ML20151C179

Insp Rept 50-213/87-28 on 871116-20.Violations Noted. Major Areas Inspected:Licensee Implementation of Environ Qualification Program & Verification of Implementation Per 10CFR50.49 Requirements

ML20151C179
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/29/1988
From:	Anderson C, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151C149	List: ML20151C146 ML20151C168 ML20151C179
References
50-213-87-28, NUDOCS 8804120199
Download: ML20151C179 (29)

See also: IR 05000213/1987028

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I 1

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Report No. 50-213/87-28

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Docket No. 50-213

License No. OPR-61 Category C

Licensee: Connecticut Yankee Atomic Power Company

P.O. Box 270

Hartford, Connecticut 06141

Facility Name: Haddam Neck

Inspection At: Corporate Office in Berlin, Connecticut

Inspection Conducted: November 16 - 20, 1987

Inspector: , d 3. - 2. (t- 8d

R. J. olino, S N h Reactor Engineer date

PSS 9/RI

Other Participants And Contributors To The Report Included:

S. Alexander, Equipment Qualification and Test Engineer, NRR/HQ

M. Dev, Reactor Engineer - OPS /EB/RI

L. Cheung, Reactor Engineer - PSS/EB/RI

E. Claiborne, Consultant, Sandia National Laboratory

L. Magleby, Consultant, Idaho National Engineering Laboratory

J. Stoffel, Consultant, Idaho National Engineering Laboratory

Approved by: J T

C. J.VAnderson, Chief, Plant Systems Section date

EB/ ORS /RI l

Inspection Summary: Inspection on November 16 - 20, 1987 (Inspection *

Relort No. 50-213/87-28)

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Areas Inspected: Special, announced inspection to 1) review the licensee's l

implementation of an Environmental Qualification (EQ) program and verify its i

implementation in accordance with 10 CFR 50.49 requirements for maintaining i

the qualification status of safety related electrical equipment in Larsh '

environment, 2) review licensee response and resolutions to NRC concerns identi-

fied in the Technical Evaluation Report (TER) issued by The Franklin Research

Center (FRC) and; 3) verification of installed configuration of EQ electrical

equipment selected from the EQ master list.

8804120199 880401

PDR ADOCK 05000213

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Results: The inspection determined that the licensee has implemented an EQ

program that meets the requirements of 10 CFR 50.49, except for certain

deficiencies listed below:

A. 10 CFR 50 Appendix B Criterion II Violation

Description Paragraph Item No.

Inadequate quality assurance program to 7.0 87-27-02

control activ; ties by written procedures,

instructions or training of personnel

resulting in grease being added to motor

housing instead of gear box

! B. 10 CFR 50.49 Paragraphs (f) and (g) Violations

Description Paragraph Item No.

1) Qualification of Rockbestos Firewall 13.2 87-28-03

SR cable for submergence not established

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prior to this inspection

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2) Qualification of Kerite Cable for 13.3 87-28-05

submergence was not established prior to ,

this inspection. Cable is qualifiaale

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3) Qualification of Solenoid Valve 13.6 87-28-11 ,

J No. 526-6042-1 by similarity

not established prior to this

inspection

4) Qualification by similarity for 13.9 87-28-14

Bishop tape not established. Tape

is qualifiable

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5) Qualification of unidentified cable 14.0 87-28-15

to junction box not established

prior to this inspection

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6) Qualification of Raychem installation 15.2 87-28-17

(seal length) not established prior

to this inspection

j C. Unresolved Items

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Description Paragraph item No,

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1) Discrepancies between the 5.0 87-28-01

I' augmented in service inspection

program as described in the approval

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letter and the Technical Specification

! change request

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Unresolved Items (Cont'd.)

Description Paragraph Item No.

2) Qualification checklist does not agree 13.2 87-28-04

with SCEW sheet on submergence issue.

Licensee to revise EQ file to reflect

correct status

3) EQ files to be revised to reflect the 13.4.1 87-28-05

280 F temperature profile

4) Add four new MOVs to Master List and 13.4.2 87-28-07

EQ maintenance program

5) T. drains omitted on new MOVs. 13.4.3 87-28-08

Licensee to add T drains prior to

startup

6) Revise EQ files to include 13.5 87-28-09

calcul tions demonstrating post-

accident operability time

7) Licensee to revise EQ file and 13.5 87-28-10

obtain a revised C of C for ASCO

valves, certified to Isomedix

Report No. 21678

8) Licensee to update EQ File to 13.7 87-28-12

include Weed Report No. N9004-

87-A and calculations verifying

temperature rise.

9) Licensee to revise EQ file to 13.8 87-28-13

reflect submergence requirements

for level transmitter junction box

10) Licensee to replace broken gear 15.1 87-28-16 I

case fitting in MOV-596 prior to i

startup

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DETAILS

1.0 Persons Contacted

1.1 Northeast Utilities Service Company (NUSCO)

• M. Alexander, Engineer

• T. J. Dante, Supervisor Nuclear Operations

• P. A. Blasioli, Supervisor Licensing

R. J. Blumstead, Generation Electrical Engineering

• J. Ferraro, Manager-Generation Electrical Engineering

R. Goldman, Technical Training Supervisor

• W. E. Hutchins, Generation Facility Licensing

• B. Kaufman, Superintendent QA Assessment

M. Kleimaa, Electrical Engineer

• G. L. Johnson, Director-Generation Engineering and Design

• R. M. Kacik, Manager Licensing

S. Oates, Licensing, Senior Technician

M. Marino, Nuclear Operations

• E. J. Mroczka, Senior Vice President Nuclear Engineering

and Operations

P. Nurnberger, Senior Engineer Assessment Qualification

, R. Peterson, Generation Electrical Engineering-Qualification

Engineering

J. Regan, Supervisor Generation Electrical Engineering

• A. R. Roby, Systems Manager - GEE

W. Romberg, Vice President Nuclear Operations

• F. Sears, Vice President Nuclear Electrical Engineering

• B. Tuthill, Supervisor Qualification Engineering

G. Van Noordennen, Licensing Supervisor (CY, MP)

S. Vick, Licensing Engineer

R. P. Werner, Vice President Generation Engineering and

Construction

1.2 Connecticut Yankee Atomic Power Company (CY)

• G. Bouchard, Unit Superintendent

• D. B. Miller, Station Superintendent

• K. Petschauer, Electrical Engineer

• G. H. Tylinski, Assistant Engineering Supervisor-Electrical

1.3 U.S. Nuclear Regulatory Commission

A. Asar, Resident Inspector

• P. K. Eapen, Acting Chief, Engineering Branch DRS/RI

• J. T. Shediosky, Senior Resident Inspector

• Denotes personnel present at the exit meeting of November 20, 1987.

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2.0 Purpose

The purpose of this inspection was to review the licensee's

implementation of a program to meet the requirements of 10 CFR 50.49 for

the Haddam Neck Facility and their implementation of corrective action

commitments resulting from deficiencies identified in the Franklin

Research Center Technical Evaluation Report,

3.0 Background

The final rule on the environmental qualification of electric equipment

important to safety for nuclear power plants became effective on February

22, 1983. This rule, Section 50.49 of 10 CFR 50, specifies the

requirements of electrical equipment important to safety located in a

harsh environment. In accordance with this rule, equipment for Haddam

l Neck may be qualified to the criteria specified in either the 00R

Guidelines or NUREG-0583, except for replacement equipment. Replacement ;

equipment installed subsequent to February 22, 1983 must be qualified in i

accordance with the provisions of 10 CFR 50.49 using the guidance of

Regulatory Guide 1.89 unless there are sound reasons to the contrary.

