ML20027C954

Interim Deficiency Rept 9 Re Underrated Terminal Strips on Limitorque Valve Operators.Initially Reported on 810115. Underrated Terminal Blocks Replaced W/Marathon 300 Series Blocks.Next Rept Will Be Sent by 830131

ML20027C954
Person / Time
Site:	Midland
Issue date:	10/22/1982
From:	Jackie Cook, 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, 19070, 81-01-#9, 81-1-#9, MCAR-46, NUDOCS 8210280076
Download: ML20027C954 (11)

Text

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a-Consumers Power James W Ceek Company via n,u.. r,.i t,, e.,i

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General offices: 1946 West Parnell Road, Jockeen, MI 49201 e (617) 78&O463 October 22, 1982 81-01 #9 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT DOCKET NOS 50-329 AND 50-330 UNDERRATED TERMINAL STRIPS ON LIMITORQUE VALVE OPERATORS File:

0.4.9.47 Serial:

19070

Reference:

J W Cook letters to J G Keppler, same subject:

1) Serial 11190, dated February 13, 1981 2)

Serial 11976, dated April 24, 1981

3) Serial 12041, dated July 8, 1981

4) Serial 13665, dated September 11, 1981

5) Serial 14617, dated November 20, 1981 6)

Serial 14690, dated February 12, 1982 7)

Serial 17503, dated June 4, 1982 8)

Serial 17565, dated August 6, 1982 This letter, as were the referenced letters, is an interim 50.55(e) report concerning the terminal strip voltage ratings on Limitorque valve operators. provides a status of the corrective actions in progress to resolve this problem.

Another report, either interim or final, will be sent on or before January 31, 1982.

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Attachment:

1) MCAR 46. Interim Report #9, " Qualification Concerns for Various Components on Limitorque Valve Operators," dated September 24, 1982 8210280076 821022

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81-01 #9 CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant CBechhoefer, ASLB Panel RSDecker, ASLB Panel FPCowan, ASLB Panel Jilarbour, ASLB Panel AS&L Appeal Panel MMCherry, Esq MSinclair BStamiris CRStephens, USNEC WDPaton, Esq, USNRC FJKelley, Esq. Attorney Ceneral SilFreeman, Esq, Asst Attorney General WlIMarshall GJMerritt, Esq. TNK8J 1

OC1082-0017A-MP01

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?OOhOQ Serial 19070

1. 9 Bechtel Associates Professional Corporatioh-Mansmoment Corrective Action Report (MCAR)

SUBJECT:

MCAR 46 (issced 1/15/81)

Qualification Concerns for Various Components on Limitorque Valve Operators INTERIM REPORT 9 DATE:

September 24, 1982 PROJECT:

Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Description of Deficiency The following deficiencies are covered by MCAR 46:

a)

The use of underrated terminal blocks in Limitorque operators b)

The use of terminal blocks without proper environmental qualifica-tion in Limitorque operators c)

Additional concerns regarding qualification of various Limitorque operator components These concerns are detailed below.

A.

Underrated Terminal Blocks While replacing a damaged terminal block on a Limitorque operator, Bechtel determined that some of the terminal blocks used for the termination of the leads from the 460 V motor were rated less than 460 V.

These Limitorque operrtors, when used on safety related valves, must function on an anergency core cooling actuation signal (ECCAS). In addition to beiag a personnel safety hazard, the potential exists for a short circuit /flashover, which could render the valves inoperative.

B.

Environmental Qualification During random inspection for underrated terminal blocks, it was discovered that in some cases terminal blocks from manufacturers not covered by existing qualification reports were used.

Limitorque provided the following information on environmental qualification of terminal blocks in its July 31, 1981, letter.

8729.5 086960 Bechtel Associates Professional Corporation MCAR 46 1

Interim Report 9 September 24, 1982 l

Page 2 The Buchanan 0524 has been qualified by analysis. To supplement the qualification by analysis, Limitorque is currently running a type test on the Buchanan 0524 terminal block. The Buchanan 0824 terminal blocks are not qualified and must be replaced.

Some of the Limitorque operators having Buchanan 0824 type terminal blocks have been used on safety related valves located inside con-tainment. These operators must function on an ECCAS. The poten-tial exists for a terminal block to fail during its intended service life because of aging and radiation effects, which would render the valve inoperable and prevent proper operation of the safety related system.

C.

