supervisor
W. Ventres, Assistant Maintenance Supervisor
R. Rogozinski,, System Engineer
T. Mcdonald, Technical Traning Supervisor
G. Winters, Senior Technical Trainer - ,
J. Delawrence, In Service Inspection (ISI) Engineering
J. Calderone, ISI Engineering
L. Lebaron, Engineer
J. Stanford, Operations
R. Willis, Shift Supervisor
G. Andrews, Materials Engineer
M. Surprenant, Procurement Vendor Services Supervisor, NUSCO
J. Coleman, Procurement Inspection Services Supervisor, NUSCO
T. Mulder, NUSCO Engineering
R. Kasuga, Engineer '
J. Paris, QC Technician
M. Etre, Engineer
G. Pitman, Electrical Manager
T. Clark, Engineer
G. Tylinski, Assistant Engineering Superivsor
K. Murphy, QSD Auditor, HUSCO
S. Wainio, Senior Engineer
- D. Maret, NES
- M. Marino, NUSCO Nuclear Operations
- J. Festa, NUSCO, Instrument and Control (I&C) Engineer ;
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- J. Quinn, Millstone Unit.1, Engineering
- G. McNatt, Millstone Unit 2, Engineering
- W. Richter, Millstone Unit 3, Engineering
- T. Galloway, I&C Supervisor
- J. Beauchamp, NUSCO,. Quality Services . Supervisor
R. Gill, Security' Supervisor
P. Jewett, Security
J. Miskimen, Maintenance
B. Nuclear Regulatory Commission
- E.Brach, Chief,VendorInspectionBranch(VIB),NRR
- L. Dettenhausen, Chief,' Project Branch #1, Region I
- V. Potapovs, Chief, Reactive Inspection #2, VIB
- A. Wang, Project Manager, NRR
- J. Shedlosky, Senior Residnent Inspector j
- A. Asars, Resident Inspector J
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- Attended exit meeting
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APPENDIX B
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' PROCUREMENT PROCESS AND PROCEDURES
The procurement of material, equipment, and services at Connecticut Yankee
Atomic Power Company's -(CYs) Haddam Neck Plant (HNP) is governed by the
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procedures listed below. When the need for procurement of material or services
is identified, the cognizant HNP engineer will have a purchase requisition (PR)
prepared listing all technical and quality assurance (QA) requirements. The
requisition is then reviewed and approved by the appropriate department head
with QA concurrence. Any engineering evaluations that are required are
prepared by the onsite engineering support organization. The
department and the Procurement System Quality Assurance (PSQA)
group purchasing
under the
Northeast Utilities Service Company (NUSCO) headquartered at the Northeast
Utilities (NU) corporate offices in Berlin, Connecticut review and approve the
procurement requirements and the selection of the vendor and the purchasing
department generates a formal CY purchase order (PO) for dispt ch to the
' vendor.
It should be noted that materials, equipment, and services (including replace-
ment components and " piece-parts") used or applied to safety-related systers
are subject to the requirements of 10 CFR Part 50, Appendix B, for quality
assurance (QA), and of 10 CFR Part 21. " Reporting of Defects and
Noncompliance." It should also be noted that the'e s requirements apply to
facilities licensed under 10 CFR Part 50, regardless of the original basis or
quality assurance standard under which the facility was constructed.
A f acility licensed by the NRC under 10 CFR Part 50 may choose to procure
parts, equipment, or services for safety-related applications from vendors who
lack a.10 CFR Part 50, Appendix B, QA program under which to supply parts
certified to be nuclear safety-related. However, the facility must then
institute its own measures to ensure that the prccured materials are of
adequate quality and capability to perform their safety-related functions under
normal service, seismic, and harsh environmental conditions as required.
The licensee has prepared a master equipment list of safety-related HNP
components. It consists of four volumes of documentation and is entitled,
" Connecticut Yankee; Quality Assurance; Material, Equipment, and Parts List"
(MEPL). Revision 4, dated August 26, 1988. Preparation and updating of the
MEPL is controlled by procedure ACP 1.2-2.1 " Material, Equipment, and Parts
List for In-Service Nuclear Generation Facilities." The procedure provides
identification of safety-related, (HNP Category I), structures, systems, and
components that fall under the auspices of the CY Quality Assurance Program in
compliance with 10 CFR Part 50, Appendix B. The MEPL contains specific
criteria for determining whether an item of plant equipment is categorized as
safety-related, and covers mechanical, electric and instrument and control
systems.