On April 10, 1984 a meeting was held to discuss Connecticut Yankee Atomic I

Power Company's proposed method to resolve the environmental qualification  ;

deficiencies identified in the December 13, 1932 Safety Evaluation Report  !

(SER) and the June 7, 1982 Franklin Research Center Technical Evaluation

Report (FRC TER), Discussions also included Connecticut Yankee Atomic

Power Company's general methodology for compliance with 10 CFR 50.49. The

minutes of the meeting and proposed method of resolution for each of the

environmental qualification deficiencies are documented in the licensee's

submittals of October 19, and Noventber 30, 1984. The Connecticut Yankee

Atomic Power Company met with the NRC staff on September 17, 1986 regard-

ing reliance on feed-and bleed and the augmented in-service inspection

program to address issues associated with environmental qua'ification and

high energy line breaks.

The acceptability of the licensee's electrical equipment environmental

qualification program is based on the results of the audit review per-

formed by the staff of 1) the licensee's proposed resolution of the en-

vironmental qualification deficiencies identified in the December 13, 1982

SER and the June 7,1982 FRC TER; 2) compliance with the requirements of

10 CFR 50.49; and 3) the licensee's augmented inservice inspection program

regarding feed-and-bleed.

4,0 EQ Program

The NRC inspectors examined the implementation and adequacy of the

licensee's EQ program for establishing and maintaining the qualification

of electrical equipment important to safety in compliance with the

requirements of 10 CFR 50.49. The licensee's EQ program encompasses

electrical equipment important to safety which has the potential of being

subjected to a harsh environment.

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Equipment important to safety as defined in 10 CFR 50.49 includes both

safety related and non-safety related equipment plus certain

post-accident monitoring equipment. Specifically included, are those

systems required to achieve or support:

• Emergency Reactor Shutdown

• Containment Isolation

• Reactor Core Cooling

• Containment Heat Removal

• Core Residual Heat Removal

• Prevention of significant release of radioactive material to the

environment

The licensee's program for establishing and maintaining qualification of

electrical equipment within the scope of 10 CFR 50.49 is defined in the

Nuclear Engineering and Operations Procedure No. NE0-2-21 entitled

"Nuclear Plant Environmental Qualification Program," revision 1, dated

July 24, 1987. The Northeast Utilities (NU), Nuclear Service Company

Branch Instructions for the Environmental Qualification Program is defined

in the corporate procedure for Generation Electric Engineering No. GE-EQ-01,

for Connecticut Yankee, Millstone Units 1 and 2. Specific guidance for the

Connecticut Yankee Atomic Power Plant Company Equipment Environmental

Qualification Program is provided in Procedure No. ACP-1.2-2.21, revision 1,

dated October 23, 1937.

These documents and the documents referenced therein were reviewed to

evaluate the procedural methods and their effectiveness for:

• Requiring all equipment that is located in a harsh environment and

is within the scope of 10 CFR 50.49 be included on the Master List

of electrical equipment requiring qualification.

Controlling the generation, maintenance and distribution of the EQ

Master List.

• Defining and differentiating between a mild and harsh environment.

Determining harsh environmental conditions at the equipment location

through engineering analysis and evaluation.

• Establishing and maintaining a file of plant conditions.

Establishing, evaluating and maintaining EQ documentation.

Training of personnel in the environmental qualification of

equipment.

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• Controlling plant modifications such as installations of new and

replacement equipment and providing for updating replacement

equipment in accordance with 10 CFR 50.49 criteria.

NUSCO Qualification E..gineering develops and maintains qualification

documentation files for each plant for all equipment that must be quali-

fled to 10 CFR 50.49. The file contains specific information addressing

each type of equipment from a distinct vendor and is intended to support

demonstration of qualification of EQ equipment to plant specific require-

ments. The qualified life of each piece of EQ equipment is established by

engineering analysis of qualification documentation and specific inst al-

lation environmental parameters. Compliance is determined by impler ting

procedure no. NE0-2.25. The guidance provided in generic letter 86-:: is

applied in the evaluation of the potential noncompliance. To achieve and

maintain electrical equipment qualification, the licensee has established

a comprehensive Environmental Qualification Program for the Nuclear

Engineering and Operations Group. The program incorporates NRC Regula-

tions, Regulatory Guides as well as the Institute of Electrical ard

Electronics Engineers (IEEE) standards and sound engineering practices

to form a detailed and workable program.

Based on the above review, the NRC inspectors concluded that the licensee

has implemented an EQ Program that complies with 10 CFR 50.49 requirements

except for specific deficiencies noted in this report.

5.0 EQ Master List

The NRC inspection team reviewed the current Haddam Neck (HN) Equipment

Master List (ECML), and associated documents discussed below to verify the

adequacy of the implementation of CYAPCO's EQML development and mainte-

nance procedures.

The HN EQML was based on a review of technical specifications, emergency

operating procedures (EOPs), "of f-normal" operating procedures (ONOPs),

piping and instrumentation diagrams (P& ids), electrical diagrams,

Regulatory Guide 1.97 (Revision 2, Categories 1 and 2), Regulatory Guide

1.89 (Revision 1), NUREG-0737, NUREG-0588, IE Bulletin 79-01B,10 CFR

50.49, HELB correspondence, and plant equipment verification walkdowns.

Most EQ engineering work for CYAPC0 on HN is done by the Generation

Electrical Engineering Branch (GEE) of Northeast Utilities Service

Company (NUSCO) and the nuclear engineering support division of CYAPCO's

parent company, Northeast Utilities (NU). NU's Nuclear Engineering and

Operations (NEO) Group includes both CYAPC0 and Millstone's operator,

Northeast Nuclear Energy Company (NECo).

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Generation Electrical Engineering Procedure GE-EQ-01, Revision 1, dated

October 3, 1986, "Environmental Qualification Program for Connecticut l

Yankee, [now Haddam Neck] Millstone Unit 1 and Millstone Unit 2, governs

development and maintenance of the EQML as well as other aspects of the

1 EQ program. EQML maintenance is also governed by NEO procedure NE0 2,21,

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Revision 1, entitled "Nuclear Plant Environmental Qualification Program,"

and by NE0 3.03, Revision 6, entitled "Preparation, Review, Disposition of

Pl3nt Design Change Records." Review of these procedures inrHeated that

j all types of equipment required to be qualified at HN would be included.

i Records pertaining to deletion of EQML items were also reviewed with no

i unjustified deletions identified.

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Safety related equipment required to mitigate high energy line breaks -

(HELBs) outside containment, principally auxiliary feedwater (AFW) system

equipment, and subject to a harsh environment from those HELBs was l

previously excluded from EQ. It was CYAPCO's position that functions  ;

performed by that equipment, principally reactor decay heat removal, could

be accomplished by "feeding and bleeding" reactor coolant using the safety

injection system (SIS) and power operated relief valves (PORVs).

CYAPC0 took this position because the unique design of HN's A N turbine

, steam supply piping, made the plant unable to satisfy the single failure .

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criterion. HN's four main steam AFW branch lines ultimately feed into a '

1 single pipe section before splitting to supply both of the plants AN pump ,

2 turbines. Thus a single pipe break in this section could render both  :

steam driven AN pumps inoperable. HN's single electric AN pump is not

, considered suitable for safety related applications and is not qualified.

! The NRC recognizes that feeding and bleeding is available as a backup, but l

j has determined that it is unacceptable as the primary means of decay heat

i removal for HN. Thus CYAPCO has proposed an augmented in-service inspec-

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tion program for the welds in this section of AN steam piping in order to

be able to postulate no breaks in welds in this area and not have to

impose the single failure criterion, Under these conditions, AN could

t then be relied upon as a safety related system.

