ML20010B973
| ML20010B973 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/16/1981 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20010B972 | List: |
| References | |
| 12046, NUDOCS 8108180562 | |
| Download: ML20010B973 (7) | |
Text
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U Consumers power James W Cook C0mpany via n,,u..,
nna e,,,,,,,,a,,,
and Con,truction General offices: 1945 West Parnall Road, Jackson, MI 49201 + (517) 788 0453 July 16,1981 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Huclear Regulatory Commission Region III 70"> Roosevelt Road Glen Ellyn, IL 60137 MIDLAND IPJCLEAR PLANT -
INSPECTION REPORT NO 50-323 81-11 AND 50-330/81-11 FILE:
0.h.2 SERIAL:
12046
Reference:
1.
NRC Letter, C E Norelius to J W Cook, dated June 16, 1981 This letter, including all attachments, provides Consumers Power Company's response to Reference 1 which transmitted the subject Inspection Report and which requested our written statement regarding four items of noncompliance described in Appendix A of Reference 1.
Consumers Power Company By
(
Je' as W Cook Sworn and subscribed to before me on this 16th day of July,1981.
dM bf BBVEIll A. AYB4 f
6 Notar3 Public, Jjf kson County, Michigan My commission expires January 16, 1985 MIS /lr CC:
PJCook, USNRC Resident Inspector Midland Nuclear Plant (1) 8108180562 810812 PDR ADOCK 05000329 0
PDR 0 Wul g,2
Serial 12046 CONSUMERS POWER COMPANY'S RESPONSE TO NOTICE OF VIOLATIONS DESC&I3Fp IN NRC INSPECTION REPORT NO 50-329/61-11 AND 50-330/81-11
- 1) Items 1(a) and 1(b) from Appendix A (Item of Nonecmpliance 329/81-11-02; 330/81-11-02 and 329/81-11-06; 330/81-11-05) provide:
"10CFR50 Appendix B, Criterion V, states in part:
' Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstancea and shall be accomplished in accordance with these instructions, procedures or drawings.'
Consumers Power Company's Quality Assurance Program Policy No 5, Revision 9, Paragraph 1.0, states in part:
' Instructions for con-trolling and performing activities affecting quality of equipment or op ations during the design, construction and operation phases of nuclear power plants, such as.
. construction, installation
.. are docunented in instructions, procedures, specifications, checklists and other forms of documents. '
Contrary to the above, as of May 1,1981, the following instances of failure to develop appropriate procedures were identified:
a.
Appropriate procedures had not been developed for tem-porarily supporting cable and cable coils in that Bechtel Power Corporation Procedure FPEeh.000, Installation of Electrical Cable, Revision 3, dated March 13, 1979, did not require that care be exercised to assure that the method of support of pulled or partially pulled cables would not result in damage to the cable jacket or exceeding the minimum bend radius criteria (Paragraph 6.7 of FPE-k.000). As a result, four cable jackets were damaged by the single coil of rope from which they were supported, and two cables were supported such that the minimum bend radii were exceeded.
b.
Appropriate procedures had not been developed for the routing of cables into the equipment to which they are terminated in that Bechtel Power Corporation Procedure FPE-7.000, Cable Terminations, Revision 7, dated December 26, 1979, did not establish measures to assure that the bend radius criteria (Paragraph 6.7 of FPE h.000) were not exceeded. As a result, cable 1336h0hA was observed to be routed into Motor Control Center (MCC) 1E64 such that a minimum bend radius was excecaed."
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- ~.
2 Serial 120h6 Consumers Power Company's Response to Item 1(a)
The corrective action of Bechtel NCR 3hl8 was to repair the four damaged cable Jackets with Raychem WCSF-N Shrink Tube per vendor print 7220-E-26-19-4.
This was accomplished on July 6, 1981.
Bechtel NCRs 3hl7 and 3404 vere written as a result of the NRC inspector's identification of two cables supported such that the minimum bend radii were exceeded. Project Engineering is scheduled to provide dispositions of NCR 3hl7 and NCR 3h04 by July 17, 1981.
Process corrective action was to revise FPE h.000, " Installation of Electrical-Cable," to f.nclude requirements thst coiled cables are properly supported, protected frcm damage and do not violate the minimum bend radius.
Inter-office memorandum 0-3885 was issued on May 15, 1981, to field construction
~
to provide interin instructions for coiling of cable until FPE-h.000, whi7h is presently in the review cycle, is approted.
