View source for A07155, Responds to NRC Re Violations Noted in Insp Rept 50-213/87-28.Corrective Actions:Affected Motor Disassembled, Inspected,Degreased,Reassembled W/New Bearings & Retested

{{Adams
| number = ML20154A076
| issue date = 05/06/1988
| title = Responds to NRC Re Violations Noted in Insp Rept 50-213/87-28.Corrective Actions:Affected Motor Disassembled, Inspected,Degreased,Reassembled W/New Bearings & Retested
| author name = Mroczka E
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
| addressee name = Johnston W
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000213
| license number = 
| contact person = 
| document report number = A07155, A7155, NUDOCS 8805130135
| title reference date = 04-01-1988
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 8
}}

=Text=
{{#Wiki_filter:_ _ -_____
NORTHEAST UTILITIES                                                          o.nemi on,c.. . seiaen street. B.,on. connecticui L L lT MCT,ClLT.C',
H nTronscoNNECTICUT 06141-0270 (203) 665-5000 May 6, 1988 Docket No. 50-213 A07155 Re:                           10CFR50, Part 2, Appendix C Dr. William V. Johnston Acting Director, Division of Reactor Safety U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

==Reference:==
(1)   W. V. Johnston letter to E. J. Mroczka, transmitting Inspection No. 50-213/87-28, dated April 1, 1988.
Gentlemen:
Haddam Neck Plant                                                                                 (
Environmental Qualification Response to Inspection Report No. 50-213/87-28 Reference (1) transmitted the results of Inspection No. 50-213/
87-28, which was conducted November 16-20, 1987 of the Haddam Neck Plant equipment qualification program. During that in-spection, two violations of NRC regulations were identified.
Connecticut Yankee Atomic Power Company (CYAPCO) hereby provides its response to the identified violations.
Requirement 10 CFR 50, Appendix B, Criterion II states, in part, that:                                                          "The applicant shall establish      .... a quality                            assurance          program         ....
This program shall be by written policies, instructions, procedures ....      The quality assurance program shall provide controls over activities affecting quality .... The program shall provide indoctrination and training of personnel performing activities affecting quality ...."
fgo!
8805130135 880506                                                                                           I PDR    ADOCK 05000213                                                                                         g Q                  DCD

Dr. WilliCQ V. Johnston A07155/Pago 2 May 6, 1988 Violation contrary to the above, on November 18, 1987, NRC inspectors observed grease from Limitorque MOVs draining into plastic buckets. The grease had been added to the motor housing instead of the gear box by untrained contract personnel with inadequate direction, written instructions / procedures.
This is a Level IV Violation (Supplement I).
Root Cause CYAPCO's investigation identified several contributing factors related to the cause of the event. These are:
o   The Maintenance Procedure utilized and the technical infor-mation provided were inadequate.
o   The grease plug and other pipe plugs are sir.ilar in design and in close proximity.
o   "Hands-On" training provided had been parformed using older style MOVs.
o   The supervision of this effort was not sdequate. The super-visor did not provide adequate instruction or job oversight.
The root cause of the event has been independently assessed via the Human Performance Evaluation System (Hfff) and Management Oversight Risk Tree (MORT) review systems          This review has identified the following causes of this event:
o    The Plant Design Change packages under which EEQ Limitorque motor operators were installed did not ensure that adequate training was performed for maintenance on these EEQ operators, t           o    Training on EEQ MOVs was available for Maintenance Department i                personnel, but was not attended by the foreman of this job.
o    The procedure for performing routine, preventive maintenance on EEQ Limitorque motor operators 16 inadequate. It does not address the presence of motor T-drains or the gear box grease relief fitting.
o    Inadequate supervision was provided. The person in charge, I                an electrician temporarily upgraded to foreman, had not received hands-on training on this EEQ equipment.
(1) These activities were performed under a program put in place and executed by the corporate Nuclear Safety Engineering group.
l l
t

