IR 05000329/1981011
| ML20005A631 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/03/1981 |
| From: | Gardner R, Love R, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20005A618 | List: |
| References | |
| 50-329-81-11, 50-330-81-11, NUDOCS 8106300517 | |
| Download: ML20005A631 (9) | |
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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMEYT REGIO.\\ III Report Nos.: 50-329/81-11; 50-330/81-11 Docket Nos. 50-329; ;0-330 License Nos.: CPPR-81; CPPR-82 Licensee: Consumers Fower Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Plants, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted:
April 28-30 and May 1, 1981 h
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Inspector:
P.. N. Gardner
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R. S. L ve s
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6 $ WhiW Approved By:
C. C. Williams, Chief 3/8/
Plant Systems Section
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Inspection Summary Inspection on April 28-30 and May 1, 1981 (Report No. 50-329/81-11; 50-330/81-11)
Areas Inspected: Observation of electrical installation activities, review of instrumentation installation - specificatt 2s and procedures, review of QA implementing procedures. This inspection involved a total of 66 inspector-hours onsite by two NRC inspectors.
Results: Of the three areas inspected, four apparent items of noncompli-
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ance (Criterion V - examples of failure to establish procedures - Paragraphs (
1.b. and 2. ; Criterion X - failure to perform adequate inspection - Para-graph 1.c.; Criterion XV - failure to identify and control nonconforming components - Paragraph 1.d.; Criterion III - failure to translate design criteria into drawings and s pecifications - Paragraph 3.a.) were identified l
in three areas.
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DETAILS Persons Contacted
Consm',ers Power Company
- W. R. Bird, Manager of QA
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- J. W. Cook, Vice President
- T. Cooke, Project Manager
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- E. Jones, IE&TV
- D. R. Keating, IE&TV
- H. P. Leonard, QAE
- D. Miller, Site Manager
- B. H. Peck, Construction Supervisor
- M. Schaeffer, QAE Bechtel Power Corporation
- W.-J. Crr.el, CQCE
- L. Davir, Site Manager
- M. A. D:.etrick, PQAE
- E. Smith, PFQCE U. S.' Nuclear Regulatory Commission, Region III
- H. Cook, Resident Inspector
- Denotes those present at the exit interview.
Licensee Action on Previous Inspection Findings (0 pen) Unresolved Item (329/80-01-03; 330/80-01-04):
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During a previous inspection it was determined that there was no specific requirement to verify conformance of installed instrumentation with the separation criteria, based on the assumption that the installation drawings adequately reflect the separation criteria. As indicated in Inspection Reports No. 50-329/80-01 and No. 50-330/80-01 the licensee intended to revise Quality Control Instruction (QCI) I-1.10 to emphasize separation criteria verifications. To date, QCI I-1.10, Revision 2, dated April 16, 1981 does not address this requirement. Review of the subject QCI will be-made during a subsequent inspection.
Functional or Program Areas Inspected 1.
23servation of Electrical Work Activities a.
The RIII inspectors observed numerous instances in which the ends of Class IE cables were not sealed after the cables had been pulled or partially pulled. Specific examples identified were:
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(1) 2AFWO96B pull box in room 351.
(2) 2AD1001AS panel 2D10.
(3) 2AD1001AT panel 2D10.
(4) 2BB2408C MCC 2B24.
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IBWO20G Service Water Building.
The inspectors reviewed the 3echtel Power Corporation Procedure FPE-4.000, "Installat!
of Electrical Cable", and observed that the sealing of cable ends is not addressed in this procedure.
The sealing of cable ends is addressed in Field Instruction FIE 4.100, " Receiving, Storage and Identification of Cable", which states in Paragraph 4.3 that " Cable ends shall be sealed by use of end caps or_ tape except when in process of cutting or pulling."
The licensee informed the inspectors that the sealing of cable ends is only required during cable storage such as in the cable reel yard and that the licensee does not consider the sealing of cable ends of pulled or partially pulled cables to be of significant importance in assuring the quality of Class IE cables. The licensee was requested to provide an engineering oasis for the aforementioned position and pending review of that basis this is an unresolved matter.
(329/81-11-01; 330/81-11-01).
b.
