View source for B13186, Provides Addl Info Re Dedication of commerical-grade Items, 10CFR21 Requirements & Westinghouse Technical Bulletin NSD-TB-83-02,in Response to Insp Rept 50-213/89-200

{{Adams
| number = ML20247K300
| issue date = 03/30/1989
| title = Provides Addl Info Re Dedication of commerical-grade Items, 10CFR21 Requirements & Westinghouse Technical Bulletin NSD-TB-83-02,in Response to Insp Rept 50-213/89-200
| author name = Mroczka E
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
| addressee name = Bettenhausen L
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000213
| license number = 
| contact person = 
| document report number = B13186, NUDOCS 8904050216
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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               ,N.AST UTILITIES                                         o.nor i Orrice. . seioon sir..i. Boriin. Conn.ciicui 9           ww a .mc mme eacmc c""                                  P.O. BOX 270
                             .mo.: wea oma cw" HARTFORD. CONNECTICUT 06141-0270 k    k   J  C C , C ','E ~.                                         (203) 665-5000 March 30, 1989 Docket No. 50-213 B13186 Re:   Region Based                                                                    ;
Inspections l
U.S. Nuclear Regulatory Commission Region I Attention: L. Bettenhausen 475 Allendale Road King of Prussia, PA 19406 i
Gentlemen:
1 Haddam Neck Plant Additional Information The NRC Staff conducted a site inspection at the Haddam Neck Plant during the week of February 6-10, 1989 (Inspection No. 89-200). During the exit meeting                                                               1 on February 10, 1989, Connecticut Yankee Atomic Power Company (CYAPC0) commit-                                                             l ted to providing additional information on the following issues:                                                                          !
o     Dedication of Commercial Grade Items o     10CFR Part 21 Requirements o     Westinghouse Technical Bulletin NSD-TB-83-02 Dedication of Commercial Grade Items--Procurement Level C--Purchase Orders As identified during the exit meeting on February 10, 1989, CYAPC0 will perform a random sampling evaluation of purchase orders generated between January 1985 and May 31,              1988. Preliminary estimates indicate that 1250 Level C purchase orders were generated during this time period.                                                 The acceptable quality level (AQL) for the sampling plan should be set to assure no operability concerns exist. For 1250 purchase orders, this implies less than a 0.1 percent defective rate. Using this AQL and Military Standard 105D (April 29, 1963) for a normal Level II inspection, the sample size will be approximately 125 purchase orders. Any nonconforming conditions will generate a nonconformance report (NCR).
If any of the NCRs cannot be dispositioned "use as is," then an operability evaluation will be performed and the use of the sampling plan will be reevalu-ated. If all of the NCRs are dispositioned "use as is" for the sample of
,                  125 purchase orders, then the entire population of 1250 will be deemed accept-able in accordance with Military Standard 105D.                The sampling program is expected to be completed approximately 60 days after the 1989 refueling outage.                                                                                                                              7 8904050216 890330
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PDR    ADOCK 05000213 Q                      PDC                                                                                                      7 l                                                                                                                                                       (
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1 U.S. Nuclear Regulatory Commission B13186/Page 2 March 30, 1989 10CFR Part 21 Requirements--Procurement A/B Purchase Order l
CYAPCO will perform a sampling evaluation of approximately 125 Level "A" and "B" purchase orders generated between January 1985 and May 1988. The sampling plan will be based on Military Standard 105D. The extent of the sampling evaluation should define the magnitude of the problem with regard to invoking 10CFR Part 21 requirements on Procurement Level A/B purchase orders.        The i sampling results will be addressed when CYAPC0 responds to the formal inspec-tion report.
Westinghouse Technical Bulletin NSD-TB-83-02 During the exit meeting of February 10, 1989, Haddam Neck Plant maintenance     )
l                                   procedures were questioned with respect to the vendor recommendation in l                                   Westinghouse Technical Bulletin NSD-TB-83-02 that the Undervoltage         Trip 1
Attachment (UVTA) be cycled ten times prior to returning the breaker to service. The Technical Bulletin implied that the ten trip cycles of the UVTA    ,
are a functional test of the device. The Westinghouse letter to CYAPC0 dated    l March 6,1989, explains that the ten trip cyclas are not a functional test,      ;
but rather assure the initial " burnishing-in" of the MOS(2) lubricant and      l subsequent effectiveness of the lubricant.                                      '
!                                   In Procedure PMP 9.5-40, " Functional Test of Reactor Trip Breakers," Steps 6.9 l                                   and 6.11 require two functional tests of the UVTA, and Step 6.27 requires       I ten trip cycles of the Reactor Trip Breaker. Step 6.27 is not a functional      I test of the UVTA, but it does assure the initial " burnishing-in" and subse-quent effectiveness of the lubricant required by the Technical Bulletin and the Westinghouse letter to CYAPC0 dated March 6,1989.
We are confident that the VVTA does cycle in Step 6.27 of our procedure.
First, the UVTA is functionally verified twice just before Step 6.27. The electrician closely observes the operation of the UVTA and will immediately stop the test and correct the problem if the UVTA " hangs up."
The latest edition of the Westinghouse Owners' Group Maintenance Program,
                                    " Maintenance Program Manual MPM-W0GRTSDB50-01 for Westinghouse Type DB-50 Reactor Trip Circuit Breakers and Associated Switchgear," Revision 0, dated November 20, 1986, recommends functionally verifying the UVTA four times prior to returning the breaker to service.          CYAPC0 will revise our Proce-dures PMP 9.5-23, " Preventive Maintenance of Reactor Trip and Isolation Breakers," and PMP 9.5-40, " Functional Test of Reactor Trip Breakers," by July 1, 1989, to comply with this recommendation.
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i                                                                                                 j U.S. Nuclear Regulatory Commission B13186/Page 3 March 30, 1989 If you have any questions, please contact us.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY   !
ff    M E. J./Mroczka [/
Senior Vice President cc:  U.S. Nuclear Regulatory Commission, Document Control Desk                    l E. W. Brach, NRC-NRR/VIB                                                    l R. McIntyre, NRC-NRR/VIB W. T. Russell, Region I Administrator                                       '
A. B. Wang, NRC Project Managet. Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant                1 i
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