Consumers Power Company's Response to Item 1(b) i Bechtel NCR 3h05 was written on the violation of minimum bend radius of cable i
1BB640hA terminated in MCC 1B6h. Field Engineering evaluated the dicerepancy umad determined that the portion of these cables of indeterminate quality -
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could be cut off and the remaining cable reterminated to meet design require-ments. The Field Engineering disposition is presently in the approval cycle.
FPE-7 000, " Cable Terminations," Revision 8, was implemented on May 21, 1981, i
to include the requirement that " bend radius for training cable / conductor j
shall be per vendor's requirements." This vill establish measures to assure l
that the bend radius criteria vill not be exceeded.
l
- 2) Item 2 from Appendix A (Item of Noncompliance 329/81-11-03) provides:
"10CFR50 Appendix B, Criterion X, states in part:
'A program for inspection of activities affecting quality shall be established i
and executed by or for the organization performing the activity to verify conformance with the documented-instructions, procedures and drawings for accomplishing the activity. '
Consumers Power Company's Quality Assurance Program Policy No 10, Revision 8, Paragraph 1.0, states in part:
' Inspection and surveillance ere performed to assure that activities affecting quality comply with documented instructions, design documents and applicable codes and standards.'
Contrary to the above, the electrical contractor's QC inspection of cable termination activities on September 25, 1980, failed to verify conformance to Paragraph 3.1 of Project Quality Control Instruction
. Attachment l' 3
Sarial 120h6 4
E-5.0 which states in part:
' Verify that the cables.
. are routed within the equipment without violation of minimum separation requirements.
As a result, the violation of the six-inch minimum separation requirement between class lE cable IAY001C and non-class lE cablea 1NBlT05A and 1NA05001A vas not identified."
Consumers Power Company's Response to Item 2 Consumers Power Company's NCR M-01-9-1-Ohl was written to address the non-conformance. As a result, the corrective action taken was to provide the required separation between the class lE and non-class 1E cables and verify that the separation requirementa of Drawing E-h7 had been met. The cables were independently verified by CPCo inspection to be re-arranged to meet the requirements on May 18, 1981.
Process corrective action to prevent recurrence was: 1) previde instrn: tion to termination creve on the need to meet the separation requirements of Drawing E-h7 in equipment, and 2) reinstruct all termination Quality Control Engineers (QCEs) on separation requirements for class lE cables, internal wiring of control panels and equipment.
The lead electrical superintendent confirmed that electrical termination superintendents and craft personnel were instructed on the need to meet the separation requirements on Drawing E-h7 in equipment. Instructions were documented on an inter-office memorandum dated May 28, 1981. Furthermore, a plastic coated criteria card with do's and don't's referencing color codine and separation distance between channels is given to each termination
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electrician on the jobsite.
The QCE involved was reinstructed in the requirements stated in Drawing E-47 for cable separati,n.
- 3) Item 3 of Apper.ix A (Item of Noncompliance 329/81-11-05 and 330/81-11-04) provides:
"10CFR50 Appendix B, Criterion XV, states in part:
' Measures shall be established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation.
. disposition and notification to affected organizations. '
Consumers Power Company's Quality Assurance Program Policy no 15, Revision 9, Paragraph 3.2, states in part:
'When a nonconforming item or activity is discovered or observed during design and con-struction for the Midland Project
. the responsible.
Consumers Power organization assures that the condition is docu-mented and that nonconforming items are tagged, marked,' segregated or controlled to prevent inadvertent use or installation.
Contrary to the above, on April 28, 1981, the inspectors identified 1h instances in which cable tray in the upper and lover cable spread-ing areas were not installed in accordance with the separation
h Sarial 12046 requirements delipoated in the Midland FSAR and which had not beer.
identified and controlled to prevent inadvertent use or installation.
Furthermore, documentation, disposition and notification to all affected organizations of these nonconformances was not in accordance with the established Quality Assurance Program requirements even though similar significant discrepancies had been identified 16 months earlier."
Consumers Power Company's Response to Item 3 As noted in the body of the NRC report, Consumers Power Company documented the nonconforming condition on a Nonconformance Report (NCR) in May 1979 Part corrective action on the two trays specifically covered by the NCR was initiated in July 1979 by physically _ moving one of the trays to~ provide space for barrier installation. The NCR has remained open to track completion of the part corrective action and the process corrective' action.