The RIII inspectors observed the licensee's method for tempor-arily supporting cable and cable coils of pulled or partially pulled Class IE cables. The RIII inspectors observed the following:
(1) Class IE cables 2BQ403N, 2BB2430G, 2BB2431N and 2BB2430E were observed to have gouges in their outer jackets as a result of their being supported by a single coil of rope.
These four cables were supported by that coil of rope along with numerous other cables.
(2) Class IE cables 2AB6304D and IBD2001AA were supported in a manner'which resulted in exceeding their minimum bend radius.
(3) Class IE cable IBWO20G was supported by a small gauge bare wire.
The RIII incpectors reviewed the Bechtel Power Corporation Procedure FPE-4.000, " Installation of Electrical Cable",
Revision 3, and observed that the procedure does not address a method for temporarily cupporting cable and cable coils nor does it require that care be exercised to assure that during the temporary supporting of such cable, damage to the cable jacket and exceeding the minimum bend radius be avoided.
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The inspectors informed the licensee that the above is an example of failure to prescribe activities affecting quality by documented procedures and that this was an item of noncompliance, contrary to the requirements of Criterion V of 10 CFR 50, Appendix B.
(329/81-11-02; 330/81-11-02)
c.
The RIII inspectors observed that class IE cable IAY001C at panel IC47 in ti:a main control room was not separated from non-class 1E cables INBl?CSA and INA05001A by the separation criteria identified
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in Bechtel Quality Control Instruction E-5.0.
Paragraphs 3.0 and 3.1 of E-3.0 states "The following inspection activities shall be performed to assure that the completed work meets the quality requirements '... verify that the cables or field jumpers are routed within the equipment without violation of minimum separ-ation require.nents... "The date of QC inspection for cabl-1AY001C is identified on inspection records to be Septembu 25 1980 while the date of termination of the aforementioned non-class IE cables was identified by the iicensee to be May 8, 1979 and May 29, 19/9. The lack of required separation was not identified prior to the NRC inspection.
The inspectors informed the licensee that the failure to perform an adequate inspection is an example of an item of noncompliance, contrary to che requirements of Criterion X of 10 CFR 50, Appendix P (329/81-11-03)
d.
The RIII inspectors observed 14 instances in which cable tray in the upper and lower cable spreading areas were not installed in accordance with the separation criteria specified in the Midland FSAR. Paragraph 8.3.1.4.1.1 of the Midland FSAR states that "The minimum senaration distance between redundant Class 1E cable trays is 1 foot between trays separated horizontally and 3 feet between trays separated vertically." Paragraph 8.3.1.4.1 of the Midland FSAR states "Non-Class IE circuits are separated from Class IE and associated circuits by the minimum separation requirements speci-
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fied in Subsections 8.3.1.4.1.1..."
The following instances were identified in the lower cable s
spreading area:
(1) 6 inch vertical separation between Class IE tray 1AGB08 and non-Class IE tray 1NTG13.
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(2) 7 inch vertical separation between Class 1E tray 1ATF14 and l
non-Class IE tray INHK03.
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(3) 7 inch horizontal separation between Class 1E tray 1AGB06 and non-Class IE tray 1NJS04 (4) 21 inch. vertical separation between Class 1E tray 1AGEC2 and
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l non-Class 1E tray INGJ07.
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(5) 8 inch vertical separation between Class 1E tray 2AGM05 and non-Class 1E tray INFD26.
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14 inch vertical separation between Class IE tray 2CFA01 and non-Class 1E tray 2NJY05/06.
(7) 4 inch vertical separation between Class IE tray 2AFC08 and non-Class IE tray 2NGA02.
(8) 4 inch vertical separation between Class IE tray 1AGL10 and Class IE tray ICFA01.
(9) 5 inch horizontal separation between Class IE tray 1AFLO4 and Class 1E tray ICFa01.
(10) 6 inch vertical separation between Class IE tray 2CGB02 and Class 1E tray 2AGH02.
The following instances were identified in the upper cable spreading area:
(1) 8 inch vertical separation between Class IE tray IBJS01 and non-Class IE tray 1NTP01.
(2) 4 inch vertical separation between class IE tray IBFD10 and non-Class 1E tray INFG05.
(3)
18 inch vertical separation between Class IE tray 1DFA05 and Class IE tray 1BGB09.
(4) 4 inch vertical separation between Class IE tray IBFD02 and non-Class IE tray INFG07.
