IR 05000213/1989200

Forwards Insp Rept 50-213/89-200 on 890130-0210.Deficiencies Re Procurement of commercial-grade Items Noted

ML20247K784
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/25/1989
From:	Varga S Office of Nuclear Reactor Regulation
To:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
Shared Package
ML20247J243	List: IR 05000213/1989200 ML20247J239
References
NUDOCS 8906020015
Download: ML20247K784 (7)

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UNITED STATES M .!"

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NUCLEAR REGULATORY COMMISSION  !

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LDocket No. 50-213'. I

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Mr.- E. J. Mroczka,: Senior. Vice President'

" . Nuclear Engineering and Operations Connecticut Yankee Atomic Power Company Post Office Box 270

' Hartford, Connecticut '06141-0270

Dear Mr. Mroczka:

SUBJECT: INSPECTION OF THE VENDOR INTERFACE AND' PROCUREMENT PROGRAMS AT'THE HADDAM. NECK PLANT (INSPECTION REPORT NO.: 50-213/89-200)

This letter transmits the report of the inspection conducted from January 30 through February 10, 1989, at the Connecticut Yankee Atomic Power Company (CY) Haddam Neck Plant (HNP), by Messrs. R. P. McIntyre,' S. D.! Alexander,

'J. J. Petrosino, W. P. Haass, and R. C. Wilson of'the NRR Vendor Inspection.

- Branch 'and A. E. Finkel_ of NRC Region I. The inspection was related to plant; site activities. authorized by NRC license number'DPR-61. At the conclusion of the inspection, our findings were discussed with Mr. D. B. Miller, HNP Station Superintendent, and the members of your staff' identified .in Appendix A of the enclosed inspection, report.:

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The purpose of the. inspection was to review implementation of the HNP vendor interface program'and the programs for the procurement of. items for use in safety-related applications. The inspection team reviewed the documentation

. of specific vendor-related technical issues,' including.10 CFR Part 21 notifica-tions received by HNP, and documentation concerning the procurement of both nuclear. safety grade and commercial grade items installed in safety-related systems, or stored'in the' warehouse.

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The"results of'the inspection indicate that weaknesses exist in the areas of procurement and dedication of commercial grade items and interfaces between HNP.

and'its vendors. During review of the procurement program and accompanying procedures, the inspection team identified deficiencies in the procurement of commercial grade items intended for safety-related applications and purchased prior to June 1988. These deficiencies included the failure to properly dedi-cate and provide documentation for certain commercial grade items procured for

- and: installed in. safety-related -systems. HNP failed to perform documented

' technical evaluations to identify attributes.such as the components' safety i

functions and critical characteristics. Verification of design and manufactur-E ing/ material changes, and receipt inspection requirements beyond a visual verification of identification and markings, and a check for physical damage were not evident.

8906020015 890525 PDR ADOCK 05000213 '

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Mr. E. May 25, 1989 {

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This resulted in the utilization of certain components of unverified quality in safety-related applications. Additionally, HNP failed to impose the require-ments of 10 CFR Part 21 on several vendors when the purchase orders specified that the components or items purchased must be in accordance with nuclear specifications.

An unresolved item concerning dispositioning of deviations was identified when reviewing procurement of services and equipment by Bechtel Power Corporation (as designee for Northeast Utilities and CY) for modification of the vital batteries and associated components. The inspectors could not determine whether CY is adequately controlling the disposition of deviations and nonconformances identified during procurement activities.

The review of the HNP vendor interface program indicates the need for improve-ment, especially as related to the assessment and implementation of corrective action on service and maintenance recommendations received from Morrison-Knudsen concerning the General Motors / Electro-Motive Division (GM/EMD) emergency diesel generators. CY failed to perform a documented evaluation of all the GM/EMD Power Pointers and Maintenance Instructions for their applicability to the HNP emergency diescl generators. This deficiency most likely was a result of the

'ailure to implement a site-level procedure for processing incoming vendor information. The review of the vendor interface program also identified a weakness in which certain vendor communications received by HNP describing potential safety concerns were improperly and/or incompletely assessed and dispositioned.