The NRC inspector reviewed CYAPCO's qualification analysis of the AN l

system which concluded that the only components that needed to be  !

qualified that were not already qualified were the Limitorque motorized

valve actuators on the main feed isolation valves. CYAPCO had replaced

these actuators with qualified actuators. The inspector did not identify

any equipment, required to be qualified, that was not on the EQML.

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As a further validation check, the inspector selected 16 items of equip-

ment required to be used with the emergency operating procedure for a

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loss-of-coolant accident (LOCA)/ main steam line break (MSLB) and verified

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that they were all either listed in the EQML as qualified or were exempted

for a valid reason.

In approving CYAPC0's proposed AFW augmented in-service inspection program  !

(AISIP) by letter dated January 27, 1987, the NRC called for submittal of

a Technical Specification change request incorporating the proposed ,

program as a formal surveillance requirement. The change request had  ;

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already been submitted to the NRC at the time of this inspection. The

approving office stated that the program was included in the licensing

basis for EQ for HELBs. Accordingly, the inspector reviewed CYAPCO's

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implementation of the program as an integral part of the basis of the '

EQML. In this review, the inspector identified discrepancies between the

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program as described in the NRC approval letter and Tech. Spec. change

request and the implementation of the program thus far at HN.

(1) The approval documentation, Tech. Spec change request, original

description of the proposed AISIP and the CYAPCO safety evaluation of

which the provisions of the program were based stated that the AISIP

would include 59 welds, the existence of which had been postulated

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based on a drawing review. However, upon detailed examination of the

piping with the lagging removed. CYAPC0 had identified four welds in

straight pipe sections that would not have been expected from looking

at the drawings and eight "T" piping joints that were thought to

incorporate a T-section and three welds that were actually single-weld

branch connection or "stub-in" type joints. These differences ac-

counted for the fact that 47 welds of a size requiring ISI were

actually found in the piping.

(2) The AISIP was to include surface and volumetric non-destructive

examination (NDE) of each weld every 3-1/3 years for the first

ten years with a ten year periodicity thereafter; to revert to

3-1/3 years if any results were not within ASME guidelines. However,

the computerized ISI Work Plan in effect at the time of the inspec-

tion provided for ten year NDE only.

(3) CYAPCO personnel who prepared the safety evaluation for the proposed

AISIP stated that the prescribed volumetric NDE was intended to cover

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100% of each weld and CYAPC0 had determined that the volumetric NDE

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would be by ultrasonic test (UT). However, the NRC inspector's re-

) view of the site NDE department's ISI tracking sheets for the base-

line NDE series revealed that only 50% coverage was documented.

) (4) The AISIP is to include also a monthly visual inspection of each weld

for signs of leakage. It was not clear from the available documenta-

tion whether the lagging would be removed each time to accomplish

this surveillance, CYAPCO's stated that their intention was to have

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auxiliary operators (A0s) accomplish this by monthly walkdowns of the

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system without removing lagging. However, it was not clear how the

weld locations would be identified, or whether the A0s would be look-

ing for signs of wet lagging or plumes of steam.

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Before the end of the inspection CYAPC0 informed the inspector (1) that

the appropriate NRC staff personnel had been contacted to initiate dis-

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i cussioris of the issues, (2) that the computerized ISI data base, from

which the ISI work plans are generated, was not updated to reflect the

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correct surveillance /NDE requirements, (3) that they had been unable to

UT 100% of each weld due to piping arrangement interfering with UT trans-

i ducer probe positioning, but that alternate volumetric NDE techniques were

being considered, and (4) that CYAPC0's intended method of accomplishing

the monthly visual inspection would be made clear to NRC approving

authorities.

This item remains open pending completion of NRC review and approval of

Tech. Spec. changes submitted by the licensee to resolve the discrepancies

noted above. (050-213/87-28-01)

6.0 EQ Procurement and Spare parts

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The licensee's Nuclear Engineering and Operations Procedure NEO 6.02

provides for the preparation and review of quality related purchase

requisitions. The manager, Quality Assurance is responsible for in-

corporating quality assurance program requirements and for verifying

quality assurance requirements, QA category and the procurement level

for safety-related procurement of equipment, components and spare parts,

including EQ related items. Generation Electrical Engineering is re-

sponsible for reviewing and incorporating EQ requirements, as applicable,

for the procurement of electrical, instrumentation or control system

equipment.

The inspector reviewed the licensee's procurement documentation for the

following EQ related purchase orders.

PO MRIR Stock Number Item

742633 86-484-1A 52400320 Valcor Valve

742633 86-484-1B 52400320 "

747009 86-48B 57404150 Raychem HST

747009 86-489 59410124 "

741436 86-417 56802260 AMP

741436 86-425 62402033 AMP

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These purchase orders incorporated EQ requirements and the procured

items were inspected by the licensee's QC receiving inspectors to verify

the vendor's compliance. The receiving ir.spectors were found to have

been adequately trained and indoctrinated to verify the EQ related

attributes. The inspector also physically inspected the storage and

handling of these components. The material traceability was verified

through material receipt and issue reports (MRIRs) and found adequate.

Based on the above review, and discussion with the cognizant personnel,

and walkdown of the Haddam Neck warehouse, the inspector determined that

the licensee's EQ procurements and spare parts program implementation is

adequate.

7.0 EQ Maintenance

EQ maintenance requirements are defined in Section 8.A of Procedure NE0

2.21 entitled "Nuclear Plant Environmental Qualification Program", Review

1 dated July 24, 1987. Specific maintenance required to preserve the

qualification status of an equipment typa is ider,tified on page 4 of the

SCEW (system component evaluation work) sheets. The licensee's engineer-

ing at Berlin, Connecticut developed a maintenance document entitled

"Electrical Equipment Qualification Maintenance Book" which documents all

EQ related maintenance. Plant site personnel use this book to develop

maintenance procedures and to schedule maintenance activities.

Two groups at the plant site are responsible for performing maintenance

activities: the I&C maintenance group for instruments such as transmitters

and pressure switches and the electrical maintenance group for electrical

items such as Limitorque valve motors and solenoid valves. These two

groups operate independently. Each group has its own engineers and

specialists to develope and update the maintenance procedures, its own

PMMS (Plant Modification and Maintenance System) planner to schedule the i

maintenance activities and to track the status of these activities to '

minimize maintenance overdue problems.

The inspector selected the following maintenance and work documents for I

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• PHP 9.2-85 "Equipment Environmental Qualifications for Weed *

Instrument RTDs", dated April 12, 1986

• PMF 9.2-84 "Equip:.ent environmental Qualification for GEMS /DeLavel

Level Transmitter", dated September 15, 1987

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SUR 5.2-2.1 "Pressurizer Level Channel 1 Calibration", dated

September 15, 1987

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PMP 9.2-81 "Preventive Maintenance Procedure for Equipment

Environmental Qualification for Foxboro N-Ell and N-E13 series

transmitters", Revision 1 dated October 14, 1987

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CMP 8.5-123 "Maintenance of Valcor Solenoid Valves," dated

September 26, 1987

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CMP 8.5-25 "Corrective Maintenance for Limitorque Valve Motor

Operators Revision 10, dated July 18, 1987

• Work order No. CY-87-09293 "Maintenance for PR-50V-552A, Solenoid

Valve, pressurizer vent to sparger install new stainless steel

covers, grafoil packing, and 0-rings", dated September 18, 1987

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Work order CY-86-06617 "Maintenance for MOV-567 pressurizer relief

isolation", dated August 8, 1937

Work order CY-86-04622 "RTD replacement TE-412B", dated March 22,

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• Work order CY-87-07401 "Reactor Protection System Upgrade", dated

September 17, 1987

In addition, the inspector condacted a physical inspection for evidence

of proper maintenance activities. During the physical inspection, the

inspectors observed four Limitorque valve motors with buckets under the

motor T-drain hole with grease dripping from the hole. Discussions with

the licensee revealed 20 environmentally qualified Limitorque valve

motors had been improperly lubricated. This problem had been identified

by the licensee prior to this inspection. The licensee's electricians

performing preventive maintenance put grease into the motor housing

instead of the pinion gear housing of 20 environmentally qualified

Limitorque valve motors.