The FSAR, in Paragraph 8.3.3.3, states "Where the physical separa-tion distances specified in Subsection 8.3.1.4 are unattainable, barriers are installed or enclosed raceway is utilized to maintain the independence between redundant Class 1E and between Class 1E and non-Class 1E systems."
The RIII inspectors, in reviewing the pertinent raceway installa-tion drawings and in discussions with the licensee, determined the following:
(1) There are no requirements for the installation of raceway barriers or enclosures indicated on the raceway drawings.
The licensee stated that barriers had been identified pre-viously but were removed from all drawings in January 1980.
(2) The licensee stated that the aforementioned instances of inadequate separation between trays in the cable spread rooms had not been previously identified and documented. Each of the above trays had been inspected anu released for cable installation and each contained cable.
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(3) There are no comprehensive in-place controls to assure that either the required separation distance between trays will be attained or that barriers will be installed in lieu of the separation distance requirements.
(4) The licensee had previously initiated NCR M-01-4-9-048 dated May 2, 1979, which identifiud a violation of the separation criteria for two trays in the lower cable spreading areg While the Midland Project Quality Assurance Department letter to Bechtel Power Corporation dated January 8,1981, identifies the licensee's awareness that the separation barrier for the two nonconforming trays was not reflected on the installation drawing, there is no indication that established controls (e.g., Nonconformance Report (NCR),
Quolity Action Requests (QAR), Managemenc Corrective Action Report (MCAR), hold tags, etc.) were implemented for the remainder of the nonconforming trays (of which 14 instances are identified above).
As described above, the licensee recognized 16 months ago that significant inadequacies and discrepancies existed involving raceway separation / fire barrier installations, and the related construction and erection documents.
The fundamental adverse conditions and the potential scope of the problem is partially documented only in inter-office letters.
There is no comprehensive Quality Assurance / Control document such as an NCR, MCAR, QAR or other " cont rolled" document associ-ated with this matter. The licensee, as indicated previously, did identify two instances of separation / fire barrier inadequacy on NCR M-01-4-9-048, however, this NCR identifies inadequate clearance (5/8") between Class IE tray 2AGC05 and non-Class IE tray 2NHL01 such that the tray to barrier separation criteria could not be met. The fire barriers discussed above were identified on the installation drawings at the. time this NCR was initiated.
It appears that as a result of not handling this adverse quality issue comprehensively within the scope of the Midland QA Program, the adverse coedition has been compounded in that:
(1) The impact of continuing raceway and electrical cable installation on the future identification, control and resolution of the noted discrepancies has not been documented.
(2) The location and extent of the raceway separation noncon-formances (without any construction document indicating the need for and type of barrier) has not been established, although raceway has been released for electrical cable installation and cable installation is currently preceding at 100,000 feet per week.
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(3).The corrective action taken to date is incomplete and has not been prompt.
The RIII inspectors informed the licensee that failure to identify and control the above nonconforming conditions in accordance with QA program provisions to prevent inadver-tent use or installation is an item of noncompliance, contrary to the requirements of Criterion XV of 10 CFR 50, Appendix B.
(329/81-11-04; 330/81-11-03)
e.
The RIII inspectors observed that vendor wiring in C1'a:s IE Battery Charger ID17 is terminated with spaded lugs. The RIII inspectors will review the desiga criteria and qualification documents for Battery Charger 1D17 to assure that proper con-sideration was given to the use of spaded lugs in lieu of ring type lugs normally used in seismically qualified Class 1E equipment. This matter is unresolved.
(329/81-11-05; 330/81-11-04)
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f.
The RIII inspectors selected five Class IE electrical cables which had been install?d in Units 1 and 2.
The routing of each cable was compared with the routing requirements identified on the respective pull cards. The inspector observed the following:
(1) 600 volt control cable 2BB1806T was observed to be routed correct.!y at routing points 2BSL364, 2BJB036, 2BJB01, 2BJB02, 2BJM01, 2BJA04, 2BJA05, 2BJE01 and 2BJ034.
(2) 600 volt control cable 2BB1807L was observed to be routed correctly at routing points 2BSL363, 2BKF15, 2BJB037, 2BJB01, 2BJB02, 2BJB03, 2BJF01, 23FL11 and 2BFLO3.