Additional Qualification Concerns During June 1982, a random inspection was made of safety related Limitorque valve operators supplied through various valve manufac-turers and installed inside the reactor building. This, inspection resulted in various potential concerns regarding qualification of these Limitorque operators.

Summary of Investigation and Historical Background A.

Underrate Terminal Blocks 1.

The manufacturer's name was the only form of identification found on a damaged terminal block. To order a replacement for the damaged terminal block, it was therefore necessary to measure the block's critical dimensicns and compare them with those for blocks listed in Marathon Catalog 10M79. This l

comparison indicated that the terminal blocks used for the termination of the leads from the 460 V motor could have been rated less than 460 V.

Eighteen Limitorque operators on Bechtel Purchase Order (P.O.) 7220-M-132-AC were inspected and eight were found to have underrated terminal blocks (Marathon l

100 Series and Cinch Jones 140 Series). Thus, Bechtel deter-mined that some terminal blocks in Limitorque valve operators may be underrated for their intended function. The other ten i

operators inspected had Marathon 300 Series terminal blocks which are correctly rated for the intended service. Purchase Order 7220-M-132 is with Henry Pratt Company for the supply of nuclear service butterfly valves.

n86960 08 7 Bechtel Associates Professional Corporation MCAR 46 Interim Report 9 September 24, 1982 Page 3 2.

Representatives from Limitorque and Henry Pratt visited the Midland jobsite on January 31, 1981. After inspecting the terminal blocks, they confirmed the results of Bechtel's investigation.

3.

Randon inspection was performed by Limitorque during the week of May 11, 1981, to establish the magnitude of the presence of the underrated terminal blocks in the Limitorque operators.

Limitorque provided Bechtel with detailed reports of its inspection. After review of the inspection reports, Bechtel determined that underrated terminal blocks were not used on any Q-listed purchase orders except P.O. 7220-M-132(Q).

4.

Seven different types of terminal blocks were identified (Buchanan 0222, 0524, and 0824; Marathon 300 Series; Beau 7600; Kulka 622; and General Electric EB-5) during the random inspec-tion referred to in Item 3 above. All seven types are accep-table for 460 V service.

5.

Arrangements were immediately made by Bechtel to inspect any unshipped valves upon receipt at the Midland jobsite for underrated terminal blocks. Inspection results are tabulated in Item B.7 below.

6.

Limitorque/ Henry Pratt submitted the terminal block replace-ment procedure and Certificate of Compliance for the terminal blocks which Bechtel project engineering approved upon review.

The actual replacement of all underrated terminal blocks on Limitorque's Purchase Order 7220-M-132(Q) was undertaken by Bechtel construction personnel under the supervision of Limitorque service engineering during the second week of June 1982. The replacement work is now complete; all operators on P.O. 7220-M-132(Q) were inspected.

7.

Bechtel has received the inspection / replacement report for the work described in Item A.6 above, from Limitorque and is currently being reviewed.

8.

Limitorque's letter dated June 25, 1981 (Ref: MCAR 46, Interim Report 4, Item A.1) states that terminal block types (Buchanan 0524 and Beau 7600) were previously rated for 600 V service using the breakdown voltage method of rating. A con-cern was raised because no documents are currently available at Bechtel to support this statement. Limitorque will be asked to provide additional documentation and/or justification l

for the use of these terminal blocks for 460 V service.

l

086960 087295 Bechtel Associates Professional Corporation MCAR 46 Interim Report 9 September 24, 1982 Page 4 B.

Enviror. mental Qualification 1.

During the random inspection of underrated terminal blocks, referred to in Item A.3 above, Buchanan 0824 terminal blocks were found on three Limitorque operators purchased from Westing-house on P.O. 7220-M-123A for nuclear service stainless steel valves. Voltage rating data submitted by Limitorque for these terminal blocks were found acceptable. However, these terminal blocks are unacceptable because of Limitorque's previously cited finding that these blocks "are not" environmentally qualified and "must be replaced."

2.

According to Limitorque, the use of unqualified terminal block type Buchanan 0824 is limited to P.O. 7220-M-123A(Q)-AC with Westinghouse Electric, based on Westinghouse's specific require-ments. These blocks are not qualified and would require replacement with properly qualified terminal blocks. Based on random inspection results, it was concluded that Buchanan 0824 terminal blocks are not used on any other P.O.

3.

