ML20024F286
| ML20024F286 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/29/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 23770, 83-06#1, 83-6#1, NUDOCS 8309090217 | |
| Download: ML20024F286 (9) | |
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C0HSumBIS power u,,,e,, o C0mp8ny vic< erc <=c - Proicct s"si <ci s and Construction General offices: 1945 West ParneH Road, Jackson, MI 49201 * (517) 78& O453 August 29, 1983 83-06 #1 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Il 60137 MIDLAND ENERGY CENTER PROJECT DOCKET NOS 50-329 AND 50-330 ELECTRICAL RACEWAY SYSTEM NONCONFORMANCES FILE:
0.4.9.78 SERIAL:
23770 On July 29, 1983 W R Bird notified Mr R Gardner of your staff of a 10CFR50.55(e) condition involving nonconformances in safety-related electrical raceway systems.
This letter is an interim 10CFR50.55(e) report. The attachments to this letter describe the concern and summarize the invescigation and corrective action taking place.
As discussed in Attachment 2, Bechtel Project Engineering has concluded that deficiencies which would have any significant effect on the safety of-plant j
operations are not likely to exist. This conclusion is based on engineering evaluation of a significant portion of existing raceway systems.
[
8309090217 830829 PDR ADOCK 05000329 S
'o 1
OC0883-0012A-MP01 1
If
e 2
Serial 23770 83-06 #1 Consumers Power Company supports the Bechtel conclusion. However, a final
-determination will be made when the construction review program and 100%
. quality control reinspection have been completed.
Another report, either interim or final, will be sent on or before October 28, 1983.
- hAnaJ, JWC/WRB/cd CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear. Plant Attachments:
- 1) MCAR-1, Report No 70, dated July 29, 1983
- 2) MCAR-70, Final Report, dated August 23, 1983 OC0883-0012A-MP01-
3 Serial 23770 83-06 #1 CC: CBechhoefer, ASLB Panel LBernabei, GAP FPCowan, ASLB Panel JHarbour, ASLB Panel AS&L Appeal Panel
~MMCherry, Esq MSinclair BStamiris CRStephens, USNRC WDPaton, Esq, USNRC FJKelley, Esq, Attorney General SHFreeman, Esq. Asst Attorney General WHMarshall GJMerritt, Esq TNK&J INPO Records Center Creat Lakes QA Managers OC0883-0012A-MP01 I
I AI A0021 Priority: 02 Trend Code: B-3, K-9 S.U. PGM000
/,3d4d QUAUTY ASSURANCE PROGRAM i
MANAGEMENT CORRECTIVE ACTION REPORT MCAR 1 REPORT NO. MCAR 70 JOB NO.
7220 Q NO.
DATE 7/29/83 4
l' DESCRIPTION (including references):
Various discrepancies have been identified regarding electrical raceway (includes cable tray and conduit) and raceway supports:
1.
Raceway and raceway supports not installed in accordsuce with the design.
2.
Project Engineering drawings for cable tray supports lack proper specifi-city and/or completeness to assure correct installation and inspection.
(continued)
- RECOMMENDED ACTION (Optional) 1.
Project Engineering to develop and implement a plan to review cable tray support drawings for lack of specific design criteria and revise to clarify the design where necessary.
2.
Construction to develop and implement a status assessment plan for Field Engineering review and QC inspection of raceway and raceway supports, including training of appropriate personnel.
3.
Engineering and construction to determine the root cause of the discre-pancies and take action to prevent recurrence.
REFERRED TO 10 ENGINEERING E CONSTRUCTION [E QA MANAG MENT O
O PROCUREMENT ISSUED BY N[M-7 -M-E3 6 t-Project GA Eng$
Den
- bW TN//Mm 11 REPORTABLE DEFICIENCY See note on page 2.
NOTIFIE UENT O NO 13 YES
~
% Mene t y
/
111 CAUSE CORRECTIVE ACTION TAKEN
-l AUTHORIZED BY Date STANDARD DISTRSUTION ADDITIONALDISTRBUTION AS APPROPRIATE ENONEERNG MANAGER FORMALREPORTTO CUENT DevesON QA MANAGER Da#
MANAGER OF QA BPC PROJECT ENGINEER (if Sectionll AppEes)
GPO - QA MANAGER QE N CONSTRUCTION MANAGER SFPD QA MANAGEp; PROJ SUPT /PROJ CONSTR MANAGER PROJECT MANAGER CHIEF CONSTR OC ENGNEER CUENT CORRECTIVE ACTION.lMPLEMENTED DMSION PROCURENT MGR PROJ PROCUREMENT MOR PROCUREMENT SUPPUER OUAUTY MOR AND DfV SUPPUER QUAUTY MOR VERIFIED BY Propect OA Engeiser Date
- Descrae in space provided and ettech reference document.
AAPD 0161
9
'p%, p* '
1 MCAR 70 Page 2 123843 Description continued:
3.
Raceway and raceway supports previously inspected and accepted by field quality control have been subsequently found to be nonconforming to the design.
