IR 05000213/1987028

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-213/87-28

ML20155F458
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	06/08/1988
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
References
NUDOCS 8806160395
Download: ML20155F458 (2)

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Docket No. 50-213 Connecticut Yankee Atomic Power Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141 Gentlemen: Subject: Inspection No. 50-213/87-28 This refers to your letter dated May 6,1988, in response to our letter dated April 1, 198 Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed progra Your cooperation with us is appreciate

Sincerely, Orisinal signed Ey Jacque P. Durr, Chief Engineering Branch Division of Reactor Safety cc: D. B. Miller, Station Superintendent ! D. O. Nordquist, Director of Quality Services ' R. M. Kacich, Manager, Generation Facilities Licensing , W. D. Romberg, Vice President, Nuclear Operations ' Gerald Garfield, Esquire Public Document Room (PDR) Local Public Document Room (LPOR) Nuclear Safety Information Center (NSIC) y d , ! NRC Resident Inspector l ' State of Connecticut

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l l OFFICIAL RECORD COPY RL HN 87-28 - 0001. /27/88 8806160395 880608 l PDR ADOCK 05000213 ! _ _ - _ - _ _ _ - _ _ . _ _ _ _ _ _ _ p DCD

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. . , Connecticut Yankee Atomic 2 Power Company bec: Region I Docket Room (with concurrences) Section Chief, DRP W. Raymond, SRI, Millstone 1&2 A. Wang, LPM, NRR R. Bores, DRSS

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0FFICIAL RECORD COPY RL hH 87-28 - 0002. /27/88

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. . s NORTHEAST UTILITIES c.n.ro on,c.. . s.io.n si,..i. e.,nn. conn.ci,cui 1 5iIi c$E P.o Box 270

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H ARTFoRD. CONNECTICUT 061410270 k L J [,7,232 [.C.',. (203) 665 5000 May 6, 1988 Docket No. 50-213 A071T5 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) V. Johnston letter to E. J. Mroczka, transmitting Inspection No. 50-213/8'-28, dated April 1, 198 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 Noven.ber 16-20, 1987 of the Haddam Neck Plant equipment qualification program. During that in-spection, two violations of NRC regulations were identifie Connecticut Yankee Atomic Power Company (CYAPCO) hereby provides its response to the identified violation 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 .... l l T ouVlh[} r~ R, (/) m

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. sDr. Williaa V. Johnston    l A07155/Pags 2 May 6, 1988    '
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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 / procedure This is a Level IV violation (supplement I).

Root Cause CYAPCO's investigation identified several contributing factors related to the cause of the even These are: o The Maintenance Procedure utilized and the technical infor-mation provided were inadequat o The grease plug and other pipe plugs are similar in design and in close proximit o "Hands-On" training prov.ded had been performed using older style MOV o The supervision of this effort was not adequat The super-visor did not provide adequate instruction or job oversigh The root cause of the event has been independently assessed via the Human Performance Evaluation System (H{{S) 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 operator o Training on EEQ MOVs was .vailable for Maintenance Department personnel, but was not attended by the foreman of this jo o The procedure for performing routine, preventive maintenance on EEQ Limitorque motor operators is inadequat It does not address the presence of motor T-drains or the gear box grease relief fittin o Inadequate supervision was provided. The person in charge, an electrician temporarily upgraded to foreman, had not received hands-on training ;n this EEQ equipmen (1) These activities were performed under a program put in place and executed by the corporate Nuclear Safety Engineering group.

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, , Dr. Willice V. Johnston A07155/Pags 3 May 6, 1988 Corrective Action o Each of the affected motors has been disassembled, inspected, degreased, reassembled with new bearings, and reteste These actions were performed using approved station procedures under the cognizance of the motor manufacture These MOVs have been declared operabl 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 performe 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 equipmen 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 QA involvement will be re-evaluated. This will be completed prior to the next refueling outage (currently scheduled to start in August 1989) and will include a checklist for EEQ Concern 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 outag 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, 198 Violation l Contrary to the above, on November 20, NRC inspectors identified l

the following items for which the licensee had not established qualification prior to this inspectio ) Qualification of Rockbestos Firewall SR cable for submergence was not established, l I

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. . $r. Willica V. Johnston AC7155/Pago 4 May 6, 1988
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Root Cause The file preparer failed to explicitly evaluate the submerged conditio 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 cource 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 cabl 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 submergenc 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 l conditio Corrective Action A summary of the qualification data available in the files on Rockbestos SR, and Kerite cable which described how the existing l information should be evaluated in concluding that the subject l 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 cabl __ __

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- I Dr. Williaa V. Johnston A07155/Page S May 6, 1988 Action to Prevent Recurrence All cable qualification files will be reviewed fur Haddam Neck to ensure that cables requiring qualification fo't submergence include adequate discussions of the reasoning behind our conclusion that the cables are in fact qualified for submergenc 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 outag 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 eaternal conduit configutation gave ao indication that the arrangement was anything other than the scandard configuratio It was therefore not opened for inspection, and was never discovered until work was done on the circuit during the outag Corrective Action The unidentified wire was replaced. The SOV and limit switch circuit is now in a fully qualified configuratio A test report which qualified the wire discovered in the junction box was obtained shortly after the conclusion of the audi 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 existe The test report qualifying the Raychem splice ccafiguration discovered during the audit walkdown will he incorporated into the Raychem fil 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 pr? gram, 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 futur l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _

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Violation 4) Qualification of Bishop tape Splice by similarity was not establishe The splice is qualifiabl ,

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Root cause Bishop tape was qualified by analyzing similarity between it and a tape which had been type teste 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 necessar 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 refualing outag 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 outag Violation 5) Qualification of solenoid valve No. 526-6042-1 by similarity not established prior to this inspectio Root Cause Information linking the tested equipment to the installed equip-ment was omitted due to a lack of thoroughness during the initial file preparatio Corrective Action Just prior to the audit, supplementary information was obtained , which established the similarity between the tested and installed I equipment. Qualification was therefore established by similarit 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 l established in the qualification files. This review will be i completed prior to the start of the next refueling cutage.

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Violation 6) Qualification of Raychem splice (seal length) on Namco switches not establishe 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 splice This was completed in September 1987. No short seal lengths were discovered in the incpection and therefore the test report which qualifies short seal lengths was not added to the Raychem file The short seal length was found during the audit walkdow Corrective Action The unidentified wira 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 audi 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 existe The tent report qualifying the Raychem splice configuration disc ered during the audit walkdown will be incorporated into the Raychem fil 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 futur ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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If you have any questions related to the above, please feel free to contact my staff directl Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY

     # w<p E. J  'r cz Sen or Vice  resident 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
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