After the walkdown inspection, the inspector conversed with the

Maintenance Foreman and the Unit Superintendent to determine the cause of

this error. The following explanation is a preliminary reconstruction of

the events that led to this occurrence and the corrective actions the

licenseo has taken since the event.

In October, a Haddam Neck electrician and several contract electricians

were assigned to perform preventive maintenance on Limitorque valve

motors. After checking tne grease level, they reported to the foreman

that the pinion gear housing needed to be greased. The foreman directed

them to add grease in accordance with the procedure. The procedure pro-

vides general directions to all Limitorque operators. It does not include

any graphics or model specific guidance.

The problem was identified on November 17, 1987 when the Maintenance

Supervisor was conducting a postwork walkdown of the equipment to be '

inspected during this EQ inspection. While conducting this inspection, he

noticed the T-drains were incorrectly installed on the top of the motor

and a solid plug was in their place on the bottom of the motor. This

finding led to the discovery that the electricians had inadverteatly put

grease into the motor housings of 20 Limitorque motor operated valves

rather than the pinion gear housings. In addition, when the grease

started to drip out of the T-drains, the electricians interchanged the

solid plugs and T-drains to stop the leakage.

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Several areas of concern have been identified by this event:

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1. The preventative maintenance procedures were not adequate to ensuro i

the grease level is read properly and grease is added to the proper

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location.

2 2. Maintenance personnel were not properly trained to perform

maintenance on EQ equipment (they apparently did not know that the

purpose of the T-drain was to prevent moisture accumulation).  ;

! 3. Proper supervision and communication between workers and supervisors

l were not adequate.

4. More quality control may be necessary when work is being performed

on EQ equipment.

The Limitorque valve motors that were found to have grease in the motor

housings were MOV-567, 569, 596, 597, 598,599, 200, 298, 861A, 861B,

8610, 8610, 780, 781, 803, 804, 23, 34, 2928, and 292C.  ;

Based on the above information, the following action has been taken, or I

will be taken, by the Licensee,

o The PMMS will be searched to identify all work orders involving work

, performed on EQ equipment. Each will be reviewed to verify that the

work performed did not compromise the equipment qualification of the

equipment.

o The licensee will inspect all safety-related Limitorque valve motor

to ensure that no inappropriate work has been performed. '

i o Until the Unit Superintendent verifies the procedures and training

are adequate, he will review preparations prior to authorizing work

j en any EQ equipment,

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o MOV procedures will be upgraded to include specific instructions and

graphics for each type of operator. Procedures will include a

i greater level of detail. The amount of Quality Assurance

j involvement will be reevaluated. '

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4 o Limitorque valve motor training will be upgraded to include specific

} issues related to preservation of qualifications.

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o The Limitorque valve motors that were incorrectly greased have been

tagged out and declared inoperable.

1 o Licensee has contacted Limitorque and Reliance Motor Company and is

j evaluating the alternatives to restore the motors to an operating .

condition before plant opsrations.  !

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This item is a violation of 10 CFR 50, Appendix B, Criterion II in that

the licensee did not have a Quality Assurance Program to provide adequate

controls for applying grease to Limitorque M0V's by Written instructions ,

or procedures and provide indoctrination and training of personnel

performing activities affecting quality as necessary to assure suitable

proficiency is achieved and maintained. (50-213/87-28-02)

8.0 EQ Personnel Traininj

Section V, attachment 8A to procedure NE0 2.21 entitled "Nuclear

Environmental Qualification Program" prescribes the training

requirements for licensee's personnel performing activities affecting

EQ. The Training Department is responsible for the implementation of

these requirements. An EQ training program has been developed by the

licensee.

As part of this training program, a generic course (Lesson ID #CED-01)

entitled "Corporate Equipment Environmental Qualification" has been

given to various level of the licensee EQ personnel. This course covers

the purpose of EQ, discussion of 10 CFR 50.49 and RG 1.89, qualification

type test, and various EQ programs. Tailored training courses were given

to I&C draftsmen and electrical maintenance personnel as follows:

• Lesson ID # NU-TT-ICIT-GENADAM-LO 6005 "Environmental Qualifications"

for I&C maintenance personnel.

• Lesson ID # NU-TT-ELIT-ESKILL-L11005 "Electrical Equipment

Qualification, Introduction" for Electrical Maintenance personnel.

• Lesson ID # NU-TT-ELIT-ESKILL-LOS "Raychem Installation".

• Lesson ID # NU-TT-ICIT-REPREW-803004 "Raychem Splices".

• Lesson ID # NU-TT-ELIT-ESKILL-LO5005 "Introduction to Raychem".

• Lesson ID # NU-TT-ELIT-ESKILL-LO5010 "Raychem WCSF".

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Four of the licensees key EQ personnel participated in various EQ

seminars sponsored by outside agencies, including EPRI, American Nuclear

Society, and Raychem Corporation.

Based on the inspector's review of training records and discussions with

licensee personnel, the inspector concluded that with the exception of

the licensee's maintenance deficiency that lead to the grease problem  ;

discussed in Paragraph 7, the licensee's EQ training is adequate. i

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9.0 EQ Plant Modification

The licensee has developed procedure NEO 3.03 entitled "Preparation,

Review and Disposition of Plant Design Change Records (PDCR)," Revision 6

dated November 21, 1986. This procedure establishes the process and

control of the plant design changes. All major plant modificatior.s for

haddam Nack are initiated from Nuclear Engineering and Operation in

Berlin, Connecticut. The originator of the design change request must

provide sufficient information in the request to support the design

change, including a clear statement of the design change scope, reason and

justification for the change. When the design is complete, the package

is reviewed by various engineering groups, including EQ review group for

compliance with the licensee's EQ program. Sections 4.8 and 6.3.4 of NE0

3,03 prescribes these requirements. Subsequently, a safety evaluation is

performed on the design change. The final design package is reviewed by

the PORC/SORC review teams.

When the design change (plant modification including installation and

testing) is complete, the as-built PDCR is again reviewed by the

PORC/50RC review teams before releasing for operation.

The inspector selected the following PDCRs (plant modification packages),

one EQ and one non-EQ, for review:

• PDCR No. 758 for the replacement of reactor coolant system loop

temperature elements, dated December 24, 1985.

• PDCR No.85-302 for the team generator primary channel head

decontamination dated January 22, 1986.

The inspector verified that for the first package, proper EQ reviews were

performed and proper EQ installation consideration was included and that

these activities did not apply to the second package, which is a non-EQ

plant modification.

Within scope of this review, no deficiencies were identified.