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c In'the course of inspecting the HNP procurement and dodication program and its
implementation, the NRC. inspectors reviewed the following CYAPC0/HNP
administrative control procedures (ACPs):
ACP 1.2-2.1, " Material Equipment Parts List," Revisions 9 (5/85), l
10 (1/86), 11 (7/86), 12 (7/87), and 13 (1/89)
" Classifying and Upgrading Spare Parts," Revisions 3 (4/85),
ACP 1.2-2.5,(8/66),
4 (7/86), 5 and 6 (11/87)
ACP 1.2-4.1, " Procurement Document Review," Revisions 14 (2/85),), and
15(11/85),16(8/86),17(2/87),18(4/87),19(9/87),20(3/88
21 (1/89)
ACP 1.2-4.2, "Comercial Grade Procurement / Upgrade and Dedication,"
Original (6/88)andRevision1(1/89) {
ACP1.2-4.3,"SubstitutionofSpareParts," Original (7/88)
ACP 1.2-7.1, " Receipt, Inspection and Identification of Materials, Parts
and Components," Revisions 15(1/85),16(7/85),17.(9/85),18(7/86),and
19(2/87)
The overall HNP procurement process is governed by procedure ACP 1.2-4.1
" Procurement. Document Review." Thisproceduredefinesprocurementlevels(PLs)
"A," "B," "C," and "D," depending on the nature of the purchased commodity, and
its intended use or availability for use in the plant.
PL-A is prescribed for procurement of " engineered," safety-related (designated
by the procedure as " Category I") components (e.g., for use in plant modifica-
tions) and for safety-related services. PL-B is for non-engineered replacement
parts and components for safety-related applications to be procured as nuclear
safety-related items. PL-C is for the procurement of commercial grade items (CGIs)
,
to be upgraded or dedicated for use in safety-related plant applications. PL-D
is prescribed for materials, equipment, and services not considered Category I.
PL-A, -B, -C, and -D procurement each have associated controls, prescribed to
be commensurate with the degree and nature of importance to plant safety of the
purchased system or equipment. To determine the proper level of control and QA
required for procurement, as .well as for other reasons, the safety-related
status and safety functions are defined for all major plant systems and equip-
ment in the Material Equipment, and Parts List (MEPL) governed by ACP
1.2-2.1. A relatively new program in the process of being implemented, called
the " Bill of Materials Program," is designed to identify those components or x
piece-parts of safety-related equipment that actually have or are associated
with some safety function (active or passive) as distinguished from those with
no identifiable safety function. Presently, the scope of the program is
limited in most cases to those components that normally are or would be
replacea during the course of plant preventive and corrective maintenance.
UnderHNP'sprogramforequipmentenvironmentalqualification(EQ)pursuantto
10 CFR 50.49, certain additional electrical equipment which is not classified
as safety-related (Class IE), primarily postaccident monitoring equipment, but
which is required to be environmentally qualified, is treated for procurement
purposes, as Class 1E equipment.
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. The review of the procedures revealed some programmatic deficiencies and the l
review of individual procurement identified several instances in which these I
practices resulted in quality and safety concerns. Examples of deficient
individual procurement and dedications are discussed in the main body of this
report.
The elements that were missing in HNP's earlier programs that would be
necessary for adequate dedication would include, but are not limited to:
(1) establishment of traceability of the replacement parts and components to
their manufacturers, (2) definition of the items' safety functions and the
conditions under which they must be performed, (2) identification of critical
characteristics or attributes of the items considered vital to the items'
ability to perform its safety functions as required under all design conditions
including seismic, (3) review and technical evaluation of any changes in design, ,
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process, and materials and any impact on the suitability for safety-related
applications under all design conditions, (4) methods for receipt inspection
and testing sufficient to demonstrate that critical characteristic requirements
are met, and (5) detailed requirements for documentation of these actions.
The procedures required that the licensee evaluate the suitability of commercial
grade items for safety-related applications. In practice, this consisted of l
nothing more than a verification that the part number and catalog specifications l
are the same. In most instances, as described in the procurement section of
the report, no further engineering or technical evaluation, and no review of
form, fit, and function beyond part number verification and catalog specifica-
tions were documented. Therefore, under HNP's earlier programs, the process of
dedicating or upgrading the commercial grade material for safety-related
service lacked crucial elements required to provide the assurances otherwise
associated with manufacturing under a 10 CFR Part 50, Appendix B, QA program,
audited and approved by the licensee, and the assurance, under 10 CFR Part 21, )
that any deviations from technical procurement specifications would, as a !
minimum, be reported to the licensee for evaluation of the potential for I
creation of a substantial safety hazard.
Finally, procedure ACP 1.2-2.5, " Classifying and Upgrading Spare Parts,"
Revisions 3 (4/85), 4 (7/86), 5 (8/86), and 6 (11/87), provided for the upgrade
of parts procured under PL-D. The process consisted, however, of nothing more
than a standard minimum receipt inspection as was done under PL-C and documen-
ting results on a material receipt inspection report (MRlR), often with no
reference or traceability to a P0. The section of the report on individual
procurement gives examples of this process. l
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