(3)
125 volt D.C. power cable 1AD1001AG was observed to be routed correctly from Battery Charger ID17 to 125 volt Switchgeac 1D10.
(4) 600 volt control cable 1AB6302A was observed to be routed correctly from panel IB63 to panel 0F75A.
(5) 600 volt control cable 1AB5514A was observed to be routed correctly at routine points 1ASL905, 1AJM06, IAJA05, 1AJC01, 1AJB07 and IAJB08.
The RIII inspectors observed that the raceway internals were free of hazardous debris and sharp edges. Conduit bushings were installed as required. The cables and raceways were
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properly identified and undamaged. The cables were routed as specified and no separation problems were identified.
g.
The RIII inspectors observed the following raceway installation drawings located in the upper cable spreading area:
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(1) E-o30(Q) sheet 2 of 2; Revision 2.
(2) E-631(Q) sheet 1 of 2; Revision 11.
(3) E-631(Q) sheet 2 of 2; Revision 1.
(4) E-640(Q) sheet 3 of 6; Revision 6.
'(5) E-640(Q) sheet 6 of 6; Revision 1.
(6) E-641(Q) sheet 1 of 7; Revision 14.
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The RIII inspectors verified that the above documents were of the current v<n sion.
2.
Review of QA Implementing Procedures - Terminations The RIII inspectors observed that Bechtel Power Corporation Field Procedure FFF-7.000, " Cable Terminations", does not address the requirement that the minimum bend radius of Class IE cables should not be exceeded during the routing in of these cables into the equipment to which they are to be terminated. During the RIII inspectors' observations of installed cables they observed Class 1E cable 1BB6404A routed in'.o Motor Control Center (MCC) IB64 such that the minimum bend radius for that cable was exceeded.
The Bechtel Fower Corporation Quality Control Instruction PQCI E-5.0 for cable terminations in Paragraph 3.11 states that Quality Control (QC) during the final inspection activities shall " Verify that the cable or jumper is supported using approved cable ties and the minimum installed cable bend radius is not violated." This, however, is not an in-process inspection which therefore does not provide assurance that during the routing in of Class 1E cables the required
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minimum bend radius will not be exceeded and later not detected.
The inspectors informed the licensee that the above is an example of failu e to prescribe activities affecting quality by documented procedures and that this was an item of noncompliance, contrary to the requirements of Criterion V of 10 CFR 50, Appendix B.
(329/81-11-06; 330/81-11-05)
3.
Review of Instrumentation Installation - Specificatior.s and Procedures The RIII inspectors reviewed Bechtel Power Corporation Specification J-218(Q), Revision 12, titled " Technical Specification for installation of field mounted instrumentation for Nuclear Services" which identifies the requirements for the installation of field mounted instruments and instrument impulse lines. The inspectors determined the fellowing:
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In reviewing Specification J-218 and in discussions with the licensee, it was determined that there is no requirement that either the field mounted Class IE impulse lines or the associ-ated process system instruments (e.g. flow transmitters, pre-ssure transmitters, temperature detectors, etc.) be identified in such a manner which distinctively identifies t'aat item as being a part of the protection system.
The above condition is contrary to the requirements of Paragraph 8.3.1.3 of the Midland FSAR which states, in part, "All Class IE equipment, with the exception of the main and local control boards are marked with an adhesive-backed color coded symbol."
Further, IEEE279-1971, " Criteria for Protection Systems for Nuclear Power Generating Stations", in Section 4.22 states, in part, "In order to provide assurance that the requirements l
given in thit focument can be applied during the design, con-struction, maintenance, and opera tion of the plant, the pro-tection system equipment... shall be identified distinctively as being in the protection system. This identification shall distinguisi4 between redundant portions of the prctection system."
The inspectors informed the licensee that the failare te assure that the above requirements were correctly translated into specifications, drawings, procedures and instructions is an example of.an item of noncompliance, contrary to the require-men'.s of Criterion III of '10 CFR 50, Appendix B.
(329/81-11-07; 330/81-11-06)
Unresolved Matters Unresolved matters are items about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolvel items disclosed during the inspection are discussed in Paragraphs 1.a. and 1.e.
Exit Interview The inspectors met with licensee representatives (denoted under Persons Contarted) at the conclusion of the inspection on May 1, 1981. The inspectors summarized the scope and findings of the inspection. The licensee acknowledged the information.
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