10.0 QA/QC Interface

Procedure No. Q50-2.02 nrovides instructions and guidelines for

performance, reporting and following of the Quality Service Department,

Suppliers, the Nuclear Review Board and the site audits. Control

Procedure No. ACP-1.2-2.21 provides guidance and requirements for the

identification and control of 10 CFR 50.49 regulated nuclear plant

equipment. This procedure is used to implement the requirements of

procedure no. NE0-2,21 for safety related equipment. An Environmental

Equipment Qualification (EEQ) Engineer's review is part of the QA

procurement cycle. (Reference NEO Procedure 6.02). This review is

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performed prior to NtJSCO QA approval and as a minimum verifies whether

the material is an EEQ Master List item. Appropriate EEQ specifications

and certifications are completed and correctly included and ensures that

vendor documentation is adequate to demonstrate qualification to specific '

EEQ parameters. Those items identified as "EEQ required maintenance"

must be performed on QA work orders. Equipment replacement and mainte- i

nance is performed in accordance with procedure no. ACP-1.2-4.1. Audits

are performed by the licensee's Engineering Assurance Section. Audit

No. A-30123 was conducted during May 19 through July 20, 1987 to verify

licensee's compliance with the Nuclear Engineering and Operations Proce-  :

dure No. NE0-2.21. The NRC inspector reviewed the scope of the licensee's '

audit A-30123. The audit was primarily dedicated to the overview of '

licensee's corporate EQ program as delineated in the Nuclear Engineering

and Operations procedure No. NEO-2,21. Administrative Control Procedure

No. ACP-1.2-2,21 was established to implement the EQ requirements of

NE0-2,21 for safety related electrical equipment qualification at

Haddam Neck.

For the Haddam Neck facility, the audit consisted of reviewing five EQ

files and a physical walkdown to verify information and data used in the

related EQ files for equipment qualification. The audit did not identify

any significant discrepancies or deficiencies. i

11.0 NRC Information Notices (ins) and Bulletin

NRC ins and Bulletins are handled administratively as part of a program

called "Vice President, Nuclear Operations Commitment Program," governed

by Nuclear Operations Policy NOP-1.05 (revision 3, 4/15/86). The program

provides for distribution, tracking, and assignment of responsibility for

correspondence requiring actir>n and/or response. Such items are tracked

by a system of Nuclear Operations Assignments (NOAs). Specific instruc-

tions for handling of NRC correspondence including ins, IEBs, and inspec-

tion reports are contained in N0P-R-2.04 (rev. 8, 2/17/87). Review of

the:e procedures revealed that there was no formal requirement to route

all ins and other similar material to EQ personnel for their determination

of applicability to EQ. This decision is made by personnel not directly

involved in EQ. However, the inspector determined that this was being

accomplished satisfactorily in practice due to the EQ training and

awareness of cognizant personnel.

The NRC inspectors reviewed the status of actions on EQ-related ins and

verified implementation of CYAPCO's program for processing and tracking

NRC bulletins and information notices as they related primarily to EQ.

The licensee had reviewed and evaluated appropriate EQ-related ins and IE

bulletins from IEB 79-01 through IN 87-08. Actions pertaining to

selected ins were reviewed in detail.

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Examples discusseo are as follows:

• IN 86-03, concerning unidentified internal wiring in Limitorque

motor o;erators, was reviewed. Review of the file on this, including

licensee walkdown and maintenance records, indicated that HN had con-

ducted plant walkdowns and replaced all unidentified wiring with

qualified wiring. No discrepancies in this area were noted in the

NRC's plant physical inspection of selected Limitorque switch com-

partment internals.

• IN 84-90, dealing with superheated steam release during a main

steamline break (MSLB), was evaluated for HN. Results of the

analysis indicated that existing EQ parameters are adequate for

qualified equipment exposed to this environment.

Within the scope of this review, no deficiencies were identified.

12.0 Information Notice No. 86-53

In response to Information Notice S6-53, the licensee reviewed the Haddam

neck program for installing Raychem Heat Shrink Tubing to assure that

proper engineering criteria, inspection and training requirements have

been established. At the present time the Haddam Neck facility has one

generic procedure and two specific procedures in place for installing

Raychem Heat Shrink Tubing. These procedures are 1) Procedure No.

PMP-9.2-25 entitled "Equipment Environmental Qualifications for

Installation of Raychem Sleeving, 2) Procedure No. SPL-10.7-262 entitled

"Installation of Raychem NPKV Nuclear Plant Splice Kit on P-149-1AM and

P-149-1BM Leads, and 3) Procedure No. SPL-10.5-189 entitled "Temporary

Power to Containment Welding Equipment via the CAR Fans F-17-3 and F-17-4.

Records indicate the licensee conducted two seminars, including one by

the Raychem Corporation (HST manufacturer) which provided instructions,

guidance and Hands-On training for technicians / craftsman involved in the

application of electrical splices.

The licensee's Generation Electrical Engineering Group established

inspection guidelines and conducted an inspection of existing Raychem ,

Splices and terminations to' determine compliance with established l

procedure for installation of electrical splices. No deficiencies were

identified by the licensee.

13.0 EQ File Review

13.1 The licensee's EQ files were examined to verify the qualified status  !

of equipment within the scope of 10 CFR 50.49. In addition to  !

comparing plant service conditions with qualification test l

conditions and verifying the bases for these conditions, the

inspectors selectively reviewed areas such as post-accident

operating time compared to the duration of time the equipment has

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been demonstrated to be qualified; similarity of tested electrical l

components / equipment to that installed in the plant (e.g., insulation

class, component materials, test configuration compared to installed ,

configuration and documentation of both); evaluation of adequacy of l

test conditions; aging calculations for qualified life and replace-

ment interval determination; effects of decrease in insulation re-

sistance on equipment performance; adequacy of demonstrated equipment  ;

accuracy; evaluation of test anomalies; and applicability of EQ

problems reported in IE Information Notices / Bulletins and their ,

"

resolution (s). The inspectors reviewed a selected sample of 24 EQ

files associated with various equipment types. These equipment types 6

covered such areas as electrical cable, Limitorque motor operated

valve (MOV) actuators, pump motors, solenoid operated valves, cable

splices, radiation detectors and pressure / level transmitters.

An equipment type is defined as a specific type of electrical

equipment, designated by manufacturer and model, which is

representative of all identical equipment in a plant area exposed to  ;

the same or less severe environmental fervice conditions.  !

Except for specific file deficiencits, listed below, the EQ files l

sre well organized, easy to follow and auditable. l

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13.2 EQ File No. EEQ-CY-163 (Rockbestos Firewall SR Cable)  ;

This type of cable is used for inside containment application. The

test report used by the licensee to support the qualification is a  ;

Rockbestos report (no report number) entitled "Qualification of i

Firewall SR Class IE Electric Cables, dated March 2, 1978. This

report documented the type test of a single conductor, #14 AWG, with

30 mils of methyl phenylvinyl SR insulation, identified by the manu-

f acturer as Firewall SR cable. However, this report is considered  !

invalid by NRC to support equipment qualification because of deft-  !

ciencies stated in IE Information Notice 84-44, which was issued to

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the licensee in June 1984. Information Notice 84-44 summarized some t

of the deficiencies as a result of several NRC audits of Rockbestos

a

test program. Four of the eight deficiencies are as follows:

I a) The Rockbestos Company did not establish and implement a QA

program in accordance with 10 CFR 50, Appendix B requirements

to control Rockbestos EQ testing; i.e., the EQ program was  ;

controlled by a Rockbestos engineering organization which was l

l not under a QA program until 1983.  !

<

, b) Test equipment was not properly calibrated or under the control

of the calibration system. An internal Rockbestos audit dated

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May 10, 1983, documented these generic deficiencies in their

calibration system.

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c) A number of test deficiencies, deviations, and other anomalies

were not documented and evaluated in the test reports,

d) As a result of inadequate QA controls, testing and the required

documentation were not properly controlled. Several discrepan-

cies b6 tween final qualification reports and supporting test

data were found.