Of the seven terminal blocks listed in Item A.4 above, Limi-torque stated that terminal blocks types Buchanan 0222, Buchanan 0524, Curtis Type L, Marathon 300 Series, and General Electric EB-5 were environmentally qualified for inside contain-ment, but were unable to provide the required qualification documentation.

4.

Limitorque presently has no specific plans for an environmental testing of the remaining terminal block types Kulka 622 and Beau 7600 for outside containment use.

5.

Environmental qualification documentation for terminal block types specified in Items B.3 and B.4 above was returned to Limitorque with comments. Currently, the acceptability of all terminal block types remains indeterminate pending resolution of Bechtel comments. It is expected that Limitorque will be resubmitting these qualification documents by September 30, 1982.

6.

Bechtel field engineering has generated Nonconformance Report (NCR) 3780 against valves 2MO-1111, 2M0-1101B, and 2M0-1120B purchased from Westinghouse Electric on P.O. 7220-M-123A(Q)-

AC, Items 4.2, 5.4, and 5.8, respectively. This NCR was initiated at the request of project engineering because of the presence of an unqualified terminal block, Buchanan 0824

386960

,.87295 Bechtel Associates ProfessionalCorporation MCAR 46 Interim Report 9 September 24, 1982 Page 5 i

7.

The following 18 operators were to be inspected upon receipt from the vendors at the jobsite for the presence of noncon-forming terminal blocks. The status is as follows:

Terminal Block (TB)/

P.O. Number Item (Quantity)

Remarks 7220-J-255A(Q) 23(8)

TB Kulka 622 7220-M-117(Q) 5.1(1)

Under investigation 7220-M-117(Q) 5.2(1)

(Valves converted to 7220-M-117(Q) 5.3(1) manual type; operators 7220-M-117(Q) 5.4(1) have been surplused) 7220-M-168(Q) 1.5(1)

TB Buchanan 0222 7220-M-398(Q) 1.1(1)

TB Kulka 622 7220-M-398(Q) 1.2(1)

TB Kulka 622 7220-M-398(Q) 3.1(1)

TB Kulka 622 7220-M-398(Q) 3.2(1)

TB Kulka 622 7220-M-398(Q) 3.3(1)

TB Kulka 622 All operators listed above are located outside containment.

The terminal blocks' voltage ratings are acceptable. However, environmental acceptability is pending review and acceptability of the Limitorque qualification documentation described in Item B.5 above.

C.

Additional Qualification Concerns 1.

The motor nameplate ambient temperature rating on various l

motors installed inside the containment on some Limitorque operators is 40C. The specified reactor building ambient temperature is 50C, and these valves are required to function j

post accident.

2.

The motor insulation on various motors installed on some l

Limitorque operators lists the motor insulation as Classes B l

or H.

It is not presently known whether these types of insula-tion are suitable for the service conditions because they are not covered by Limitorque qualification reports.

3.

No identification was evident on certain materials internal to the Limitorque operators (e.g., wiring, insulation, etc.).

It is not presently known whether these materials are qualified for the service conditions.

086960 Bechtel Associates Professional Corporation 8723a MCAR 46 Interim Report 9 September 24, 1982 Page 6 4.

Various orientations of installed operators were observed. It is not presently known whether the operators are qualified for all installed orientations.

5.

Drain plugs on operators were observed to be both in place and removed. Orientation of the operators did not always result in the drain holes being at the lowest point of the installed operator.

It is not presently known whether the existence of the drain plug or the orientation of the drain hole is essen-tial to proper operation of the operator or is in conformance with the qualification tests for the operator.

6.

Various Limitorque operator limit switch gear frames were observed to be made of a white metal. It is not presently known whether material of gear frame is qualified for the service conditions.

7.

Information obtained from purchase order files and QVDP files does not agree with the installed components.

8.

It is presently not known whether space heaters are qualified or required to be qualified.

9.

Various 0 rings are located throughout the actuator. It is not presently known whether these components are qualified for the service conditions.

10.

Unidentifiable terminal blocks (nonpower lead connectors inside the operators) were observed in other Limitorque operators. It is not presently known whether these components are qualified for the service conditions.

To discuss the concerns listed in C.1 through C.10 above, a meeting was held at Limitorque on August 31, 1982.

Safety Implications and Reportability 1.