Late in 1979, the project determined that Marinite barriers were not the most suitable design approach for the present plant configuration. This resulted in removing from the drawings the barrier requirement in January 1980.
In the spring of 1980, a study was initiated as to the approach that should be taken to provide barriers when the required physical separation is not possible. A Bechtel inter-office memorandum (IOM) dated March lb,1980, documents the bnplementation of the study and acknowledges the hold placed on the use of the Marinite barriers. The same IOM reccgnized that the barrier installation vauld best be accomplished after cable pulling was complete.
In eltninating the Marinite approach, Project Engineering was confident that there was no serious risk in having to rework cable tray in order to install the barriers under evaluation.
It was known that physical conditions were being created that would require barriers. A SAR Change Notice was originated on August 21, 1980, which reflects the results of the study and the project's decision to use Kaovool or Cerablanket as a barrier or to utilize completely enclosed racevays. The lengthy time to obtain approval and incorporation of the SAR change was due to the further extensive reviews by Consumers and Bechtel Engineering. Specifically, this change affected the design approach to be used to meet new requirements on fire protection separation (twenty (20)-foot requirement). Revision 33 of the FSAR, dated April 1981, now reflects in Section 6.3.3.3.1 the design approach to be used where the physical separation distances specified in the SAR are unattainable.
On June 11, 1981, Bechtel's Project Engineering issued a Draving Change Notice against Drawing E-6hl, Sheet 7, Revision 1, to indicate proper barriers for cable trays 2AGC05 and 2NHLO1 which are identified on Consuners Power NCR M-01-4-9-Oh8.
Engineering is presently in the process of generating a set of drawings to be issued for construction showing areas of the plant where separation barriers are required to be installed.
It is anticipated that the subject drawings will be issued for construction by September 1, 1981.
The inspection for incorporation of barriers will be incorporated in PQCI E-3.0 (Final Electrical Area Completion Activities). Thio is consistent with installing barriers at the completion of cable pulling activities. As stated to various members of the Region III staff on May lb,1981, ve feel m
e.
5 Serial 120h6 there are no si nificant constructability problems antic (pated with the C
installation of the separation barriers.
Consumers Power Company will close out NCR M-01-h9-048 when all of the part corrective action is complete on the two, specific trays covered by the NCR and when we have assured the effectiveness of the process corrective action. This will be accomplished by the drawings showing the required barriers and overinspection of the PQCI E-3.0 inspection requirements.
b) Item 4 of Appendix A (Item of Noncompliance 329/81-11-07 and 330/81-11-06) provides:
"10CFR50 Appendix B, Criterion III, states in part:
' Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application.., are correctly translated into specifica-tions, drawings, procedures and instructions. '
Consumers Power Company's Quality Assurance Program Policy No 3, Revision 9, Paragraph 3.3, states in part:
'Each group or organi-zation performing detailed design translates the applicable regu-latory requirements, design bases, codes, standards and design criteria into design documents such as:
specifications, drawings...'
The FSAR in Paragraph 8.3.1.3 states in part:
'All class 1E equipment ~,
with the exception of the main and local control boards, are marked with an adhesive-backed color coded symbol.' IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations,. in Section 4.22 states in part:
In order to provide assurance that i
the requirements given in this document can be applied during the i
design, construction, maintenance and operation of the plant, the 4
protection system equipment
. shall be identified distinctively as being in the protection system. This identification shall distinguish between redur. dant portions of the protection system. '
3 Contrary to the above, as of May 1, 1981, the abcVe commitments had not been translated into specifications, drnings, procedures and instructions pertaining to the installation of field-mounted class 1E 4
instrumentation."
l Consumers Power Company's Eesponse to Item h f
Bechtel Project Engineering vill revise Specification 7220-J-218(Q) to refer-ence the requirements for color coding class lE instruments per 7220-E h7(Q)
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on or about July 31, 1981. Tnese requirements are currently specified in FSAR, Volume 14, Section 8.3.1.3, per class 1E terminal equipment. This 4
requirement does not apply to instrument process lines.
In addition, Specification T220-J-218(Q), Section 5 3.7, states that the instrur.ent Installation Summary (7220-J-705(Q)) is used to identify all e
6 Serial 120h6 redundant safety-related instruments and their impulse lines. The summary lists the "Q" status of the instrument. This specification provides the criteria for channel separation, however, it does not require any specific marking of the impulse lines.
WS/1r 7/16/81 O
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