In addition, t*m March 2,1978 Rockbestos test report did not have

any insulation resistance ceasurements during the test, and the test ,

for submers ence application did not anvelope the plant condition.

The above deficiencies in the EQ file indicate that qualification

for submergence of this type of cable was not establist the tir.e

of the inspection. This constitutes a violation of 10 . 49

paragraphs (f) and (g) which require that each item of ical

equipment important to safety be qualified and that quc :ation

must be completed at a time no later than November 30, . B5

(213/87-28-03). During the week of the inspection, the licensee

contacted Rnckbestos for additional qualification information. The

licensee stated that Rockbestos had recently completed successfuly a

qualificaticn test, including submergence test, for this type of

cable. The inspector concluded that the licensee would be able to

establish this cable's qualification based on the additional test

data.

During the review of this EQ file, the inspector noted that the SCEW

theet and the qualification check list do not agree. SCEW sheet

A-10-32 indicates that these cables were used below flood level (i.e.

submergence). However, the qualificati>n evaluation checklist item i

14 indicates that these cables will not be submerged post-accident.

The licensee stated that the SCEW sheet is correct and that the

qualification checklist would be changed to agree with the SCEW

sheet. This is en unresolved item pending NRC verification of

licensee's correction of tha EQ file. (213/87-28-04)

13.3 EQ File EEQ-CY-107 (Kerite Cable)

Qualification for the Kerite Cable is based'en NUREG-0588, Category

1. The file contains three test reports for three dif ferent cable

configurations which form the basis for cable qualification.

The three test reports are: l

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• FR insulated 600 V cable with FR Jacket-Franklin Research

Center Report No. F-C4020-1

• HTK insulated 600 V cable with FR Jacket-Franklin Research

Center Report No. F-C4020-2

+

HT insulated 5 KV cable with HTNS Jacket-Wyle Laboratory Report

No. 47176-1

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The test for the HT-600 volt cable and the HT-5KV cable was marginal.

Both cable specimens maintained rated voltages and current during the {

DBE, however, insulation resistance (IR) was low and both cables ~

failed the post-DBE withstand test. The test reports did not address

submergence test for the two 600 volt cable even though it was a

NUREG-0588 Category 1 requirement. To qualify the cables, the .

liconsee provided additional information obtained during the inspec- l

tion. This information was in the form of an Isomedix Report No.

1-R279-02 and supplemental information from Kerite to the Franklin '

Report F-C4020-2. The Isomedix Report documents qualification of FR '

insulation (30 mils) and FR jacketed (5 mils) 16 AWG cable. Qualifi-

cation was based on tests done in accordance with IEEE-383 (1974)

that enveloped the Haddam Neck LOCA profile. During this LOCA testing. <

the cable specimens were subjected to: a) four hours at 330*F and 55 *

psig saturated steam, b) twelve hours at 260'F and 21 psig saturated i

steam, c) ninety-five hours at 220'F and 3 psig saturated steam, and (

d) twenty-six days at 200'F and 0 psig. During this test the cables e

were continuously sprayed with a sodium hydroxide solution. The

supplemental data consisted of additional LOCA testing in which the

cables were 1) energized with 600 VAC at 12 amps, 2) preaged for 101

hours at 150*C (equivalent to 40 years at 83'C), 3) exposed to 200

mega rads prior to the LOCA test, and 4) high pot test while cable

was in the LOCA chamber. The inspector determined that the licensee

nad not established qualification of the Kerite cable prior to this ,

inspection, however, data provided during the inspection indicates

the cable is qualifiable. This item is in violation of 10 CFR 50.49

paragraphs (f) and (g) which require that electrical equipment

important to safety be cualified and that qualification be completed

prior to November 30, 1935. (213/87-28-05)

13.4 EQ-File No. EEQ-CY-122 (Limitorque_

u Valve Operatorq i

13.4.1 The inspector reviewed E 'ile no. EEQ-CY-122 for Limitorque  ;

Valve Actuators type / sit 13-0, SMB-00, SMS-000 and SMB-1. ,

This review was to deterni t whether the EQ package contains .

sufficient documentation * these actuators are qualified for i

the environmental conditice 'n which they must operate and that  ;

the qualification document', is adequate. l

The licensee claims qualification to the requirements of  !

NUREG-05BS, Category 1 for all Motor Operated Valves (MOVs).  !

SCEV sheets for 23 MOV's were examined. The containment peak  ;

temperature was indicated as being 305'F. With this temperature i

it was not apparent that a 15'F margin had been met for these i

MOVs and the Marathon 300 Terminal Blocks used in the MOVs. The

licensee reconciled this by revising the accident profile as a i

result of additicaal profile evaluations initiated in 1985 and

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documented in NUSCO memorandum No. PSE-EM-86-066 dated February

12, 1985. The profile was revised to specify 280 F as the peak

temperature. This change in containment peak temperature was

not reflected in the EQ files which still list'305 F as the

containment peak temperature. The licensee indicated there is

a continuing effort to revise all EQ files to reflect the new

containment temperature profile with a peak temperature of

280 F. The licensee stated that the continued use of the old

profile (305 ) is conservative and provides a margin of 25 F.

This item is unresolved pending completion of licensee's

continuing effort in revising EQ files to include the 280 F

containment peak temperature profile. (213/87-28-06)

13.4.2 Four MOVs (Nos. 595, 596, 597 and 598) are not on the Master

List or considered qualified to NUREG-0588 untti evaluations and

modifications performed during this outage are complete. The

licensee found it necessary to qualify these MOVs af ter re-

evaluation of the feed and bleed operational functions. These

MOVs are pressurizer relief isolation valves. Based on the new

feed and bleed considerations, these MOVs must now be qualified.

This work will be done prior to startup.

This item is unresolved pending NRC review of licensee cor-

rective action to qualify and include the four new MOVs on the

Master List and in the EQ program. (213/87-28-07)

13.4.3 The inspector noted that T-drains were omitted from the new

MOVs. The licensee has committed to replacing T-drains on MOV

Nos. 595, 596, 597 and 598.

This item is unresolved pending NRC verification of licensee

corrective action to replace the missing T-drains on the above

MOVs. (213/87-28-08)

13.5 EQ File No. EEQ-CY-111 (ASCO Solenoid Valves, Models NP8316 and NP8320)

13.5.1 Qualification of the Solenoid Valves is based on the NUREG-0588,  ;

Category 1. The ASCO solenoid valves covered by the file are

located inside the containment, in the pipe trench, and in the

Main Steam Isolation Valve (MSIV) enclosure.

Concerns were raised during the course of the file review

regarding the calculation used to demonstrate the post accident

operability time. The DBE simul ?, ion and the post accident

operability time simulation were treated together in the Arrhenius

calculation analysis and compared with the required DBE and

post-accident operability time. DBE simulation normally should-

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not be used for demonstrating post-accident operability because

the time at temperature is relatively short and does not ade-

quately simulate the effects of longer times important for . ,

demonstrating post-accident operability. Also, this method

takes credit for temperature margin of the DBE simulation for

, demonstrating post-accident operability which is not justified.

In response to this concern, the Licensee performed additional

calculations demonstrating a post accident ~ operability time of

1.8 years. The concern will, therefore, be resolved when the

calculations are added to the file.