Dr. WilliCQ V. Johnston A07155/Pago 3 May 6, 1988 corrective Action o    Each of the affected motors has been disassembled, inspected, degreased, reassembled with new bearings, and retested.
These actions were performed using approved station procedures under the cognizance of the motor manufacturer.
These Movs have been declared operable, o    A review of over 150 work orders for EEQ equipment imple-mented during the 1987 Refueling Outage has revealed no activity or lack of activity which would adversely affect equipment qualification and operability.
o    All EEQ MOVs have been inspected to ensure that no inap-propriate work has been performed.
Actions to Prevent Recurrence o    Until training of electricians is completed and procedures are verified to be adequate, degreed engineer and super-intendent review of work orders will be made prior to         ,
authorizing work on EEQ equipment, o    MOV procedures will be upgraded to include specific instruc-tions and graphics for each type of operator. Procedures will include a greater level of detail. The extent of GA involvement will be re-evaluated. This will be completed prior to the next refueling outage (currently scheduled to statt in August 1989) and will include a checklist for EEQ Concerns.
o    MOV training has been reviewed and deemed adequate to address EEQ concerns. Necessary plant maintenance personnel will receive this training prior to the next refueling outage.
Requirement 10 CFR 50.49 paragraphs (f) and (g) require that each item of electrical equipment important to safety be qualified and that the qualification must be completed at a time no later than November 30, 1985.
Violation Contrary to the above, on November 20, NRC inspectors identified the following items for which the licensee had not established qualification prior to this inspection.
: 1)  Qualification of Rockbestos Firewall SR cable for submergence was not established.
J

i Dr. WilliOO V. Jchnston A07155/POg3 4 May 6, 1988 Root Cause The file preparer failed to explicitly evaluate the submerged condition.
Corrective Action A summary of the qualification data available in the files on Rockbestos SR, and Kerite cable which described how the existing information should be evaluated in concluding that the subject cable is qualified was presented during the audit. Additional information obtained during the course of the audit was to support qualification of the Rockbestos cable, since the vendor quality assurance program in effect during the performance of the published test had been questioned by the NRC. Additional information pertaining to the post LOCA mandrel bend test was also obtained for the Kerite cable.
Action to Prevent Recurrence All cable qualification files will be reviewed for Haddam Neck to ensure that cables requiring qualification for submergence include adequate discussions of the reasoning behind our conclusion that the cables are in fact qualified for submergence.
The new Rockbestos SR test report will be reviewed and incorporated into the Rockbestos SR file after its applicability has been established.      These reviews will be completed prior to the start of the next refueling outage, violation
: 2)   Qualification of Kerite Cable for submergence was not established.
Root Cause The file preparer failed to explicitly evaluate the submerged condition.
Corrective Action A summary of the qualification data available in the files on Rockbestos SR, and Kerite cable which described how the existing information should be evaluated in concluding that the subject cable is qualified was presented during the audit. Additional information obtained during the course of the audit was to support qualification of the Rockbestos cable, since the vendor quality assurance program in effect during the perforeance of the published test had been questioned by the NRC. Additional information pertaining to the post LOCA mandrel bend test was
;                     also obtained for the Kerite cable.
l l
l l

Dr. Willica V. Johnston A07155/POga 5 May 6, 1988 Action to Prevent Recurrence All cable qualification files will be reviewed for Haddam Neck to ensure that cables requiring qualification for submergence include adequate discussions of the reasoning behind our conclusion that the cables are in fact qualified for submergence.
The new Rockbestos SR test report will be reviewed and incorporated into the Rockbestos SR file after its applicability has been established. These reviews will be completed prior to the start of the next refueling outage.
Violation
: 3)   Qualification of unidentified cable used in two Solenoid Operated valves was not established (this item was identified by the licensee).
Root Cause The external conduit configuration gave no indication that the arrangement was anything other than the standard configuration.
It was therefore not opened for inspection, and was never discovered until work was done on the circuit during the outage.
Corrective Action The unidentified wire was replaced. The SOV and limit switch circuit is now in a fully qualified configuration. A test report which qualified the wire discovered in the junction box was obtained shortly after the conclusion of the audit.
A test repcrt which qualified the splice configuration for the Raychem splice was available during the time of the audit but had not been made a part of the file since a sample inspection done prior to the audit had not identified any splices not qualified by the file as it originally existed.
The test report qualifying the Raychem splice configuration discovered during the audit walkdown will be incorporated into the Raychem file.
Action to Prevent Recurrence Since the installation of the splice and the unidentified wire, training has been provided to plant and NUSCO people on the general requirements of the EQ program, and specific requirements for common EQ equipment such as Raychem splices. This training along with the more formal EQ program that has been developed, should preclude occurrences of this type in the future,