The inspection findings discussed above and in the enclosed report have been classified as Potential Enforcement Findings 50-213/89-200-01, 02, 03 and 04, and Unresolved Item 50-213/89-200-01(Enclosure 1). These will be referred to the NRC Region I office for appropriate action.

The inspectors noted that HNP's commercial grade procurement and processes for upgrading spare parts have been ao'"ing in plant procedures over the years, and that a separate procedure dt....., .th commercial grade procurement, upgrade and dedication was implemented in June of 1988. The procedure reflects the methods described in the EPRI NP-5652 guidelines for the use of comercial grade items in nuclear safety-related applications. This procedure, when fully implemented, should provide HNP reasonable assurance that comercial grade replacement parts and components, procured and dedicated under its provisions, will be suitable for safety-related applications.

We acknowledge the receipt of your letter, dated March 30, 1989, wherein you comitted to review a representative sample of installed commercial grade components using the dedication process described in procedure ACP 1.2-4.2,

"Comercial Grade Procurement, Upgrade, and Dedication Process," to assure {

that no operability concerns exist for installed equipment. {

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'Mr. E. TJ . Mroczka -4- .May 25, 1989 l

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i Gerald Garfield, Esquire' R. M. Kacich, Manager 0

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Day, Berry and Howard - Generation Facilities Licensing 1 Counselors at Law Northeast Utilities Service Company !

City Place Post Office Box 270 L Hartford, Connecticut 06103-3499 .

Hartford, Connecticut 06141-0270

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W. D. Romberg, Vice President D. O. Nordquist

. Director of Quality Services

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Nuclear Operations-Northeast Utilities Service Company Northeast Nuclear Energy Company Post Office Box 270 Post Office-Box 270 L Hartford, Connecticut 06141-0270 Hartford,' Connecticut 06141-0270 Kevin McCarthy, Director Regional Administrator-Radiation Control Unit Region I U.S. Nuclear Regulatory Comission

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Department of Environmental Protection State Office Building .

475 Allendale Road Hartford, Connecticut 06106 King of Prussia, Pennsylvania 19406 Bradford S. Chase,.Under Secretary Board of Selectmen Energy Division Town Hall Office of Policy and Management Haddam, Connecticut 06103 80_ Washington Street. .

Hartford, Connecticut 06106 J. T.- Shedlosky, Resident Inspector Haddam Neck Plant D. B. Miller,-Station Superintendent c/o U.S. Nuclear Regulatory Comission Haddam Neck Plant - Post Office Box 116 Connecticut Yankee- Atomic Power Company East Haddam Post Office RFD #1, Post Office Box 127E East Haddam, Connecticut- 06423 East Hampton, Connecticut 06424 G. H. Bouchard,, Unit Superintendent Haddam Neck Plant j

RFD #1 Post 0ffice Box 127E East Hampton, Connecticut 06424 i

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'n . [ i Mr., E. ' J. Hrocz ka -3- May 25, 1989

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'Should you have any questions concerning th'is inspection..we Wil'1 be pleased to discuss them with-you.

Siricerely, Original signed by:

G. C. Lainas for Steven A. Varga, Director i Division of Reactor Projects, I/II l Office of Nuclear Reactor Regulation i

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Enclosures:

1. Potential Enforcement Findings 2. Inspection Report No.: 50-213/89-200 with Appendices A and B cc: See next page DISTRIBUTION:

Docket Files 50-213 LBettenhausen, RI VIB Reading EHcCabe, RI 3 DRIS Reading Afinkel, RI

'CCentralj FileO -JLieberman, OE PDR LPDR-BKGrimes EWBrach )

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JPetrosino SAlexander RWilson WHaass JHSniezek

.SVarga GLainas i BVoger gfb/ -

JStolz AWang i g LShao j WKane, RI Triartin, RI l

• Previously concurred.