This item is unresolved pending NRC review of licensee

corrective action to perform the additional calculations and

add these calculations to this EQ file and the other affected

EQ files. (213/87-28-09)

13.5.2 The file contained a section that addressed the applicr.ble NRC

Inspection and Enforcement notices. A concern was raised

in regards to the response to IN 84-23. This information notice

reported that ASCO Report AQR-67368 may not be sufficient for

qualification of Model NP-8316 because of failures of a natural-

ly aged test valve of the model in the NRC sponsored. tests

conducted by Franklin Research Center (FRC). The Licensee's

file addressed the failure of the NRC/FRC test and reported that

ASCO "feels" that the aging sequence of the NRC/FRC test was'not

indicative of the true aging process. Also, the Licensee

established that the temperature in the DBE simulation of the

NRC/FRC test was significantly higher than the required tem-

perature profile for the Connecticut Yankee plant. The inspector

did not consider this explanation as sufficient justification

l for not conforming to the suggested action of the information

notice to establish qualification of the Model NP8316 by the

Isomedix AQS Report Number 21678/TR-Rev. A. In response to the

concern, the Licensee established that the required service

conditions for the ASCO valves are enveloped by the tests of the

Isomedix AQs 21678/TR-Rev. A report. Therefore, they contended

that their limited use. of the AQR-67368 report is consistent l

with the statement in the information notice of using the i

AQS-21678 report. In addition, the Licensee committed to

investigate the possibility of obtaining revised certificates of

compliance. If recertification to AQS-21678 is available, the

Licensee committed to revise the file to base qualification on

this report. Because the licensee has established that the

service conditions are enveloped by the AQS-21678 tests, the

Inspector concluded that the action committed to by the Licensee

would adequately address the concerns of the information notice

IN 84-23.

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This item is unresolved pending NRC review of licensee

corrective action to obtain a revised C of C certified to the ,

Isomedix Report No. AQS-21678. (213/87-28-10)  !

13.6 EQ File No EEQ-CY-128 (Valcor Solenoid Valve Model V526-6042-17)

The Valcor solenoid valves covered by this file are located inside

containment and are used for reactor head and pressurizer venting.

The valves are normally de-energized and are energized to open for

venting. Solenoid valves with plant equipment identification (ID)

numbers of SOV-596B&D and S0V-552-0 were reported to be qualified to

DOR Guidelines. Solenoid valves with equipment ID numbers of S0V-596A

have been replaced with new equipment and were reported to be quali- ,

fled to NUREG-0588.

In reviewing the EQ file, the inspector noted that the qualification

to D0R guidelines and NUREG-0588 was based on Wlcor Report QR526-5683-6.

This report has a list identifying similar valve models for which the

report could be.used as the bases for qualification. .Model V526-6042-17  ;

is installed at Haddam Neck, however, this valve was not included in

the list of qualified valves. During the course of this audit, the

licensee obtained a letter of "Certification of IEEE Qualification" i

dated November 9, 1987 which established that the test report also

applied to Model V526-6042-17. Prior to this inspection the licensee '

did not have data to support qualification of the installed valve. l

This item is in violation of.10 CFR 50.49 Pagragraphs (f) and (g) in

that qualification for Valve Model No. V526-6042-17 was not established

prior to receiving the November 9, 1987 letter. Paragraphs (f) and

(g) require that qualification of safety-related electrical equip-

ment / components must be completed prior to November 30, 1985. '

(213/87-28-11)

13.7 EQ File No. EEQ-CY-132 (Weed RTDs, Model Nos. N9004S-1B and N90040-1B) i

The inspector reviewed the EQ Reference File No. EEQ-CY-132 for Weed  !

Resistance Temperature Detectors (RTDs) model N90045-1B and '

N90040-1B to determine whether the package contained sufficient

evidence that these det'ectors are qualified for the environmental i

conditions in which they must operate during and following the

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Design Basis Events (DBEs).

Documents reviewed include:

Weed /SWRI Report No. 06-8680-TP Rev. 1, dated June 26, 1986.

SWRI/ Weed Report No. 06-8680-003 Rev. 1, dated June 1987.

Westinghouse Test Report No. 86-0450 Rev. 1, dated May 27, 1987.

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• Licensee Document NU Calculation PA-78-836-514-GE Rev. 1,

Calculation of Post-Accident Operability Time.

• License Document NU Calculation PA-78-836-515-GE Rev. 1,

Calculations of Aging.

• License Document EQ Reference File No. EEQ-CY-132-06, Accuracy

and Traceability Documentation.

• Franklin Research Report entitled "Technical Evaluation Report

Review of Licensee Resolution of Outstanding Issues From NRC

Equipment Environmental Qualification Safety Evaluation Reports

(F-11, B-60) NRC Docket 50-213, dated June 7, 1982.

• Licensee SCEW Sheets No. A-1-7 for Weed RTDs Model N9004S-1B,

dated November 12, 1987; and No. A-1-9 for Model N90040-1B,

dated November 12, 1987.

The Weed RTDs qualified using this file are located inside the

containment and are mounted on the main coolant loops. They are used

to measure hot and cold leg loop temperatures. The file stated that

the valves were to be qualified to NUREG-0588 Category 1.

In reviewing the above documents, the inspector noted that accuracy

measurements were not taken during the test on DBE simulation as

described in Weed /SWRI Report No. 06-8680. These RTDs are used to

initiate safety functions and to perform these functions they must

retain adequate accuracy during the accident. A loop accuracy

analysis was included in the file, File no. EEQ-CY-132-06. This

analysis used 1.5*. as the error for the Sensor Accident Accuracy

(SAA) term but justification for this value was not provided. In

response to this concern the licensee stated that the RTDs have a

3-wire circuit to compensate for temperature gradients and that the

terminal head of the RTDs at Connecticut Yankee are potted which

would essentially eliminate any leakage path. In addition, the

insulation resistance (IR) measurement taken after the test indicated

that the resistance was greater than 100 MD indicating that moisture

had not penetrated into the head. The licensee concluded that the 1

steady state accuracy would be maintained during the accident. A l

calculation was included in the file to evaluate the additional cable !

leakage due to the accidental condition. Using the steady state ac-  !

curacy for the RTO and the accident cable leakage, the Licensee  ;

calculated the expected error for the accident as less than .5% which I

is conservatively enveloped by the 1.5% used in the loop error l

analysis. The inspector concluded that this explanation adequately

resolved the concern.

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The inspector also noted that the temperatures for aging evaluation

and DBE simulation appeared to be based on the ambient temperature

without consideration of the. temperature use of the RTO head due to

conduction from the loop coolant. In response ta'this concern, the

licensee _provided a Weed Report No. N9004-87-A entitled "Weed Test

Report on Effects of Ambient and Process Temperature on Temperature

Inside Weed G.P. S.S. Head" dated June-5,1987. This report showed

by test that 15 F was a conservative bound for the temperature rise

due to conduction. The Licensee reported that the Weed /SWRI Report

No. 8680-TP demonstrated that the qualified life at a 135 F is greater

than 40 years. The qualified life for Connecticut Yankee, with an

aging temperature of 120 F and a 15 F temperature rise for conduc-

tion, is still greater than 40 years.

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In response to the concern for the DBE simulation, the licensee

provided revised calculations for post-accident operability time.

Using the 135 F to include the 15 F temperature rise from conduction,

the calculated post-accident operability time was much_ longer than

the specified one year. The licensee also' included a comparison of

the test temperature profile with the Connecticut Yankee profile.

The comparison showed that the test profile still had the 15 F re-

quired margin when 15 F was added to the Connecticut Yankee profile.

The licensee committed to revise the file to include the Weed Report

No N9004-87-A to provide documentation of the 15 F temperature rise

due to conduction, to include a discussion explaining that the 15 F

rise from conduction was incorporated in determining qualified life,

to include the revised calculation of post-accident operability time

and to include the comparison of the test temperature profile with

the plant profile with the 15 F rise from conduction added.