The above deficiencies were initially addressed by NCR M01-9-3-033, SCRE 78 and CPCo MCAR/R DN-2.
NOTE:
Engineering analysis on the problems noted to date have not resulted in any safety concerns; however, it is recommended that this condition be reported because many of the raceway and raceway supports have not been evaluated which causes their present status to be indeterminant. During the status assessment plan, all nonconformances (not including design change items) will be documented on a nonconformance report and processed in accordance with programatic requirements.
J l
Bechtel Associates Professional Corporation 126548
,265a4
SUBJECT:
MCAR 70 Discrepancies Regarding Electrical Raceway and Raceway Supports FINAL REPORT DATE:
August 23, 1983 PROJECT:
Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Introduction This provides the status and the course of corrective action required by Management Corrective Action Report (MCAR) 70.
Description of Deficiencies NCAR 70 concernc deficiencies in electrical raceway and raceway supports. These deficiencies fall into three categories:
1.
Raceway and raceway supports not installed in accordance with the design documents 2.
Design drawings for cable tray supports that are not specific or complete 3.
Raceway and raceway supports previously inspected and accepted by quality control that have been subsequently found not conforming to the design documents These concerns have already been addressed by Nonconformance Report, NCR-M01-9-3-033, Safety Concern and Reportability Evaluations, SCRE 78 and Consumers Power Company Management Corrective Action Report, MCAR/R DN-2.
Investimative Backaround This concern was identified during an overinspection by the Midland Project Quality Assurance Department (MPQAD) of electrical raceway and raceway supports in the auxiliary building.
Analysis of Safety Implications A safety evaluation was performed for the cases identified in SCRE 78, and specifically to investigate the nonconforming conditions identified in NCR-M01-9-3-033 and NCAR/R DN-2.
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Bechtel Associates Professional Corporation 126548 E M 70 126554 Final Report August 23, 1983 passe 2 P
Engineering evaluated the electrical raceway and raceway support discrepancies. Calculations were performed to evaluate the structural adequacy of the existing conditions.
In $11 cases, the raceway and raceway supports were shown to have margins sufficient to ensure adequacy and no conditions were found that would affect the safe operations of the Midland plant.
A separate review, which to date has included more than 50% of the raceway supports, has identified no safety concerns and no conditions more severe than the nonconformances identified above. This is due to conservatisms in design and analytical techniques. A seismic raceway and support status assessment program has been developed to ensure that as-constructed conditions will be in accordance with design requirements and any nonconformance reports (NCRs) will be evaluated in accordance with the Consumers power Company program to assign disposition to NCRs.
probable cause 1.
Construction Nonconformances Supports were not installed in accordance with the design. This was due to congestion, which created many constructibility problems, and to the practice of attaching conduits to cable tray supports without engineering approval.
Engineering approval was not obtained before changing the support configuration, nor was clarification obtained when drawings were not clear or complete.
2.
Engineering Some cable tray support drawings did not have sufficient detail to allow for adequate ir,stallation.
3.
Quality Control Inspection procedures were not followed.
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Bechtel Associates Professional Corporation 126548126554 NCAR 70 Final Report August 23, 1983 Page 3 Corrective Action 1.
Construction A seismic raceway and support status assessment program will be used for reviewing raceway seismic supports for compliance with current design documents. Field procedures will be revised and personnel trained to these revised procedures. The program for completing this work will be implemented after approval by consumers Power Company.
This is anticipated by September 30, 1983.
2.
Engineering The cable tray support drawings (E-700 series) are being reviewed for specificity and/or completeness and revised where the review indicates additional or revised information is needed. Completion of this effort is scheduled for December 30, 1983.
3.
Quality Control All Seismic Category I raceway and raceway supports will be subject to 100% quality control reinspection upon completion of construction's review program, Reinspection will be performed as part of the construction completion program (CCP) by the quality control organization, which is now part of NPQAD. Quality control procedures have been revised as necessary and personnel trained to the latest revisions.
Actions to Preclude Recurrence Future activities related to installation and inspection of Seismic Category I raceway and raceway supports, including training of appropriate personnel, will be performed in accordance with the design documents and the requirements of the seismic raceway and support status assessment program.
Design personnel have been formally directed to provide sufficient detail on the engineering drawings to permit adequate installation.
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Bechtel Associates Professional Corporation NCAR 70 126548 126554 Final Report August 23, 1983 i
Page 4 j
1 Reportabilit;I The condition was reported to the NRC on July 29, 1983.
The safety of operation of the Midland plant is not affected for the specific cases analyzed. Due to the conservatisms in the design and analytical techniques, no safety concern has been identified.
b Submitted by:
S.L. Sobkowski Civil Group Supervisor Approved by: CST E.M. Hughes Project Engineer Concurrence by:
Y T.E. Johnson d Chief Civil Engineer Concurrence b :
m g
E.H. Smit)
Engineering Manager Concurrence by:
/1
/ A wh f
6 - M.A. Dietrich,
Project Quality Assurance Engineer i
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