.[HADDAMNECKLETTER]

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, P0TENTIAL ENFORCEMENT FINDINGS Connecticut Yankee Atomic Power Company Docket No.: 50-213 I Haddam Neck Plant License No.: DRP-61 During the period of January 30 through February 10, 1989, representatives of j the NRC's Vendor Inspection Branch and Region I reviewed the vendor interface i and procurement programs of the Haddam Neck Plant (HNP). As a result of the {

inspection, and in accordance with the " General Statement of Policy and Proce- 1 dures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the NRC inspection team identified the following potential enforcement findings:

A. Potential Enforcement Finding 50-213/89-200-01 a I^

The NRC inspectors identified certain instances in which HNP installed commercial grade items (CGls) in safety-related systems without adequately evaluating their suitability for use in such applications. CGIs were procured without performing technical evaluations to identify attributes .

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such as the components'/ items' safety functions and critical characteris-tics. Verification of design and manufacturing / material changes, and receipt inspection requirements beyond a part number verification and check for physical damage were not evident. This programmatic deficiency resulted in the installation of certain components of unverified quality in safety-related systems.

The examples identified by the inspectors are listed in Section 1.A.1 of the inspection report.

B. Potential Enforcement Finding 50-213/89-200-02 The NRC inspectors identified several instances in which HNP failed to specify the orders (P0s)provisionsof10CFRPart21asbeingapplicableonpurchase for items intended for use in safety-related applications that specified that the components or items purchased must be provided in accordance with nuclear specifications or quality assurance requirements.

This did not meet the requirements established in 10 CFR 21.3 for the I definition of commercial grade items or 10 CFR 21.31 for specifying the  ;

provisions of 10 CFR Part 21 on procurement documents.  !

C. Potential Enforcement Finding 50-213/89-200-03 The NRC inspectors determined that until January 25, 1989, HNP had not established a formal documented site-level program, for the receipt, evaluation, and implementation of recommended corrective actions for incoming technical information received from vendors. As a result, only six of the issues contained in Power Pointers (PPs) and Maintenance Instructions (mis) received from the emergency diesel turer, General Motors / Electro-Motive Division (GM/EMD) generator manufac-

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l , received a documented evaluation for their applicability to the HNP. Although the six issues formally evaluated were appropriately dispositioned, HNP could not demonstrate that all the manufacturer's recommendations and corrective Enclosure 1 l

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. . POTENTIAL ENFORCEMENT FINDINGS -2-actions promulgated in PPs and mis had been accomplished. Additionally,

'the' governing emergency diesel generator maintenance and operating manuals were not maintained'in an up-to-date condition.

D. -Potential Enforcement Finding 50-213/89-200-04 The NRC inspectors identified four vendor communications describing potential safety concerns that were received at HNP but were improperly-and/or incompletely assessed for HNP applicability or were inadequately dispositioned. . In all four cases, however, HNP initiated corrective action.

to address NRC concerns before the end of the inspection. The four communications identified by the inspectors are described in Sections III.C and III.E of the inspection report and are listed below:

1. Westinghouse Technical Bulletin NSID-TB-86-07 concerning auxiliary pump assembly hold down bolts 2. Westinghouse Technical Ed11etin NSID-18-86-08 concerning ECCS injection of unborated water 3. Westinghouse Technical Bulletins NSID-TB-83-02 and 83-03 concerning DB-50 reactor trip breakers 4. Yalcor Engineering Corporation Letter, dated April 16, 1986, 1 concerning failure of valves with 17-7PH stainless steel spring material i E. Unresolved Item 50-213/89-200-01 l While reviewing procurement activities of Bechtel Power Corporation (BPC)

for services and equipment associated with the upgrade and modification of the vital battery and associated components, the NRC inspectors questioned .

the adequacy of BPC's dispositioning and closing of deviations identified '

in procurement activities. Bechtel, acting as designee for Northeast Utilities Service Company (NUSCO), was performing the modification activi- I ties at HNP. The inspectors could not determine if HNP was adequately controlling the disposit' ion and correction of deviations and nonconfor-mances identified during the battery upgrade and modification.

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