This item is unresolved pending NRC verification of licensee cor-

rective actions of revising the EQ file to include the Weed Report

No. N9004-87-A and the inclusion into their EQ file the calculation

with the added temperature rise due to conduction. (213/87-28-12).

13.8 EQ File No. EEQ-CY-101 (Gems DeLaval Level Transmitter Model

No. XM-54852)

The GEMS DeLaval level transmitters qualified using this file are

located inside containment and are used to detect containment flood

level. The file stated that the level transmitters were to be

qualified to NUREG-0588 Category 1.

In reviewing the above documents, the inspector noted that the

submergence test reported in the Wyle Report No. 45700-2 was

conducted for only 30 minutes. The required submergence time for

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plant service was not identified in the file nor was the adequacy of-

the 30 minute test discussed. In response to this concern the

licensee stated that the junction box of the transmitter was the

only part that was susceptible to submergence and this component was

located above flood level. The licensee committed to correct the

SCEW sheets and checklist in the file to clarify the installed

configuration and identify that qualification of the junction for

rubmergence is not required. The li ensee stated that even though

the junction box would not be submerged it was filled with DOW 710

silicone fluid to match the configuration used in the test.

This item is unresolved pending NRC verification of licensee correc-

tive actions to revise the file to reflect the installed configuration

and to clarify requirements for submergence. (213/87-28-13)

13.9 EQ File No. EEQ-CY-147 (Bishop Tape Splices W-963)

The inspector reviewed the EQ Reference File No. EEQ-CY-147 for

Bishop Tape Splices to determine whether the package contained

sufficient test data to support qualification of the Bishop Tape

Splice. In reviewing the file, the inspector noted that the file ,

data documents test data for a type W-942 tape and that reference

147.01, qualifies a W-963 tape for Radiation only. The file does not

address similarity of the W-942 and W-963 tape. Reference 147-02 and

147-03 addresses testing for the Okonite T-95 tape in a Wyle Report

No. 17722-1. Reference No. 147-04 describes the use of the Bishop

tape throughout the plant. Installation of the tape consists of '

wrapping the Bishop tape over varnished cambric in multiple layers

, with a final layer of Vinyl tape. There is no data to indicate this

splice configuration was tested for use in a harsh environment. The

licensee is in the process of having the Bishop tape analyzed for

their physical and chemical properties to further establish similarity

to the qualified Okonite T-95 tape.

Based on the above data, the inspector concluded that the Bishop tape '

,

is qualifiable. However, this item is in violation of 10 CFR 50.49

paragraphs (f) and (g) which require that electrical equipment '

important to safety be qualified and that qualification be completed

prior to November 30, 1985. (213/87-28-14)

14.0 Undocumented Cables Identified by the Licensee

During the week of November 9, 1987, while the plant was in its refueling

outage, the licensee identified 6 pieces of cables, about 3 feet long

each, whose qualification status was unknown. These cables are located ,

inside the reactor containment for 2 solenoid operated valves (S0V) and

one limit switch. The 2 S0Vs are used to operated.the 2 PORVs (PR-A0V-568 l

and PR-POV-570). The limit switch is used to provide position indication l

of pR-A0V-570. The license later identified these cables to be Anaconda

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Continental SIS 14 AWG XLPE insulated cables. No EQ file exists for these

cables nor are they listed in the EQ Master List.

During the week of the inspection, the licensee completed a preliminary

evaluation on the reportability of this event. This evaluation was

still being reviewed by the licensee's management. The result of the

evaluation indicates that the plant would be operable if an accident were

to occur.

The licensee determined to replace these cables with qualified ones. At

the time of the inspection, the replacement was not yet initiated.

However, the licensee committed to have these cables replaced before

restart.

The inspector concluded that, at the time of the inspection, the

qualification of these cables was not established because there was no

EQ file to support the qualification. This constitutes a violation of

10 CFR 50.49 paragraphs (f) and (g) which require electrical equipment

important to safety be qualified and that the qualification be completed

at a time no later than November 30, 1985. (213/87-28-15)

Following completion of this inspection, on December 3, 1987, the

licensee submitted additional information to NRC to justify the

qualifiability of the Continental SIS cables. The licensee stated that

they had located a test report issued by Patel for Calvert Cliffs plant,

report No. PEI-TR-860500-02 entitled "Final Test Report for Anaconda

Continental SIS Crosslinked Polyolefin cables used in the Calvert Cliffs

Nuclear Power Plant" dated January 23, 1986. The licensee maintained

that the test sample successfully passed.the LOCA/MSLB test and that the

test profile envelopes the Haddam Neck conditions, the samples had been

properly aged and irradiated.

15.0 Plant Walkdowns

The plant physical inspection consisted of an examination of specific EQ

electrical equipment selected from the Master List, Components selected

for inspection include solenoid operated valves, pressure / level transmit-

ters, Limitorque motor operated valves, cable splices, connectors, radia-

tion detectors, terminal blocks and wiring. Inspection characteristics

include mounting configuration, orientation, connection interface, model

number / type, physical condition and housekeeping.

Specific equipment examined consisted of:

• Temperature Element TE-4118, TE-413 and TE-413B

+

Solenoid Operated Valve No. 568, 552B

• Litton Connectors for SOV 596A, B & C

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• Conax Penetration RCP-11A, 3A and 6C

• Pressure Transmitters No. PT-403 and 401-1

• Names Limit Switches 32-PCW-568 V&L, 32-PCV-570 V&L

• Instrument Cable

• Cable Splices

• Limitorque Motor Operated Valves

i

15.1 During the inspection of.the above. items, the inspectors identified

Limitorque M0V-598 (covered by file No. EEQ-CY-122) and others on top  !

of the pressurizer with motor T-drains installed on top of the motor

and a broken gear case relief fitting on MOV-596.

The licensee indicates he will review procedures for' installing the

T-drains, make corrections and replace the broken gear case relief l

fitting prior to startup. This item is unresolved pending NRC

review of licensee corrective action. (213/87-28-16).

.

15.2 Namco limit switches on PORV A0V-568 (33-PCV-568 V&L) had.Raychem

Splices on their pig tail leads in a configuration that had not been

qualified by Raychem (file No. EEQ-CY-105) in that the splice seal  ;

length on the pig tail Nad wire was less than the 2 inches. The

overall splice length was 2 inch rnd 1 3/4 inch. Qualified Raychem

in-line splices are 6 inch overall. In response to this finding the i

licensee cited tne Wyle Laboratory recent testing (Wyle Report No.  !

17859-028) in which splices with as little as 1/2 inch overlap were

tested for DBE conditions enveloping those at Haddam Neck. The

referenced report is dated March 1987. There was no documentation

to indicate that the performance data from this testing had been

evaluated for the specific plant application at Haddam Neck. There

was no documentation to indicate splices seal length less than 2 inch ,

had been qualified prior to the Wyle report of March 1987.

This item is in violation of 10 CFR 50.49 paragraphs (f) and (g) .

which require that each item of electrical equipment important to l

safety be qualified and that qualification must be completed at no '

time later than November 30, 1985. (213/87-28-17)

16.0 Unresolved Items  !

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items or violations.

Unresolved item (s) identified during this inspection are discussed in

details, paragraph 5.0, 13.2, 13.4.1, 13.4.2, 13.4.3, 13.5, 13.5.2, 13.7,

13.8 and 15.1.

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17.0 Exit Meeting l

The inspector met with licensee corporate personnel and licensee

representatives (denoted in Details, paragraph 1 0) at the conclusion of

the inspection on November 20, 1987. The inspector summarized the scope

of the inspection and the inspection findings.

At no time during this inspection was written material given to the

licensee.

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