Seven of the eight valve operators having underrated terminal blocks are located in the component cooling water and service water systems and are used on safety related valves. These must function on an emergency core cooling actuation signal. The potential exists for a short circuit /flashover which could render the valves inoperative.

86960 Bechtel Associates Professional Corporation 087295 MCAR 46 Interim Report 9 September 24, 1982 Page 7 Based on the potential safety concerns, this item was considered reportable. This deficiency was reported by Consumers Power Company on January 14, 1981, to R. Sutfin, R. Cook, and R. Knop of the Office of Inspection and Enforcement, Region III, U.S. Nuclear Regulatory Commission, as a reportable deficiency for Midland Plant Units I and 2 in accordance with 10 CFR 50.55(e).

2.

The concerns expressed above are regarded as indeterminate because insufficient information exists to classify them otherwise. These concerns are presently being evaluated and will be addressed in the next interim report.

Probable Cause A.

Underrated Terminal Block According to Limitorque, it does not stock Marathon 100 Series terminal blocks. However, Limitorque believes (according to its January 21, 1981, letter) that when its field service engineer visited the Midland jobsite in November 1977 to increase the number of points on the terminal blocks for 66 operators (P.O. 7220-M-132),

ha may have procured the subject terminal blocks locally. Limitorque further explained that an additional 20 terminal blocks (140 Series, manufactured by Cinch Jones) were shipped to Midland, to make up for quantities damaged in an earlier shipment. These blocks are similer to Marathon Series 100 blocks and may have been used by the Limitorque service engineer to terminate the 460 V motor leads.

According to Limitorque's July 1, 1982 letter, the root cause for the presence of underrated terminal blocks was the lack of adequate training for a newly employed field service engineer.

B.

Unqualified Terminal Block According to Limitorque's July 1,1982, letter, Buchanan 0824 ter-minal blocks have not been tested for environmental qualification.

These terminal blocks were furnished with actuators built in 1974 to the specific requirements of an individual valve manufacturer.

However, the terminal blocks were considered qualified by analysis at the time they were supplied. The Buchanan 0824 uses nylon construction, which is unacceptable in today's nuclear industry.

It is Limitorque's opinion that this terminal block would pass a

086960 Bechtel Associates Professional Corporation n87295MCAR 46 Interim Report 9 September 24, 1982 Page 8 nuclear qualification test; however, because of the stigma attached to the use of nylon in this application, the terminal block would still be considered unacceptable.

C.

Additional Qualification Concerns The additional concerns addressed above are still being evaluated.

A discussion on the probable causes of these concerns will be covered in a future interim report.

Corrective Action A.

Underrated Terminal Blocks During Limitorque's June 1982 inspection / replacement trip to the Midland jobsite, all underrated terminal blocks were replaced by correctly rated Marathon 300 Series terminal blocks on operators purchased on P.O. 7220-M-132(Q). Thus, this deficiency will be considered completely resolved, pending acceptance of the report covering the inspection / replacement activities and Limitorque's response regarding use of terminal block types Buchanan 0524 and Beau 7600. The review of the report is expected to be complete by October 4, 1982.

B.

Unqualified Terminal Blocks 1.

Resubmittal of the qualification report from Limitorque is expected by September 30, 1982.

2.

Bechtel project engineering is to provide procurement with specifics for further inspection and replacement for unquali-fled terminal blocks by November 8, 1982. This will include l

terminal blocks on all Limitorque operators located inside containment, outside containment in harsh environments, and those purchased on P.O. 7220-M-123A(Q ).

3.

Bechtel project engineering is to disposition NCR 3780 by l

r November 15, 1982.

i'87295 Bechtel Associates ProfessionalCorporation MCAR 46 Interim Report 9 066960 September 24, 1982 Page 9 C.

Additional Qualification Concerns Arrangements are being made with Limitorque to review the docu-mentation of each Limitorque operator for the expressed concerns.

The unqualified components / operators shall be replaced with qualified ones in accordance with Limitorque's recommendation (s). Based on the results of this arrangement, further required actions will be reported in future interim reports.

Submitted by:p.

N' &

7 Ferre"<asee g

y T. Ballweg 7

Mechanical Group g

Supervisor Appro E.M. Hughes (

Ann Arbor Project Engineer Concurrence by:

M. Fravel Chief Mechanical Engineer p

b Concurrence by:

rL L E. Smith Engineering Manager Concurrence by:

W M.A. Dietrich 4

Project Quality Assurance Engineer

.