Dr. Willica V. Johnston A07155/POgo 6 May 6, 1988 violation
: 4)  Qualification of Bishop tape Splice by similarity was not established. The splice is qualifiable.
Root Cause Bishop tape was qualified by analyzing similarity between it and a tape which had been type tested. A comparison of data sheet properties and compounds had been done, but a detailed chemical analysis had not been done because it was not considered to be necessary.
Corrective Action A chemical analysis of the tapes has been completed which demonstrates the similarity of the tape compounds. This will be made a part of the qualification file prior to the start of the next refueling outage.
Action to Prevent Recurrence The qualification files will be reviewed to verify that where similarity is the basis for qualification, the similarity between tested components and the installed equipment is clearly established in the qualification files. This review will be completed prior to the start of the next refueling outage, violation
: 5)  Qualification of solenoid valve No. 526-6042-1 by similarity not established prior to this inspection.
Root Cause Information linking the tested equipment to the installed equip-ment was omitted due to a lack of thoroughness during the initial file preparation.
Corrective Action Just prior to the audit, supplementary information was obtained which established the similarity between the tested and installed equipment. Qualification was therefore established by similarity.
Action to Prevent Recurrence The qualification files will be reviewed to verify that where similarity is the basis for qualification, the cimilarity between tested components and the installed equipment is clearly established in the qualification files. This review will be completed prior to the start of the next refueling outage.

Dr. Willica V. Johnston A07155/PCgo 7 May 6, 1988 Violation
: 6)   Qualification of Rnychem splice (seal length) on Namco switches not established.
This is a Level IV violation (Supplement 1).
Root Cause Short Raychem seal lengths had been identified as a potential problem in IEN 86-53. CYAPCO initiated a program to do a sample inspection of Raychem splices. This was completed in September       :
1987. No short seal lengths were discovered in the inspection and therefore the test report which qualifies short seal lengths was not added to the Raychem files. The short seal length was found during the audit walkdown.
Corrective Action
-     The unidentified wire was replaced. The SOV and      limit switch circuit is now in a fully qualified configuration. A test report which qualified the wire discovered in the junction box was obtained shortly after the conclusion of the audit.
A test report which qualified the splice configuration for the Raychem splice was available during the time of the audit but had not been made a part of the file since a sample inspection done prior to the audit had not identified any splices not qualified by the file as it originally existed.
The test report qualifying the Raychem splice configuration discovered during the audit walkdown will be incorporated into the Raychem file.
Action to Prevent Recurrence Since the installation of the oplice and the unidentified wire, training has been provided to plant and NUSCO people on the
:     general requirements of the EQ program, and specific requirements for common EQ equipment such as Raychem splices. This training along with the more formal EQ program that has been developed, should preclude occurrences of this type in the future.
l l
[

                  . 2
           , .*                                                                                                                     I
                      .Dr. Willica V. Johnston A07155/Pcg3 8 May 6, 1988 If you have any questions related to the above, please feel free
* to contact my staff directly..
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY
                                                                                       /
C. J/ Mr6czkpJr Senior Vice President cc:  U.S. Nuclear Regulatory Commission Attn:      Document Control Desk Washington, D.C.                   20555 A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant s
i I
.                                                                                                                                   t J
                                                                                                                                    ~
                                                                                                                                 .-}}